The following Privacy Statement is applicable on the use of our websites, products, services, or otherwise by interacting with Us. It applies to the processing of personal data carried out by Sinch AB (publ) or any of its subsidiaries (“We”, “Our”, “Us” or “Sinch”). The websites and Portals of Sinch are operated by Sinch Sweden AB unless we state otherwise. This includes how your personal information is collected, used, and shared when you visit or make a purchase from sinch-swag.com (the “Site”). Please do not engage in any of these activities if you do not agree with the terms of this Privacy Statement.

This statement is divided into two parts. Your personal data will be processed by Sinch in accordance with the privacy notice for Sinch Group employees, which you can find here. The information that you find on this website will only be applicable on the data processing in the context of your use of this website and should be seen as additional information to our privacy notice. We encourage you to read the entire statement (even if it might be a bit long) but if you plan to skip reading the statement and just accept, please do note a quick overview: 

• That Sinch does not sell your personal data to third parties.
• That Sinch may share your personal data within the group if necessary, to provide the service that you requested or to answer your question in the best way possible.
• That Sinch website is structured specifically to not attract anyone under 13, nor do We collect or maintain Personal Data on the Site from those who Sinch actually knows are under 13.
• That Sinch may transfer your personal data to countries outside of the EU/EEA. If we do this, we take sufficient technical, organisational and contractual measures to ensure that an adequate level of data protection is provided.
• We use various sub-processors to make this website possible and to allow you to order Sinch merchandise.
• That Sinch has a Group Data Protection Officer, based in Stockholm, Sweden. She can be reached via DPO@sinch.com whenever you want to use the rights to access, rectification, erasure, object, revoke consent or block data or have any questions. Your rights as described within our privacy notice for Sinch Group Employees have not changed and can be found there.
• In case you are an external (non-Sinch) party that wants to request information from Sinch or data that is being processed within this webshop, please see “Legal and Authority Requests” below.

 

Let’s start at the beginning: who is “we”?
The Privacy Statement applies to the processing of personal data carried out by Sinch AB (publ) or any of its subsidiaries (“We”, “Our”, “Us” or “Sinch”). The websites and Portals of Sinch are operated by Sinch Sweden AB unless we state otherwise.  We belong to the Sinch Group of which the head office is Sinch AB (publ.) located at the Lindhagensgatan 74 (postal code: 112 18) in Stockholm, Sweden (hereafter: “Sinch Group”).

So why are we informing you?
As you are used to, for employee data, Sinch is what is known as the “controller”. That means that we are responsible for the processing of your personal data and if you want to use your rights, have any questions or complaints concerning what we do, you can contact us. The law tells us that we need to inform you to fulfil our legal and contractual obligations and be able to conduct business securely and efficiently and for other specific purposes that are described in this notice as for this we need to process certain personal information about you (referred to as “personal data”).

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which when collected together or combined with other information can lead to the identification of a particular person, is also personal data.

Your personal data will be processed by Sinch in accordance with the privacy notice for Sinch Group employees, which you can find here. The information that you find on this website will only cover the use of this website and the shop.

For more information on which personal data we are processing, please read “Next questions: Who provides us with personal data, which information will we have and what will we use the data for?”

Next questions: Who provides us with personal data, which information will we have and what will we use the data for?

Who provides us with your personal data?
There are three sources that provide us with personal data: you yourself, Sinch and third parties such as ESM (later more about that). You as We might ask you to provide us with personal data in preparation of the concluding of your order or when you ask us a question. Third parties may also provide us information about you. For example, ESM will use the order information to tell us who has ordered what and whether they have received this, so we can keep track of this.

 

Which information will we have and what will we use the data for?
We will only process this personal data to fulfil the purposes stated in the privacy notice for Sinch Group Employees and the Data Processing Matrix below, and to comply with the law and what is necessary according to law in each jurisdiction.

Purpose	Personal data type and source	Legal ground	Retention time or criteria
To enable Sinch to provide you the service that you have requested, for example send you an answer to a question that you have filled into a form or send to one of the Sinch (or Sinch Contractors) email address	Contact data; such as phone number, email address, address, name, company, language   Content data: information concerning your request that you send to us   Source: Directly from you and/or via third party and/or created by Sinch	Required within the contractual relationship between us, Legitimate interest and/or required by law	As long as required in accordance with applicable law or 2 years after order
To enable Sinch or Sinch Contractors to administer any acceptance to terms and conditions as are show on the website	Contact data; such as phone number, email address, address, name, company,   Device data: such as your web browser, IP address, language, time zone, and some of the cookies that are installed on your device.   Source: Directly from you and/or via third party and/or created by Sinch	Required within the contractual relationship between us, Legitimate interest and/or required by law	As long as required by law, required by business process (you are informed at the time when you give us the information) or until you request that we remove you from the opt-out/opt-in list or you have revoked your consent
To enable Sinch or Sinch Contractors to deliver the ordered product(s) to your home or by you selected address	Contact data; such as phone number, email address, (shipping) address, name, company,   Order information: currency information, ordered product, contact preference and any other information that you may provide to Sinch     Source: Directly from you and/or via third party and/or created by Sinch	Required within the contractual relationship between us, Legitimate interest and/or required by law	As long as required in accordance with applicable law or 2 years after contact without business relationship or 5 years after end of the business relationship or when requested to be deleted and request can be honoured.
To enable Sinch to operate, administer access and use of the forums, websites, portals it provides to customers, resellers, developers and other user groups. This may include sending you services announcement (for instance, if Our service is temporarily suspended for maintenance).	Contact data; such as phone number, email address, name, company, position, contact preference and any other information that you may provide to Sinch   Technical data: such as but not limited to, http headers, computer settings when stored, log information on use of portal/forum   Source: Directly from you and/or via third party and/or created by Sinch	Consent and /or Legitimate interest and/or required by law and/or to administer contracts that you have with Sinch.	As long as required in accordance with applicable law or 2 years after contact or 5 years after end of the business relationship or when requested to be deleted and request can be honoured.
To enable Sinch to protect its website, against threats and fraud and find vulnerabilities.	Contact data; such as phone number, email address, address, name, company, position, contact preference and any other information that you may provide to Sinch   Technical and device data: such as but not limited to, http headers, computer settings when stored, log information on use of portal/forum,     Source: Directly from you and/or via third party and/or created by Sinch	Legitimate interest and/or required by law	As long as required in accordance with applicable law or 2 years after contact or 5 years after end of the business relationship or when requested to be deleted and request can be honored.

 

What is Device and Technical information information?
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

We collect Device Information using the following technologies (only as far as necessary to provide you with the website):
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

 

Who has access to my personal data? 

Sinch Internal
Personal data will only be available to authorized employees holding a position that requires them to process personal data to perform their work. These employees will only be granted access in accordance with the principle of "least privilege", meaning that our personnel will only have access to personal data that is strictly necessary for the purpose of the processing to perform their work.

Due to the fact that Sinch carries out business activities in a number of different countries, personal data may need to be transferred to Sinch affiliates and/or subsidiaries outside of your own home country that need to receive the personal data for the Sinch group's internal purposes or the purposes in this statement. This transfer is based on a legitimate interest as it is necessary within the Sinch Group for purposes as described.

That does not mean that we just provide the information to anyone without limitations. We do look at the nature of the data and whether it is necessary for our purposes. If not, then we do not use it.  We will, of course, only use data in ways that you would reasonably expect and that have a minimal privacy impact (we put appropriate safeguards in place, such as limiting access to the information and anonymise/pseudonymise the personal data where possible).

Based on the reasons we want to process the personal data and our efforts to minimize the privacy impact, we do not expect that it is likely that you will object to it. If you might want to object to it or just would like to receive more information, please read our privacy statement, and contact us on dpo@sinch.com.   

Below you will find a schedule of Sinch Group Companies where Sinch Group employees sit that may have access to your personal data (depending on your geographical location).

Name company	Address
Sinch AB (publ)	Lindhagensgatan 74, 112 18 Stockholm (Sweden) Org. number 556882-8908 - Stockholm
Sinch Sweden AB	Lindhagensgatan 74, 112 18 Stockholm (Sweden) Org. number 556747-5495 - Stockholm
Sinch Holding AB	Lindhagensgatan 74, 112 18 Stockholm (Sweden) Org. number 559061-2791 - Stockholm
Sinch UK Ltd.	Cap House, 9-12 Long Lane, London, EC1A 9HA (England) Org.-number 03049312 - London
Sinch America Inc.	7000 Central Parkway Suite 1480. Atlanta, GA 30328 (USA) Org. number 77220277010 - USA

 

Authorities
Sinch may need to provide personal data to relevant authorities (e.g. social insurance agencies and the tax authority) in accordance with mandatory law, in order to fulfil legal obligations in the jurisdiction where we (in the future) employ our employees and/or when we get a request of an authority. We will only do this when we have a legal ground to do this and will ensure to take appropriate security measure to protect the personal data.

 

Companies engaged by Sinch
In addition to the Sinch Group internal companies, your personal data will be transferred to ESM (ESM Branding, The Studios, Luckings Estate, Magpie Lane, Coleshill, Bucks, HP7 0LS, United Kingdom) (also known as “data processors”), to enable these companies to perform the services requested by us.   

All third-party providers and suppliers must follow our instructions and have entered into a, by law required, written agreement. Our third-party providers must implement appropriate technical and organizational measures for the protection of the personal data and we regularly check whether they fulfill the requirements that we have given to these companies.

To which kind of countries will my personal data be transferred?
Even within the Sinch Group, your personal data may be transferred to countries outside of the European Union. To ensure that Sinch compliant with legislation and Sinch Group's current policies regarding transfer of personal data, and that we take the appropriate measures to keep your personal data secure, Sinch uses a data processing agreement that fulfils the requirements set by the GDPR, in combination with appropriate technical and organizational measures for the protection of the personal data. If personal data needs to be transferred to a country that offers a lower level of protection for personal data than is required by applicable law (for example: USA or India), we will conclude the European Standard Contractual Clauses (that were decided upon by the European Commission) and do regular follow-ups to see whether our requirements are fulfilled.

We do not process personal data of children
Protecting the privacy of children is important to Sinch. For that reason, the Site is structured specifically to not attract anyone under 1, nor do We collect or maintain Personal Data on the Site from those who Sinch actually knows are under 13. If Sinch learns or is notified that it has collected information from users under the age of 13, Sinch will immediately delete such Personal Data. If you think that we have collected information from your children or children that are in your care, please contact DPO@sinch.com.
We don’t sell personal data
As a matter of policy, We do not sell or rent any of your information to third parties for any advertising or marketing purposes. We may disclose your information in the normal course of providing Our services or sending of Information (so towards subprocessors that act on behalf of Sinch).

Legal and Authority requests
Our employees and internal policies require us to have processes and procedures in place to ensure that we only provide information when we are required to do so. Sinch however also knows that it is our responsibility to fulfil requests of authorities whenever the law obliges us to do so. Sinch acknowledges that there is a fine line here that requires internal documentation and thorough assessment and has set up a process to implement these practices within the entire group.

All requests for data and information, preservation requests, preservation extension requests should be submitted to authorityrequests@sinch.com  or, if the request needs to be served in person or via mail to the registered address of the company of which you request the information.

Acquisitions
If another company acquires (part of) Sinch or its assets, that company will (a) process that Personal Data held by Sinch, and (b) assume the rights and obligations regarding such Personal Data described in this Privacy Policy.

Changes to this Privacy Statement and/or Cookie Statement
We reserve the right to modify this Privacy Statement and the Cookie Statement at any time, so please review it regularly. If We make changes to this Privacy Policy or the Cookie Statement, We will post the revised statement on the website and other places We deem it to be appropriate. If We change the material content of the statements, We will summarize these within the next statement. All such changes shall be binding on moment of publication.