Information on processing of personal data and cookies
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 page.
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 interest.
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 yourself.
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.
| Purpose | Legal basis |
|---|---|
| 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 unsubscribed). |
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. |
| Publication of mentor persons’ contact information on NGM's website, in order to enable searchability among approved mentors and to show which mentors NGM has a business relationship with. | Weighing of interests, where our legitimate interest is to provide relevant information to the market. |
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 may therefore take place to countries outside of the EU/EEA-area. Where applicable, NGM investigates whether or not subcontractors comply with the requirements regarding an adequate level of protection for personal data and if the transfers made to the subcontractors is subject to appropriate safeguards.
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 finished.
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: https://policies.google.com/privacy/partners?hl=en.
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 policy).
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.
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 below.
NGM's website (www.ngm.se)
| Cookie | Provider | Description | Expiry |
| hubspotutk | HubSpot | This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor. | 13 months |
| __hs_opt_out | HubSpot | This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies. |
13 months |
| _ga | Google Analytics | This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. | 24 months |
| _gid | Google Analytics | Google Analytics. It stores and updates a unique value for each page visited. | 24 hours |
| __hssrc | HubSpot | This cookie is set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session. | Session |
| __hstc | HubSpot | For tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). | 13 months |
| __hssc | HubSpot | This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. |
30 minutes |
| __cfduid | Cloudflare | This cookie is set by HubSpot’s CDN provider, Cloudflare. It helps Cloudflare detect malicious visitors to your website and minimizes blocking legitimate users. | 12 months |
| __cfruid | Cloudflare | Cookie associated with sites using CloudFlare, used to identify trusted web traffic. | 30 days |
| __ptq.gif | HubSpot | Sends data to Hubspot about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels. |
Session |
The investor competition websites
| Cookie | Type av cookie | Storage time |
|---|---|---|
_icl_current_language |
Function cookie | 24 hours |
_ga |
Third party cookie (Google Analytics) | 2 years |
_gid |
Third party cookie (Google Analytics) | 24 hours |
_gat |
Third party cookie (Google Analytics) | 1 minute |
ngm_cookie_consent |
Function cookie | 1 month |
PHPSESSID |
Essential cookies | 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: https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options.
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 processing.
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 Authority for Privacy Protection, please see https://www.imy.se/other-lang/.
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
Regeringsgatan 52
111 57 Stockholm
Phone: +46 (0) 8 566 390 00
Email: info@ngm.se
You can always choose to contact our Data Protection Officer: dpo@ngm.se
12. Entry into force
This privacy policy entered into force on May 25, 2018. The last revision was made on June 8, 2021.