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Privacy policy

Our aim is that you always feel confident that the information and personal data you entrust us with are handled in a responsible, accurate, and secure manner. Additionally, you should feel assured that your personal data is processed in accordance with the legislation and regulations applicable in this field.

In our privacy policy, we want to explain how we at Rusta handle your personal data. Please note that this privacy policy only applies to you as a shareholder or as a representative of a shareholder or as a holder of or as a representative of a holder of other financial instruments that can be converted to, or that entitle to subscription of shares in Rusta (a “Shareholder”), as well as to visitors of our website www.investors.rusta.com. When you visit www.rusta.com, purchase goods and services from Rusta, become a member of Club Rusta, or interact with Rusta in any other way, you are instead covered by our general privacy policy (https://www.rusta.com/se/sv/information/integritetspolicy/).

In this document, you can also learn more about the rights you have in relation to Rusta and how you can exercise these rights. If you have any further questions after reviewing the content of this policy, you are always welcome to contact Rusta by sending an email to gdpr@rusta.com.

To facilitate your access of the contents of our privacy policy, you will find an overview of this privacy policy below. Simply click on the relevant heading to jump directly to the desired section.

Contents of this privacy policy

Who is responsible for the personal data that I entrust to Rusta?

What is a “Data Protection Officer”?

What is the purpose of Rusta’s collection of personal data and what personal data does Rusta collect about me as a Shareholder?

What is the purpose of Rusta’s collection of personal data and what personal data does Rusta collect about me as a visitor of www.investors.rusta.com?

For how long does Rusta store my personal data?

To which partners does Rusta disclose my personal data and information about me?

Where, geographically, does Rusta process my personal data?

What rights do I have?

Links to other websites.

How do I contact Rusta about data protection?

Can Rusta adjust this privacy policy?

Who is responsible for the personal data that I entrust to Rusta?

Rusta AB, registration number 556280-2115, Kanalvägen 12, 4th floor, Box 5064, SE-194 05 Upplands Väsby, Sweden, is the so-called “data controller.” This means that we are responsible for ensuring that the handling of the personal data that you entrust to us is carried out in a responsible, accurate, and secure manner. It also means that we are responsible for ensuring that processing is carried out in accordance with the legislation and regulations applicable in this field.

The central securities depository is the data controller of the personal data in the central securities depository register.

What is a “Data Protection Officer”?

Rusta has appointed a Data Protection Officer. Our Data Protection Officer’s responsibilities include ensuring that Rusta processes all the personal data that you entrust to us in accordance with the legislation and regulations applicable in this field. The contact information for Rusta’s Data Protection Officer is gdpr@rusta.com or Rusta AB, Box 5064, SE-194 05 Upplands Väsby, Sweden. Please mark your letter with “Data Protection Officer.”

What is the purpose of Rusta’s collection of personal data and what personal data does Rusta collect about me as a Shareholder?

Which personal data do we process?

Your personal data may be shared with us directly by you or by the Rusta that you represent. If your personal data is included in the central securities depository register, it may also be disclosed to us by the central securities depository, Euroclear Sweden AB (publ). The personal data that we process includes:

  • contact information, such as name, position, address, telephone number and e-mail address;
  • personal identification number;
  • corporate registration number (if possible to connect to you as a person);
  • holdings of shares or other financial instruments;
  • financial information, e.g. information regarding voting rights at general meetings of shareholders, shareholding and rights relating to such holding;
  • if applicable, information regarding proxies representing shareholders;
  • if applicable, information regarding guardianship, pledges and pledgees, and other notes in the central securities depository register;

Other information provided by you or by the organisation that you represent or that we receive from the central securities depository may also be processed.

Purposes and legal basis for the processing

The purposes for which we process your personal data and the legal basis for each processing activity are set out in the table below.

For what purpose is the personal data collected?

Legal basis

To fulfil the Rusta’s obligations towards you as a Shareholder according to the Rusta’s articles of association.

Performance of contract

The processing is necessary in order to perform the Rusta’s contractual obligations towards you according to the articles of association.

Legitimate interests

The processing is necessary for the Rusta’s legitimate interest of performing its contractual obligations towards its Shareholders (applicable only to representatives of Shareholders).

 

For what purpose is the personal data collected?

Legal basis

To fulfill the Rusta’s obligations towards you as a Shareholder according to the Swedish Companies Act (Sw. aktiebolagslagen) or other applicable legislation or pursuant to the Rusta’s listing agreement.

Compliance with legal obligations

The processing is necessary to fulfill the Rusta’s legal obligations under the Swedish Companies Act or other applicable legislation.

Legitimate interests

The processing is necessary for the Rusta’s legitimate interest to perform its obligations under the Rusta’s listing agreement with the marketplace/stock exchange where the Rusta’s shares are traded.

The processing is necessary for the Rusta’s legitimate interest in performing its legal obligations towards its Shareholders (applicable only to representatives of Shareholders).

 

For what purpose is the personal data collected? Legal basis

To distribute shareholder-related information

Compliance with legal obligations

The processing is necessary to fulfill the Rusta’s legal obligations under the Market Abuse Regulation.

Legitimate interests

The processing is necessary in order for the Rusta to be able to provide Shareholders and other stakeholders with regulatory information and other information regarding the Rusta in a timely manner.

What is the purpose of Rusta’s collection of personal data and what personal data does Rusta collect about me as a visitor of www.investors.rusta.com?

For what purpose is the personal data collected?  What types of processing are carried out? Which categories of personal data do we need from you?

Administration of the website.

  • Collection of statistics and information about website visitors.
  • IP-address

Legal basis: Consent. The processing is carried out with your consent to our use of cookies.

 

For what purpose is the personal data collected? What types of processing are carried out? Which categories of personal data do we need from you?

Administration of our relationship with you as a subscriber to our newsletter and other communication from Rusta.

  • Communication with you.
  • Name
  • Contact details (e.g. address, telephone number, email address)

Legal basis: Legitimate interest. The processing is necessary for the purpose of Rusta’s legitimate interest in administering the relationship between you and Rusta.

 

For what purpose is the personal data collected?  What types of processing are carried out? Which categories of personal data do we need from you?

Responding to your questions, requests, or other forms of contact initiated by you.

  • Communication with you and answering any questions that you may have.
  • Handling and investigating any complaints.
  • Name
  • Personal identification number
  • Contact details (e.g. address, telephone number, email address)
  • Correspondence

Legal basis: Legitimate interest. The processing is necessary for the purpose of Rusta’s legitimate interest in responding to your questions, requests, or other forms of contact.

 

 For what purpose is the personal data collected? What types of processing are carried out? Which categories of personal data do we need from you?

Compliance with the Rusta’s legal obligations.

  • Processing necessary for compliance with the Rusta’s legal obligations.
  • Name
  • Personal identification number
  • Contact details (e.g. address, telephone number, email address)
  • Correspondence

Legal basis: Legal obligation. The processing is necessary for compliance with Rusta’s legal obligations. If the information is not provided, our legal obligations cannot be complied with, and it may affect your ability to exercise your rights under law.

For how long does Rusta store my personal data?

Rusta will not store your personal information for longer than is absolutely necessary to fulfil the purposes for which the data was collected. After that, your data will be deleted or de-identified.

To which partners does Rusta disclose my personal data and information about me?

Data processors: Rusta may need to disclose your personal data to third parties, such as other companies within the group, IT suppliers, or companies with whom we collaborate to provide our products and services.

However, Rusta establishes agreements with all data processors beforehand. Through these agreements, data processors guarantee the security of the personal data they process and commit to comply with Rusta’s security requirements and limitations, as well as requirements regarding international transfers of personal data.

Other data controllers (third parties): Rusta may also need to disclose personal data to third parties in situations where there is a legal obligation to do so, or to fulfil Rusta’s commitments to you. When personal data is shared with other data controllers, their privacy policy and data management practices apply.

Please note that Rusta does not sell your personal data to third parties for advertising purposes.

For Shareholder’s

Rusta’s share register is public information and Rusta shall afford anyone who so requests an opportunity to review a current printout or other current presentation from the share register at Rusta’s offices. The information included in the share register will therefore be disclosed upon request. Further, information regarding shareholders is disclosed to the extent necessary for the fulfilment of Rusta’s legal obligations, e.g. when submitting income statements to the Swedish Tax Agency (Sw. Skatteverket) in connection with distribution of dividends.

Minutes and voting list from general meetings of shareholders may be disclosed to Shareholders who are present at the meeting as well as to the Swedish Companies Registration Office (Sw. Bolagsverket), auditors and others to whom Rusta has a legal obligation to disclose the minutes or otherwise considers it appropriate to disclose the minutes. In addition, minutes from general meetings of shareholders, however, without the voting list, may be published on Rusta’s website.

Information regarding inter alia major Shareholders may be disclosed to authorities, advisors and the public in connection with the preparation of prospectuses, information memoranda and financial reports and may also be disclosed on Rusta’s website.

Personal data may also be shared with other trusted parties such as professional advisors and auditors.

Where, geographically, does Rusta process my personal data?

Rusta strives to process your personal data within the EU/EEA. When transferring personal data to a country outside the EU/EEA, Rusta will take measures to ensure that the personal data continues to be protected. We will also take those measures that are necessary to legally transfer personal data to countries outside the EU/EEA. For example, Rusta may transfer data collected by Google Analytics on Rusta’s website to Google in the U.S. However, Rusta has ensured that your personal data is protected through Google’s accession to the EU-U.S. Data Privacy Framework. More information on the EU-U.S. Data Privacy Framework is available at https://www.dataprivacyframework.gov/s/.

What rights do I have?

You have the right at any time to obtain, free of charge, an extract with information about what personal data is registered about you. In this extract, you can also receive information about the purposes of the processing of this personal data, as well as information about the origin of this personal data and to whom the data has been or will be disclosed. You also have the right in your extract to receive information about how long the data will be stored or the criteria used to determine this period.

A request to access such information must be made in writing and should be sent to Rusta’s customer service at the address provided below in the section ‘How do I contact Rusta about data protection?’

You also have the right to data portability. Data portability means the right, under certain conditions, to receive and transfer your personal data in a structured, commonly used, and machine-readable format to another data controller.

Rusta will, at your request or on its own initiative, correct, de-identify, complete, or delete data that is found to be incorrect, incomplete, or misleading. However, Rusta is, in some cases, legally obligated to process your personal data even if you have requested its deletion.

In certain circumstances as set forth in applicable data protection legislation (for example, if you question the accuracy of the personal data or the legality of the processing), you have the right to request the restriction of further processing of your personal data, as well as the right to object to processing.

If you want to exercise any of the above rights, have questions about what personal data Rusta has about you, or want to know more about this privacy policy, please do not hesitate to contact us. Contact information for Rusta can be found under the heading ‘How do I contact Rusta about data protection?’

Please contact us if you are dissatisfied with Rusta’s processing of your personal data. We will do our utmost to address your complaints. At Rusta, our goal is that you should always feel confident that the information and personal data that you entrust to us is handled responsibly, accurately, and securely, in accordance with the legislation and regulations applicable in this field. If, in your opinion, Rusta fails in this endeavour, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection, or the national data protection authority in another EU/EEA country of your choice.  

Links to other websites

On www.investors.rusta.com,  there may be links to external websites which Rusta does not control. These links are not covered by this privacy policy. Rusta does not take responsibility for the content of websites linked to from www.investors.rusta.com.

How do I contact Rusta about data protection?

If you have questions about how Rusta handles your personal data or if you wish to exercise your rights, please do not hesitate to contact Rusta by email at gdpr@rusta.com, by phone at +46 771 28 10 10, or by mail at Rusta AB, Box 5064, SE-194 05 Upplands Väsby, Sweden. Please mark your letter with “Data Protection Officer”.

Can Rusta adjust this privacy policy?

Rusta reserves the right to adjust this privacy policy at any time. In the event of minor adjustments, we will publish the updated privacy policy on our website www.investors.rusta.com, together with information about when the changes will take effect. If Rusta were to make more significant changes to the privacy policy, we will inform you via email, provided that we have access to your email address. If we do not have access to your email address, we will, to the extent possible, inform you through other means. If you do not accept the changes made by Rusta in the privacy policy, you have the right to request that Rusta ceases the processing of the personal data you have entrusted to us before the changes to the privacy policy take effect.