Privacy Policy -
Invoice Recipients
Respect for the privacy of the individual is important to us at Billogram (”Billogram”, ”we”, ”us”, ”our”) and we work proactively to protect the personal data that we process. All personal data is processed in accordance with applicable law. This policy contains information about how we as data controller process personal data if you are a customer of a company that uses our billing and payment service (hereafter “invoice issuer”) and where you, as a result, will receive invoices via our service.
In this Policy, we describe how and for what purposes we use your personal data, the lawful basis for the processing and what measures we take to protect personal data. We also describe how you can invoke your rights in regard to our processing of your personal data.
Definitions
”Applicable Law” means the legislation that we have to comply with governing processing of personal data. This includes the General Data Protection Regulation (GDPR) (EU 2016/679), but also complementary national legislation as well as practices, guidelines and recommendations issued by national regulatory or EU supervisory bodies.
”Controller” is the company or organisation that decides for what purpose and in what way personal data is to be processed and which is responsible for the processing of personal data in accordance with applicable law.
”Data Subject” is an identified or identifiable natural person whose personal data is processed.
”Personal data” is any information that relates, directly or indirectly, to an identifiable natural person.
”Processing” is an action or combination of actions relating to personal data, such as storage, alteration, reading, transmission, etc.
”Processor” is the company or organisation that processes personal data on behalf of the controller in accordance with the controller’s instructions and applicable law.
The definitions of the concepts above shall apply regardless of whether capitalised or not.
Billogram’s role as controller
Billogram is in some cases the controller and in other cases the processor for the processing of your personal data. This Privacy Policy describes processing where we are the controller, i.e. where we are the party that decides the purposes (the “why”) and the means (the methods, which personal data to be processed and how long it should be stored).
When an invoice issuer uses our service to provide you with an invoice and distribute your payment, we process your personal data for the most part as data processor for the company where you are a customer. In the role of processor, we process your personal data only in accordance with the controller’s instructions. If you have questions about how your personal data is processed or would like to invoke your rights in respect of billing and payment that are outside the scope of this Privacy Policy, you should contact the invoice issuer where you are a customer.
General information about our personal data processing
We have an obligation to describe how we meet the requirements imposed on us when we process your personal data. This section aims to describe general principles governing our personal data processing.
Lawful basis
In order to process personal data, the controller must have a lawful basis in applicable law for the processing. The lawful basis for our processing of personal data regarding invoice recipients is one of the following:
Legitimate interest - we have undertaken a legitimate interest assessment and determined that our interests in processing your personal data outweigh your right not to be covered by the processing.
Contract - The processing is necessary for us to be able to perform a contract we have with you or to enter into such a contract (the Swedish market only).
Consent - You have given your explicit consent that we may process your personal data. You may withdraw your consent at any time, and we will cease processing your personal data for the purpose for which you have given your consent (the Swedish market only).
How long do we store your personal data?
We only save your personal data for as long as necessary for the purpose for which it was collected. Depending on the lawful basis, the storage period may be governed by a contract, be dependent on valid consent, or an internal legitimate interest assessment. In the section “How your personal data is processed” below, we specify the criteria for when the purpose ceases and thus the time when we no longer process your data.
When we share your personal data with others
We may share your personal data with others in order for us to perform any of the processing described in this policy, for example for the storage of data. We always enter into Data processing agreements with the data processors we use, in which we, among other things, give the processor instructions on how the personal data may be processed and what security measures are required for the processing. The processor may not carry out any processing of your personal data that goes beyond these instructions.
In some cases, we need to share your personal data with another party who will decide the purpose and means of the processing and as such act as controller (the Swedish market only).
If required by law, decree, regulation, government decision or other ruling binding on Billogram, we may disclose your personal data to various authorities, such as the Swedish Tax Agency or the Swedish Police Authority.
Transfer of personal data outside the EU/EEA
Where personal data is transferred to countries outside the EU/EEA, we implement safety measures to ensure that the level of security is adequate and in accordance with applicable law. Such safety measures include, inter alia, ensuring the following:
The European Commission has decided that the third country to which your personal data is transferred achieves an adequate level of protection, or
The European Commission’s standard contractual clauses have been signed between Billogram or its processors, as applicable, and the recipient outside the EU/EEA. In these cases, we also assess whether there is legislation in the recipient country that affects the protection of your personal data. Where necessary, we take special measures to ensure that the protection of your data remains in place when transferring it to the relevant country outside the EU/EEA.
How your personal data is processed
The table below sets out the personal data we process and the purpose thereof, where the data was collected, the lawful basis for our processing, when the purpose of the processing will cease and, if possible and relevant, the basis for the assessment of the storage period (in brackets).
| Purpose | Categories of personal data we process | Source | Lawful basis | When the purpose ceases |
|---|---|---|---|---|
| Ensure functionality and prevent misuse of our billing service | Device, operating system and browser detailsIP address | From your device | Legitimate interestOur legitimate interest is that we need to ensure the functionality and prevent misuse of our service to fulfil the requirements towards our customers and you as invoice recipient. | When you no longer receive invoices via our service |
| Information regarding navigation within the service (including when the invoice was opened) | Billogram | |||
| Analyze and correct errors within our billing service* | NameAddressCustomer numberName of the invoice issuerInvoice numberInvoice amountDate of issue, when the invoice was distributed and due date | From the invoice issuer | Legitimate interestOur legitimate interest is that we need to correct errors in our service to fulfil the requirements towards our customers and you as an invoice recipient. | 3 months after the error is handled (the time we deem necessary to follow up on managed errors) |
| Personal identity numberE-mail addressTelephone numberInvoice distribution methodCommunication through the invoice (communication module) | From the invoice issuer or from you | |||
| Billogram unique IDRecipient IDInformation regarding navigation within the service | Billogram | |||
| Device, operating system and browser details | From you | |||
| Opt-in/opt-out for marketing offers from the creditor (module sales and offerings) | Billogram or from you | |||
| Payment reference number | Invoice issuer or generated by Billogram | |||
| Information on chosen bank (for markets with direct debit as payment method) | From Tink or from the invoice issuer | |||
| Information on chosen bank (for e-invoice) | From the invoice issuer’s bank | |||
| Date of consent and signing method (Sweden) | From BankID or similar identification method | |||
| Payment status (current receivables or liabilities)Payment date and method | Depending on payment method: Billogram/invocie issuer/Arvato (if debt collection) | |||
| Improve, develop and measure the use of our billing service | E-mail address**Invoice distribution methodCommunication information regarding invoices and payments | From the invoice issuer or from you | Legitimate interestOur legitimate interest is to improve and develop our service to fulfil the requirements and requests our customers and you as an invoice recipient have on the service | 5 years after you received your last invoice via our service (the time we deem necessary to analyze trends and seasonal variations) |
| Customer number**Name of the invoice issuerInvoice amountDate of issue, when the invoice was distributed and due date | From the invoice issuer | |||
| Payment reference number** | From the invoice issuer or generated by Billogram | |||
| Billogram unique ID**Recipient ID**Information regarding navigation within the service (including when the invoice was opened) | Billogram | |||
| Payment date and payment method | Depending on payment method: Billogram/invoice issuer (creditor)/Arvato (if debt collection) | |||
| Device, operating system and browser details | From you |
*Which of the specified categories of personal data that will be processed for this purpose is depending on the nature of the troubleshooting. Only personal data necessary for the specific troubleshooting is processed.
**The personal data is pseudonymised, which means that all identifying personal data is replaced with non-identifying information. Statistics are compiled at an aggregated level.
Personal data processing for Autogiro (the Swedish market only)
If you have activated Swedish Autogiro mandate and the invoice issuer subscribes to our standardised billing service where payments are made to a corporate Bankgiro number (639-8770), we process your personal data as controller in accordance with the specification below. In all other cases, we are processor for personal data processing connected to your Autogiro consent.
| Purpose | Categories of personal data we process | Source | Lawful basis | When the purpose ceases |
|---|---|---|---|---|
| Administrate Autogiro mandates | Personal identity numberDate of consent and signing method | From BankID or similar digital identification method | ContractConsent (to share your data with third party to administrate the Autogiro service) | 3 years after you have withdrawn your Autogiro mandate in accordance with statutory limitation provisions.Your consent for us to share personal data with third party ceases when you withdraw your Autogiro mandate. |
| Name | From the invoice issuer | |||
| Bank and account numberAccount holder | From Tink |
Recipients we share your personal data with
Sometimes we need to share your personal data with others to fulfil the purposes described above.
Processors
The personal data we process is stored by Amazon Web Services (AWS) where the processing only occurs within EU/EEA.
To analyze errors in Billogram’s billing service we may share personal data with Sentry and if so, the processing will take place in the USA. The personal data Sentry may process is restricted to Billogram-unique ID, recipient ID and the name of the invoice issuer. By entering standard contractual clauses (please see “Transfer of personal data outside the EU/EEA” above), we have ensured that the protection of the personal data Sentry processes is equivalent to GDPR requirements.
Other recipients (the Swedish market only)
For the processing described in section ”Personal data processing for Autogiro”, we need to share information with your bank through Bankgirot. Your bank is controller for the processing and Bankgirot is processor.
Your rights
According to applicable law, you as a data subject have several rights that you should be aware of.
– You have the right to request a record extract of the information recorded about you.
– If the data we hold on you is incorrect, you have the right to have it corrected.
– You have the right to have your personal data deleted.
– If you believe that the data is incorrect or that our processing is unlawful or that we do not need the data for a specific purpose, you may request that we restrict the processing of data about you. You can also request restriction of processing while awaiting verification from us as to whether our interest in processing your data outweighs your right not to have this data processed.
– If we cite legitimate interest as a lawful basis, you have the right to object to the processing.
– The right to data portability means that in some cases, where the lawful basis is a contract or consent, you have the right to receive your personal data and use your personal data elsewhere.
Contact details and Data Protection Officer
Billogram AB is registered with the Swedish Companies Registration Office under corporate registration number 556801-7155 and is headquartered at Klara Södra Kyrkogata 1, SE-111 52 Stockholm, Sweden.
If you have questions about how we process your personal data or wish to invoke any of your rights, you can always contact us at support@billogram.com.
You can also contact our Data Protection Officer by email: dpo@billogram.com or by post at the above address.
Complaints
If you believe that the processing of your personal data is in violation of applicable law, you should contact us. You can also contact the Swedish Authority for Privacy Protection directly with your complaint.
Privacy Policy updates
This Privacy Policy may be updated due to changes in legislation or changes in our personal data processing as a result of the development of our services.
The latest version is always published on our website.
This version was updated on 2022-09-28