Privacy Policy

Last Updated: 2025-05-05

1. Introduction

This Privacy Policy explains the privacy practices at CLVR Benefits AB, a company registered in Sweden.

Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you and/or your personal data in connection with your use of our website and any services provided by us. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

CLVR is a data processor for the purpose of providing the CLVR Benefits platform and its services. Either the Client, Benefit Provider or any other third party is the data controller.

CLVR is the data controller for any data collected via the CLVR website.

If you have any questions about how we protect or use your data, please email us at hello@clvrbenefits.com.

2. What this Privacy Notice applies to

This Privacy Notice relates to your use of our website, the CLVR Benefits platform, and any services we provide to you. The Privacy Notice does not apply to any information gathered by any benefit provider, card services provider or other third party you link to through the website or the CLVR Benefits platform, which will be processed by them in accordance with their privacy notices or policies.

3. Collection of Personal Data

The personal data we collect and retention periods

CLVR Benefits will enter into a specific Data Protection Agreement with all Clients offering the platform to its employees and all Benefit Providers to ensure all personal data is processed in accordance with local legislation.

The personal data we collect about you depends on the particular activities carried out through our website and/or on the CLVR Benefits platform. The platform may be customized after our clients' specific requests and geographical location, which means the collection of data may differ between users depending on the services delivered to the Client and its employees through offering CLVR Benefits as a flexible benefit platform.

We may collect and use personal data about you mentioned in the below table and will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Data category	Type of data	Purpose
Identity and Contact data	First name, last name, date of birth, social security number	To perform the contract entered into between CLVR and your Employer To transfer any potential subscriptions to the employee as a private person in the event of a termination of employment
Billing and Contact Information	Billing address, delivery address, private and work email address and phone numbers	To confirm orders with relevant data to Benefit Providers To transfer any potential subscriptions to the employee as a private person in the event of a termination of employment To notify you of updates of the services, functionality, terms of the platform To request your participation in a survey that is necessary for CLVR to understand the customer needs and further develop the platform
Profile data	Password, start date, end date	To perform the contract entered into between CLVR and your Employer To ensure secure log ins
Interests and preferences	User preferences and interests	To understand the customer needs To enable relevant marketing to the user
Transaction Data	Details about order and payments to and from you and other details of products and services you have purchased	To perform the contract entered into between CLVR and your Employer To enable application of discount codes To enable billing between CLVR, Benefit Providers and the Company To provide insights for the Clients on usage of the platform from their employees
Reward Data	Annual salary, pension, benefit allowance and insurances	To perform the contract entered into between CLVR and your Employer To accurately portrait correct total reward information and active pension and insurances To enable usage and as correct calculations of mock payslips as possible
Technical Data	Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.	To ensure the platform is secure and to prevent fraud through the platform. Necessary to comply with legal obligations To improve our services and ensure our technology remains at the forefront of industry standards To enable trouble shooting support
Usage Data	Information about how you use our website, the CLVR Benefits platform and services (so called cookies)	To improve user experience of the platform
Feedback and Survey responses	User feedback and survey responses	To understand the customer needs and further develop the platform from a user experience perspective Feedback on Benefit Providers and general supply on the platform
Marketing and Communications data	Communication preferences, historical purchases or orders made by you, your interests, preferences of products	To understand your communication preferences from CLVR benefits and its benefit providers Historical purchases or invoicing through the Platform To understand consumption patterns and make suggestions and recommendations to you about products and/or services that may be of interest to you Necessary to understand how customers use our services and how to improve and grow our business from a customer satisfaction perspective

CLVR Benefits has a Data Retention Policy that is in line with the requirements of the GDPR and other relevant legislation.

CLVR Benefits also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will only be used for the specific areas where essential and in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Additionally, to complete a purchase on the platform, the end user must confirm that CLVR Benefit has the consent to securely share relevant personal data to the benefit provider, necessary to complete their delivery of product and/or service toward you as a customer. Once the order is placed and confirmed, the Benefit Provider is responsible for the processing of the personal data. Should you place an order with a benefit provider outside of the platform, using a promotional code or similar, the Benefit provider is responsible for the processing of your data.

Failure to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you or your employer, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel service you have requested or entered into with us. However, we will notify you if this is the case at the time.

4. Usage of personal data

In general, the data we collect about you is essential to deliver a high performant, secure and service oriented platform and we do not rely on asking your consent for the collection of your data. However, in the cases where your data is wished to be collected, but not essential, we will ask for your consent before processing the requested data. Should you previously have given consent, you have the right to withdraw such consent at any time by contacting us.

We use your information when the law allows us to in the following ways:

to carry out our obligations relating to your contracts with us and to provide you with the information, products and services that you request from us;
to comply with any applicable legal and/or regulatory requirements;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

5. Disclosure of your information

We may share your personal data with selected third parties where we have a lawful basis to do so including:

companies within our group of companies, located in or outside of Sweden and European Union, for the supply of our Services;
affiliates, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you including employers who subscribe to our services, benefits providers who offer their products through the CLVR Benefits platform;
analytics and search engine providers that assist us in the improvement and optimisation of our site;
fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity;
affiliates, business partners, suppliers and sub-contractors who may be in a position to offer related services to you and you have consented to be contacted by them.

6. International transfers

Some of our external third parties are based outside Sweden, which means their processing of your personal data will involve a transfer of data outside Sweden.

Whenever we transfer your personal data out of Sweden, however still within the EU, we ensure a similar degree of protection in relation to GDPR is implemented.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Sweden.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Your Rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data - The right to be provided with a copy of your personal data
Correction (also known as rectification) - The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten) - The right to require us to delete your personal data—in certain situations
Restriction of use - The right to require us to restrict use of your personal data in certain circumstances
Data portability - The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format
To object to use - The right to object to your personal data being used for direct marketing
Not to be subject to decisions without human involvement - The right not to be subject to a decision based solely on automated processing
The right to withdraw consents - If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

11. Changes to our privacy policy

Any changes we may make to our privacy policy will be posted on this page and, where appropriate, notified to users of the platform by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

This Data Privacy Policy was last updated on 2025-02-23.

12. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@clvrbenefits.com.

13. How to complain

Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.

If you feel that we have not addressed your questions or concerns adequately, you may make a complaint with the Integritetsskyddsmyndigheten.