Privacy Policy

Information on the Processing of Personal Data and Cookies

1. Introduction
Nordic Growth Market NGM Aktiebolag (“NGM”, “we”, “our” or “us”) is the controller for the processing of personal data carried out within our operations.

NGM conducts stock exchange operations and provides trading in financial instruments. NGM is under the supervision of the Swedish Financial Supervisory Authority (Sw. Finansinspektionen) and its operations are primarily governed by the Swedish Securities Market Act (2007:528) (Sw. lagen om värdepappersmarknaden). NGM’s processing of personal data is under the supervision of the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) and is carried out in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

This privacy policy describes both the processing of personal data carried out by NGM in connection with the performance of our services and the processing that is conducted when you visit NGM’s website and use its services.

This privacy policy describes how and why NGM processes your personal data, your rights as a data subject, and which cookies are used and for what purposes.

Please note that, in addition to the information set out in this policy, NGM may in different contexts provide supplementary information regarding certain specific processing of your personal data. NGM may also request your consent for specific processing activities.

2. Who is responsible for your personal data?

NGM is the controller for the processing of personal data on this website and within our operations. Information on how to contact us is available under the heading “Contact us” at the top of the website. Certain contact details are also provided at the bottom of this page.

3. How is your personal data collected?

To enable and facilitate communication with customers, suppliers, issuers, financial market participants, and other stakeholders, NGM processes personal data. Personal data may be collected via, for example, email, telephone calls, postal correspondence, or through the use of NGM’s services.

You should not send special categories of personal data or other sensitive information to us via email. Personal data contained in emails may be transferred to other systems and registers within NGM.

Personal data is also collected when you register your interest in subscriptions of press releases, newsletters, or other information, or when you register for an investor competition. In order to receive such communications or participate in such competitions, you must provide the requested information. You may at any time cancel a subscription by following the instructions in the communication or by contacting us.

We also collect personal data when you use our website, such as information about your IP address and user behaviour (e.g. which pages you visit and how you scroll and navigate the website). Such data is collected using cookies or similar technologies. For more information about cookies and the data collected through cookies, see Section 8 below.

We also process your personal data when you (i) apply for job vacancies or assignments, and (ii) submit an expression of interest in employment or assignments. Your personal data is processed for the specific purposes for which it was provided and is retained for two years following (i) the conclusion of a recruitment process, or (ii) the date on which the data was submitted. This applies regardless of whether you submit your data directly to us or whether NGM receives it via a third party. If you wish for NGM to retain your personal data for a longer period than provided above, please indicate this in connection with your application and/or expression of interest.

Personal data may also be collected via NGM’s partners, including LinkedIn, Twitter, and Facebook, which may involve such partners transferring the data to NGM.

We advise you not to provide special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, or data concerning gender identity. We reserve the right, without your consent, to delete such data, as well as personal data relating to individuals other than yourself.

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

We process your personal data for the purposes set out below and based on the legal basis specified. This overview may be updated, for example, in connection with the introduction of new processing activities. In the event of material changes, we will inform you in an appropriate manner.

Purpose	Legal basis
Communication via email	Legitimate interests, where our interest is to enable and facilitate communication with customers, suppliers, and other stakeholders.
Managing (i) applications for job vacancies or assignments, and (ii) expressions of interest	Legitimate interests, where our interest is to manage and facilitate communication with persons seeking employment with NGM.
Administration of subscriptions to press releases, newsletters, and informational mailings	Legitimate interests, where our interest is to provide you with such communications.
Reactivation of subscriptions (where you have previously unsubscribed)	Legitimate interests, where our interest is to offer you the opportunity to resume receiving communications.
Investor competitions	Legitimate interests, where our interest is to organise and administer such competitions.
Marketing (see supplementary information in Section 5 below)	Legitimate interests, where our interest is to promote our services and offerings.
Analysis of user behaviour and patterns	Legitimate interests, where our interest is to improve our website, products, and services.
Production of statistics and analyses	Legitimate interests, where our interest is to improve our website, products, and services.
Publication of information on executives of listed companies, transactions by persons discharging managerial responsibilities (PDMRs), and major shareholders	Legitimate interests, where our interest is to disseminate relevant and already public information to the market.
Publication of mentors’ contact details on NGM’s website	Legitimate interests, where our interest is to provide relevant market information and enable searchability among approved mentors.

5. Marketing

Where you have provided your consent, NGM or our partners may send you marketing communications via email relating to NGM’s services and/or the products and services of NGM’s members and issuers, as well as investor competitions. You have the right to withdraw your consent at any time by following the instructions in the communications or by contacting us.

Newsletters and other informational mailings may be distributed via a domain or brand belonging to NGM or one of NGM’s partners. In such cases, the relevant domain or brand will be indicated as the sender.

Where you have provided your consent, NGM may also use social media to market NGM’s services and/or the products and services of NGM’s members and issuers, as well as investor competitions.

6. Transfer of personal data

For the purposes described above, NGM may transfer your personal data to other entities with which NGM cooperates, such as NGM’s members, issuers, partners, and other companies within the NGM group. Such transfers may occur, for example, in connection with the administration of press releases, newsletters, and informational mailings. Personal data may also be transferred to third parties such as organisers, venue providers, and administrators in connection with, for example, investor competitions. NGM will implement appropriate safeguards to protect your personal data in connection with such transfers, for example, by entering into data processing agreements or other appropriate arrangements.

Some of NGM’s service providers are situated outside the EU/EEA. Personal data may therefore be transferred to countries outside the EU/EEA. Where applicable, NGM assesses whether such recipients meet the requirements of an adequate level of protection and whether the transfers to such service providers are subject to appropriate safeguards.

7. How long is your personal data retained?

Personal data provided when subscribing to newsletters, press releases, and informational mailings is retained for as long as you remain subscribed and for a subsequent period of twelve (12) months.

Personal data provided when registering for or participating in an investor competition is retained until you unsubscribe or for up to twelve (12) months after the competition has ended. However, the names and results of participants who achieve a top ten placement are retained for three (3) years after the competition has ended. Please note that requests to unsubscribe from communications relating to competitions submitted during the competition period will take effect immediately after the competition has concluded.

Information collected through cookies is retained for the period set out in Section 8 below.

Other personal data is not retained for longer than necessary for the purposes for which it is processed.

8. Cookies

Below, we describe which cookies we use on our website and why, as well as how you, as a visitor, can avoid them. The term “cookies” is used herein as a collective term for web beacons, pixel tags, and other identifiers and/or tracking technologies.

NGM uses Google Analytics for the purposes described above. Data collected via Google Analytics, including information about your IP address, is also processed by Google. NGM is only responsible for the processing it carries out and is therefore not the data controller for processing carried out by Google.You can read more about how Google uses cookies, how it processes data, and how you can control the information sent to Google here: https://policies.google.com/privacy/partners?hl=sv

Further information about cookies is available here.

9. Your rights as a data subject

Under applicable data protection legislation, you have the following rights:

- The right to obtain confirmation as to whether your personal data is being processed by NGM and, where that is the case, access to the personal data and information about the processing (a so-called subject access request).

- The right to request rectification of inaccurate or incomplete personal data.

- The right, under certain circumstances, to request erasure or restriction of processing.

- The right to object to processing based on legitimate interests. If you object to processing for the purpose of direct marketing, your personal data will no longer be processed for such purposes.

- The right to withdraw your consent at any time where processing is based on consent.

- The right, under certain conditions, to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller (data portability).

- The right to lodge a complaint with the Swedish Authority for Privacy Protection (IMY), which is the competent supervisory authority: https://www.imy.se/

10. Changes to this privacy policy

NGM reserves the right to amend this privacy policy from time to time. Changes may be required due to developments in applicable law. The date of the most recent revision is indicated in Section 12 below. We recommend that you review this policy regularly.

11. Contact details of the data controller

Nordic Growth Market NGM AB, reg. no 556556-2138
Stureplan 2
SE-114 35 Stockholm, Sweden
Telephone: +46 8 566 390 00
Email: info@ngm.se

You may also contact our Data Protection Officer at: dpo@ngm.se

12. Entry into force

This privacy policy entered into force on 25 May 2018. The most recent revision was made on [X].