1. Introduction

Nordic Growth Market NGM AB (“NGM”, ”we”, ”our” or ”us”) is the controller for the
processing of your personal data in our business operations.

This privacy policy accounts for the personal data processing that NGM
undertakes when carrying out our services as well as the personal data
processing that takes place when visiting NGM´s website and using the
services on the website.

This privacy policy describes how and why NGM processes your personal data,
your rights and which cookies that are used and why.

Please note that NGM, in addition to what is set out in this information
text, in different circumstances may publish additional information on
certain processing of your personal data. NGM may also be requesting your
consent for certain processing.

2. Who is responsible for your personal data?

NGM is the controller for the processing of your personal data on this
website and in our business operations. Information on how to contact us is
available under the heading “Contact us” at the top of this website. You
will also find certain additional contact details at the bottom of this

3. How is personal data collected?

In order to enable and facilitate communication with our customers,
suppliers and other parties, NGM uses e-mail. You are advised not to send
us personal data of sensitive or integrity sensitive nature through e-mail.
Personal data that is sent by e-mail may be transferred to other registers
and systems within NGM.

Personal data is also collected in connection with subscribing for press
releases, newsletters, information letters and in connection with
registering for an investor competition. In order to receive such notices
or to participate in such competitions you are required to submit the
requested information. You are entitled to unsubscribe from a subscription
at any time by taking the steps set out in the notice or by contacting us.

We also collect your personal data in connection with your use of this
website, such as information on your IP-address and user behavior/pattern
(e.g. which sites you visit and how you scroll and navigate on the
website). Such information is collected through cookies or similar
technology. To find out more about cookies and which information we collect
through cookies, please see section 8 below.

Your personal data is also being processed when you (i) apply for a job and
(ii) submit an indication of interest for a job opportunity. Your personal
data will be processed for the specific purpose for which you submitted
them and will be maintained for a period of two years following (i) a
completed recruitment process or (ii) the time which you submitted them.
This applies irrespective of whether you sent the personal data directly to
us or if we received the personal data from an external party. If you want
us to maintain your personal data for a longer period than what is set out
above, please indicate so when submitting your application or indication of

Data can also be collected through NGM’s partners, including LinkedIn, Twitter and
Facebook, which may mean that the partner in turn submits the data to NGM.

We encourage you not to provide us with sensitive personal data regarding
ethnic origin, political opinions, religion or philosophical beliefs, trade
union membership, data concerning health or data concerning sexual
orientation. We reserve the right to, without your consent, erase sensitive
personal data as well as personal data pertaining to persons other than

4. Why do we process your personal data and on what legal basis?

We process your personal data for the purposes and on the legal basis set
out below. The compilation below may be updated, e.g. in connection with
NGM undertaking additional processing. Should there be material or
substantial changes, we will inform you in an appropriate manner.



Communication through e-mail

Weighing of interests, where our legitimate interest is to
enable and facilitate communication with customers,
suppliers and other parties.

Managing (i) applications for vacant jobs or assignments
and (ii) indications of interest for job opportunities

Weighing of interests, where our legitimate interest is to
be enable and facilitate communication with persons
applying for jobs at NGM.

Managing subscriptions of press releases, newsletters and
information letters.

Weighing of interests, where our legitimate interest is to
be able to distribute the press release, newsletter or
information letter to you.

Reactivating your subscription of press releases,
newsletters and information letters (if you have

Weighing of interests, where our legitimate interest is to
be able you to reactivate your subscription.

Investor competition

Weighing of interests, where our legitimate interest is to
be able to arrange and provide the investor competition.

Marketing (see additional information in section 5 below).

Weighing of interests, where our legitimate interest is to
be able to market our products and services.

User behavior and pattern.

Weighing of interests, where our legitimate interest is to
be able to improve our website, our products and services.

Producing statistics and analyses.

Weighing of interests, where our legitimate interest is to
be able to improve our website, our products and services.

Presentation of management of listed companies, managers’ transactions, and presentation of major owners of the companies.

Weighing of interests, where our legitimate interest is to disseminate relevant and already public information to the capital markets.

5. Marketing

If you have consented, NGM or our partners may distribute marketing through
e-mail related to NGM’s services and/or the products and services of NGM’s
members and issuers and marketing of investor competitions. You are
entitled to withdraw our consent at any time by following the steps in the
notice which you receive from us, or by contacting us.

Newsletters and other information letters may be distributed through a
domain or trademark belonging to either NGM or to one of NGM’s partners.
The domain or trademark will in such cases be listed as the sender.

If you have consented, NGM may distribute marketing through social media
related to NGM’s services and/or the products and services of NGM’s members
and issuers, and investor competitions.

6. Transfer of personal data

For the purposes set out above NGM may in certain cases transfer your
personal data to other companies which NGM cooperates with, e.g. NGM’s
members, issuers and partners, or to companies within the same company
group as NGM. Such transfer of personal data may e.g. take place when
managing subscriptions of press releases, newsletters and information
letters Your personal data may also be transferred to other companies, such
as arrangers, hosts or managers in connection with an investor competition.
We will take appropriate measures to protect your personal data in
connection with such transfer, e.g. by entering into a data processor
agreement or by other arrangements.

Some of NGM’s subcontractors is based in countries outside of the
EU/EEA-area. Transfer of personal data to may therefore take place to
countries outside of the EU/EEA-area.

The subcontractors used by NGM is affiliated with, and connected to, the
“EU-U.S. Privacy Shield Framework”. The subcontractors therefore comply
with the requirements regarding an adequate level of protection for
personal data and the transfers made to the subcontractors is therefore
subject to appropriate safeguards.

If you require further information on the framework, please refer to the
Privacy Shield website:

7. How long is your personal data stored?

Information which you submit upon subscribing for our newsletters, press
releases and information letters is stored for as long as you subscribe for
such notices and for an additional period of 12 months.

Information which you submit upon registering for or when participating in
an investor competition is stored until you have deregistered or up to a
period of 12 months following the end of the competition. Information on
the names and ranks of the top 10 participants is however stored for three
years following the end of the competition. Please note that
unsubscriptions from newsletters or information letters relating to an
investor competition, where the unsubscription is made during the course of
the competition, will be enforced immediately after the competition is

Regarding information which is gathered through cookies, the storage time
for the collected data is set out in section 8 below.

Other personal data is not stored longer than necessary with regards to the
purpose of the processing.

8. About cookies

The cookies we use and why, and what you can do to avoid them, is described
below. The term “cookies” is used as a collective term for web beacons,
pixel tags and other identifiers and/or tracking techniques.

NGM uses Google Analytics for the purpose described below. Information that
is collected through Google Analytics, including information on your
IP-address, is however also processed by Google. NGM is only responsible
for NGM’s processing and is consequently not responsible for Google’s
processing. You can obtain information on how Google uses cookies and
processes collected data, and how you can control the information which is
transferred to Google here:

What are cookies?

Cookies are small text files which are stored on your unit, such as
computer or mobile phone, when you visit NGM’s website and which make it
possible for NGM to recognize your browser, e.g. browser type and screen
resolution, and your activity on NGM’s website, for example the time of
visit and which information you have seen and clicked on and which website
you have visited before visiting our website.

In order to use the website and all of its functions without interruptions
you are required to approve of certain cookies. Consequently, when you
visit our website, you are asked to approve of the use of cookies. You can
always limit our use of cookies and/or delete cookies. This may however
affect the website and its functionality. Please see below for more
information on how to limit and delete cookies.

Which cookies do we use and why?

NGM uses cookies for a number of different purposes, including to obtain
information on how the website is used, to improve the user experience on
the website and for internal statistical purposes, e.g. in order to
calculate the number of unique visitors. By utilizing cookies, NGM can also
recognize your unit when you visit the website again, store information on
your activity and preferences on the website and display ads which are as
customized as possible to your interests.

The type of cookies we use and why are categorized in the following way:

Essential cookies

Certain cookies are essential in order for you to use our website and all
of its functions, for example in order to identify a request from the same
browser during a limited session time.

Function cookies

Function cookies contain a unique ID and enable the website to store user
settings, such as information on preferences, in order to offer you
individualized and customized services and content.

Performance cookies

These cookies are used to analyze the performance of the website and to
identify and correct any problems as soon as NGM identifies them.

Marketing cookies

We use marketing cookies to store information on the users activity on our
website, including which pages the user has visited and which links the
user has clicked on, but also how the user browses between different
websites. NGM uses this information in order to offer directed and
customized marketing which we think is relevant and interesting for you. By
utilizing marketing cookies, NGM can also display ads when a user visits
other websites. Finally, these cookies are used so that the same ads are
not displayed to you an excessive number of times and in order to measure
the effectiveness of our marketing campaigns.

Third party cookies

We use cookies from third parties on the website, who can collect
information on visitors on the website. NGM is only responsible for
information NGM receives from the relevant third party. If and to the
extent third party cookies collect information for other purposes, the
processing is the responsibility of such third party (for more information,
please refer to the third party privacy policy linked above, and cookie

We use Google Analytics e.g. and Hotjar in order to obtain a view on how our visitors
browse the website, which parts of the website are most frequently visited,
how long our visitors stay on different sites, and how long a visit lasts,
etc. We can thereby receive statistics and an overview on the use of our
website. Such information helps us to develop and improve our website,
expand the functionality on the website and offer a better user experience
for our visitors. We also use the information for web analyses and
marketing statistics.

We have also installed Facebook Pixel on our website which helps us to
measure, optimize and create a public for our marketing campaigns. Facebook
Pixel makes it possible for us to offer customized and directed marketing
to different target groups.

We also use Twitter Pixel to track visits and the conversion rate of our
ads and to receive information on, and better
understand, visitors visiting through ads on Twitter and thereby improve
our marketing.

Lastly we use the Facebook Like button to integrate our website with our
page on – a common feature of websites these days. In doing so
this causes some cookies to be created by Facebook that detect the number
of “likes” and whether you are logged into Facebook or not. You should
refer to Facebook’s cookie policy here. At
the last count Facebook use 12 cookies which all expire at the end of the
browser session with the exception of datr (2 years), fr (2 months) and lu
(2 years).

Compilation of cookies and storage times

We use session cookies, which are temporary and are removed when you close
your browser, as well as permanent cookies, which are stored on your unit
for a longer period of time, or until you decide to delete them. How long
the different cookies are stored on your computer is set out in the table

NGM’s website





Third party cookie (Google Analytics)

2 years


Third party cookie (Google Analytics)

24 hours


Third party cookie (Google Analytics)

1 minute


Function cookie

1 year


Third party cookie (Google Analytics)

2 years


Third party cookie (Google Analytics)

10 minutes


Third party cookie (Google Analytics)

30 minutes


Third party cookie (Google Analytics)

End of browser session


Third party cookie (Google Analytics)

6 months


Third party cookie (Google Analytics)

2 years

The investor competition websites





Function cookie

24 hours


Third party cookie (Google Analytics)

2 years


Third party cookie (Google Analytics)

24 hours


Third party cookie (Google Analytics)

1 minute


Function cookie

1 month


Essential cookie

Relevant browser session

act, c_user, csm, datr, fr, lu, p, presence, s, sub,
x-src, xs

Third party cookie (Facebook)

See description of Facebook cookies above

How can you limit or delete cookies?

You can delete all cookies from your unit and configure your browser/change
the configuration to automatically reject cookies or to be informed if a
website uses cookies. For more information on how to reject and delete
cookies, please visit:

In order to gain full access to NGM’s products and services through the
web, you are required to accept cookies. If you chose to delete or limit
the use of cookies, certain functions on our website will not work, and you
will not be able to utilize the entire website. You will in addition need
to set your preferences, such as language, each time you visit our website.

9. What are your rights as registered?

You have the following rights under applicable data protection regulation;

· You are entitled to receive information on whether NGM processes your
personal data and if so obtain access to such personal
data (so-called filing-system extract) with additional information on the

· If you believe that your personal data is inaccurate or incomplete, you
are entitled to request for it to be rectified.

· In certain cases, you may request for your personal data to be erased or limited.

· When processing is carried out based on a weighing of interests, you are
entitled to object to the processing. Of the objection is
made against processing for direct marketing, the personal data shall no
longer be processed for this purpose.

· If you have consented to certain processing, you are entitled to withdraw your consent at any time.

· Upon request and subject to certain conditions, you are entitled to
receive some of your personal data for the purpose of having it transferred
to another controller of personal data, i.e. data portability.

· If you believe that NGM has processed your personal data incorrectly or
in violation of applicable data protection regulation, you are entitled to file a complaint to the Swedish Data Protection Authority,
please see

10. Amendments to the privacy policy

NGM reserves the right to revise this privacy policy from time to time.
Amendments may be required due to changes in applicable law. The date of
the last revision is stated in section 12 below. You are encouraged to read
this policy regularly in order to take notice of any amendments.

11. Contact details to the controller

Nordic Growth Market NGM AB, company registration no. 556556-2138

Mäster Samuelsgatan 42

111 57 Stockholm

Telephone: +46 (0) 8 566 390 00


You can always choose to contact our Data Protection Officer:

12. Entry into force

This privacy policy entered into force on May 25, 2018. The last revision
was made on September 06, 2019.