We at Lowwi AB want you to feel secure when you provide your personal data to us. This privacy policy explains how we collect, use, disclose and store your personal data and how we otherwise ensure that your personal data is processed in accordance with applicable legislation. It is important to us that you read and understand this privacy policy and feel confident about how we process your personal data.
Lowwi AB, reg. no. 556881-9238 and mailing address Morabergsvägen 8, 152 42 Södertälje, Sweden (in this policy called ”Lowwi”) is the data controller for the processing of your personal data when Lowwi provides and markets products and services and in other contact with Lowwi, such as visits to our web shop or service matters via e-mail and telephone. As the data controller, it is Lowwi’s responsibility to ensure that your data is handled correctly and securely in accordance with applicable legislation.
Lowwi collects and processes the following categories of personal data about you as a customer or potential customer in connection with your purchases and use of our services as well as our marketing and sales of our products and services.
4.1 Lowwi collects your personal data directly from you when you place an order, visit Lowwi’s website, click on links in digital marketing communications we have sent you, contact our customer service and when you otherwise have contact with Lowwi and provide information about yourself. Information about you is collected on these occasions so that you can enter into agreements with Lowwi and so that Lowwi can provide its products and services to you.
4.2 If you hold an account, Lowwi also collects personal data about you when registering the account and while you are the account holder, for example your purchase history, your behaviour on Lowwi’s website, your customer settings for receiving marketing communications and which offers you have been interested in by visiting our web shop and reading or clicking on links in our digital mailings.
4.3 In addition to the data Lowwi collects from you, we may also collect personal data from someone else, i.e. from a third party. We retrieve information from public registers via third-party services for address updates, for example Ratsit, to verify that we have the correct contact details for you. We retrieve creditworthiness information from credit rating agencies, information companies or banks, for example UC.
4.4 Lowwi also collects certain personal data via cookies that log how you use our website and thus which content you prefer.
Lowwi collects and handles information about you for different purposes. These purposes define the outer limits for what we may use your personal data for. Below we explain the purposes of our processing and give examples of processing activities that occur under each purpose. Note that some of your personal data may be processed for several purposes.
5.1 Manage orders and purchases
Processing of personal data for this purpose includes activities to, among other things, identify you and send order confirmations, deliver orders, notify about delivery and handle complaints and warranty matters regarding purchased products.
The collection of data we make to be able to manage your orders and purchases is required for us to fulfil our obligations under our terms and conditions of purchase. If the information is not provided by you, our obligations cannot be fulfilled and we may in that case refuse your order or purchase.
5.2 Provide and manage account
We process personal data for this purpose to, for example, grant you the authorization to log in to the account, verify your identity, create your personal pages, maintain correct contact information, manage your settings for marketing communications and personalised offers, facilitate shopping in our web shop through pre-filled information and saved digital shopping carts, make it easier for you to manage cases and complaints and enable you to follow your order and payment history.
5.3 Provide personalised information, benefits and offers and give a personalised web shop experience to account holders
We at Lowwi want you to have the best possible experience when you visit our website and when we communicate with you. Therefore, we process personal data for this purpose so we can improve your user experience in order to create, offer and provide you with personalised content in communication and marketing via post, e-mail, sms/mms and telephone with individual benefits and offers, recommendations and other information we believe is relevant to you, as well as remind you of abandoned digital shopping carts. To enable this, analyses are performed on the data that Lowwi collects such as place of residence, order history and user-generated data.
The collection of data we make for this purpose is required for us to be able to fulfil our commitments under these terms. If the data is not provided, our commitments cannot be fulfilled and we will then need to limit certain benefits and other advantages linked to your account.
5.4 Provide information about and market products and services
We process personal data for this purpose to inform you about and market the products and offers Lowwi sells by post, e-mail, sms/mms and telephone, show recommendations, remind about abandoned digital shopping carts and invite to competitions and market and customer satisfaction surveys.
5.5 Conduct and manage participation in competitions and other marketing measures
Processing of personal data for this purpose includes measures to, for example, identify participants, communicate with participants in a competition and appoint winners and convey prizes, verify participants’ ages and communicate with participants before and after an event (such as confirmations of registrations, reminders and evaluations). Note that information that you participated in events is covered by the category user-generated data which is processed for other purposes.
5.6 Handle matters received by Lowwi’s support functions
Processing of personal data for this purpose includes Lowwi’s activities to, for example, communicate, verify the customer’s identity, investigate complaints and support matters, answer questions received by customer service or other support functions via e-mail, telephone or digital channels, correct incorrect information, provide technical support and maintain customer relationships.
5.7 Fulfil legal obligations required of Lowwi
Personal data is processed for this purpose so that Lowwi can comply with requirements in laws, judgments or authority decisions. Examples of such requirements are product liability and product safety such as preparing communication and information about product recalls and product warnings (for example in the event of a defective or hazardous product) and obligations to retain certain information according to the Accounting Act that can be linked to an individual. If the data Lowwi collects within the framework of this purpose is not provided, our legal obligations cannot be fulfilled and we may in such case refuse your order, purchase or the activity that gives rise to our legal obligations.
5.8 Prevent misuse and prevent, deter and investigate crimes within the framework of our operations
Processing of personal data for this purpose is carried out, among other things, to prevent misuse of accounts and to prevent, deter and investigate suspected theft and fraud. When you want to pay for goods by invoice, we therefore perform a fraud check where we analyse which products you want to buy, delivery address, the value of the products, and more. We flag behavioural patterns that often occur in connection with fraud and then perform a manual assessment to examine the risk that it may be an attempted fraud. Suspected crimes and attempts at crimes may be reported to the police.
5.9 Evaluate, develop and improve Lowwi’s services, products and systems for our customers in general
Processing of personal data for this purpose includes activities to, among other things, make our web shop and other services more user-friendly, develop or highlight digital features, improve our customer offering (for example development of services and products), produce material to improve goods and logistics flows (for example to enable forecasting of purchases, stock and deliveries), develop and improve the company’s assortment and resource efficiency and improve our IT system to increase security, produce statistics for market and customer analyses as well as business follow-up and business and method development related to orders and purchases, automatically archive behaviours that may later need to be reviewed for security reasons and give customers the opportunity to influence the assortment that Lowwi provides. To fulfil this purpose, Lowwi performs general analyses in aggregated form, i.e. not at an individual level, regarding among other things click and visit behaviours, device information, order history, payment history, geographic location and individual customers’ feedback.
For Lowwi to have the right to collect and process your personal data, there must be a legal basis for each purpose the data is processed for. The legal bases we rely on for our processing are described in this section. Note that several legal bases may be applicable to the same processing.
6.1 Legal obligation
This basis means that our processing is necessary to fulfil a legal obligation required of Lowwi, for example to document payment details to meet the requirements of the Accounting Act.
6.2 Contractual obligations
This basis means that the processing is necessary to perform a contract with you as a customer or to be able to enter into a contract at a later stage. For you who hold an account, you have entered into an agreement with Lowwi that sets the framework for which processing of your personal data may take place to provide, manage and administer our services related to the account, for example analysis of your personal characteristics to give you personalised benefits and offers. When ordering or purchasing, we process your data to fulfil obligations under Lowwi’s terms of purchase. Then, for example, it may be necessary for Lowwi to register your contact details so we can fulfil our obligation to deliver the product.
6.3 Legitimate interest
This basis means that our processing is based on a so-called balancing of interests of legitimate interest. This means that the processing takes place because Lowwi assesses that we have legitimate interests in processing your personal data which outweigh your interest in not having the personal data processed. On this basis we process, among other things, your personal data to prevent misuse of accounts and to prevent, deter and investigate crimes within the framework of our operations. If we determine that a crime or attempted crime has been committed and we make a police report, Lowwi will also continue to process your personal data so that we can establish, defend or assert a legal claim.
7.1 Lowwi will store your personal data as long as it is necessary to fulfil the purposes for which the data are processed. How long the storage period is therefore depends on which purpose the data are processed for. In addition, Lowwi may store the data longer if it is necessary to establish, defend or assert a legal claim, for example if there is an ongoing dispute or if a report of a crime has been filed with the Police Authority. We regularly carry out deletions and remove personal data that is no longer necessary.
7.2 Lowwi stores personal data linked to your account as long as you are active by interacting with Lowwi in various ways. If you have been inactive for a certain period, the account will automatically be closed and the personal data we have collected and processed to provide the account and the services linked to the account will be deleted.
Below we have provided an overview compilation of our processing of personal data to clearly explain which categories of personal data we process for our different purposes, which legal basis underlies our processing and how long we store the data.
Purpose | Legal basis | Categories of personal data | Retention period |
To be able to handle your orders and purchases | Contractual obligations under Lowwi’s general sales terms |
| Five years after your order is paid and delivered or, if the warranty period for the purchased product or service is longer, after that period has expired |
To provide and manage your account | Contractual obligations under the Terms for account |
| As long as you have an account |
To provide personalised information, benefits and offers and give a personalised web shop experience to account holders | Contractual obligations under the Terms for account |
| As long as you have an account |
To provide information about and market products and services | Contractual obligations under the Terms for account for you who are an account holder
Legitimate interest for you who are not an account holder |
| As long as you have an account for you who are an account holder
Three years after you last clicked a link in our communication to you if you are not an account holder |
To carry out and manage participation in events, competitions and other marketing measures | Legitimate interest |
| Three years after the event or competition has ended |
To handle matters received by customer service and other support functions | Legitimate interest |
| Five years after the last contact in the matter or, if the warranty period for the product or service to which the matter relates is longer, after that period has expired |
To fulfil legal obligations such as requirements in the Accounting Act, product liability and protection of your personal data in our systems | Legal obligation |
| As long as we are required to retain the data under applicable law or authority decision |
To prevent misuse and to prevent, deter and investigate crimes within the framework of our operations | Legitimate interest |
| For as long as necessary checks are carried out. If the processing leads to a police report, the data will be stored as long as required to fulfil the report and to establish, defend or assert the legal claim |
To evaluate, develop and improve Lowwi’s services, products and systems for our customers in general | Legitimate interest |
| As long as you have an account for you who are an account holder
Five years after you last interacted with Lowwi if you are not an account holder, for example visited our website, logged into a previous account or clicked on a link in our communication to you |
9.1 Lowwi may disclose your data to other companies so that you can take part in our offers, products and services. The recipients of your personal data may either be processors on behalf of Lowwi, i.e. companies that process your data on our behalf and according to our instructions, or independently data controllers, i.e. companies that are independently responsible for the processing of your data when they have a direct relationship with you as a customer such as Walley/Collector Bank AB.
9.2 Lowwi may also disclose your data to authorities if it is necessary to comply with law, regulation or authority decision or for Lowwi to be able to establish, defend or assert legal claims.
9.3 Depending on which contacts you have had with Lowwi, for example if you are an account holder or receive marketing communications, Lowwi may disclose your personal data to the following recipients:
Other companies within Lowwi that act as processors for Lowwi so that we can fulfil the different purposes set out in this policy. The legal bases for the transfer to our group companies are the same as for our own processing.
Companies that provide information from the population register or other public registers to ensure that we have the correct contact details for you so we can handle your orders and purchases as well as your account and the services linked to your account. The data disclosed are identification numbers and contact details based on our contractual obligations to you as the legal basis.
Analysis and marketing companies that provide services such as automated marketing tools, analytics, communications, print and distribution. These recipients help Lowwi analyse your data as well as inform about and market the products and services Lowwi sells. The data disclosed are contact details, account information, customer settings, order details and user-generated data based on legitimate interest and our contractual obligations to you as an account holder as legal bases.
Government authorities, such as the Police Authority or the Swedish Tax Agency, to whom we are obliged to disclose your personal data by law or authority decision or to whom we disclose personal data due to suspicion of crime or attempted crime. The data disclosed are contact details, identification numbers, account information, order information, payment details and user-generated data based on the legal obligation incumbent on Lowwi or so that we can establish, defend or assert legal claims.
9.4 If you place an order or make purchases from Lowwi, we may also disclose your personal data to the following recipients in connection with handling your orders and purchases based on our contractual obligations to you as the legal basis:
Suppliers, manufacturers, distributors and subcontractors of products and services Lowwi sells who among other things provide the products and services and help us with support services such as maintenance, repair and disposal of returned products. The data disclosed are contact details and order information.
Logistics companies and freight forwarders who help us with goods transports so we can deliver our products and services to you. We disclose contact details and order information to these recipients.
Insurers who provide insurance for some of our products and services. The data disclosed when you have chosen to take out insurance are contact details and order information.
Partners and providers of payment solutions, for example card acquiring companies, banks, credit institutions and other financial actors, who ensure that you can carry out payments and offer you different financing solutions. The data disclosed are contact details and payment details.
9.5 Lowwi will not sell your personal data to third parties.
Lowwi will primarily process your personal data within the EU/EEA. However, we may also transfer your personal data to a country outside the EU/EEA if we need to share your data with Lowwi’s suppliers or partners located outside or that store personal data in a country outside the EU/EEA. If your personal data are transferred to a country outside the EU/EEA, Lowwi will take the measures required to legally transfer the personal data by ensuring that your personal data are handled securely and with an adequate level of protection comparable to the protection offered within the EU/EEA, for example by entering into agreements with the recipient that include the European Commission’s standard contractual clauses or, if the transfer is to the USA, by the recipient having certified to follow the principles in Privacy Shield.
11.1 Lowwi is responsible for ensuring that your personal data are processed in accordance with applicable law. This section describes your rights related to our processing of your personal data. We will at your request or on our own initiative correct, anonymise, delete or supplement data found to be incorrect, incomplete or misleading. If you have questions about this or want to exercise any right, please contact us via the contact details provided at the end of this policy.
11.1.1 Right of access to your personal data
We at Lowwi want to be transparent about how we process your personal data. If you wish to gain insight into the processing we carry out about you, you have the right to request information about the processing, including a copy of your personal data that is being processed, a so-called register extract. This includes information about purposes, categories of personal data, categories of recipients of personal data, storage period or the criteria for how the storage period is determined, information about where data were collected from and the existence of automated decision-making including information about the logic behind and the significance of the processing. Note that when requesting access we may ask for additional information about you to ensure that we disclose the data to the correct person and which data you wish to access. The register extract is free of charge but for repeated requests Lowwi has the right to charge an administrative fee of 100 SEK.
11.1.2 Right to rectification of your personal data
Lowwi strives to have correct and up-to-date personal data. If the data we hold about you are incorrect you have the right to request that they be corrected. You also have the right to supplement any incomplete personal data, for example if we have the correct street name but lack the street number. At your request we will as soon as possible correct the incorrect or incomplete data we process about you.
11.1.3 Right to erasure of your personal data
We respect that the personal data we process about you are entrusted to us. You therefore have the right to request that Lowwi deletes your personal data when the data have been processed unlawfully, must be erased to fulfil a legal obligation to which Lowwi is subject, are no longer necessary for the purposes for which they were processed or when you object to a balancing of interests of legitimate interest Lowwi has made and there is no overriding legitimate interest for Lowwi or a third party (see section 11.1.6 below for information about the right to object). However, we may not always be able to comply with your request as there may be reasons that entitle us to continue processing, for example if the personal data are processed to fulfil a legal obligation as the legal basis (such as requirements under the Accounting Act) or if the data are necessary for Lowwi to establish, assert or defend legal claims.
11.1.4 Right to data portability
You have the right to receive a copy of the personal data concerning you in a structured format and, in certain cases, to have the data transferred to another data controller. However, this right only covers data you have provided to Lowwi yourself and which we process based on consent or contractual obligation towards you as the legal basis.
11.1.5 Right to restriction of processing
You have the right to request that our processing of your personal data be restricted in certain situations, which means that the data may only be processed for certain purposes. For example, you can request restriction of incorrect data while you have requested rectification. While Lowwi investigates the correctness of the data, their processing will be restricted.
11.1.6 Right to object to certain types of processing
When Lowwi processes your personal data based on a balancing of interests of legitimate interest as the legal basis or for direct marketing, you have the right to object to our processing. An objection to Lowwi’s balancing of interests can be made when you have personal reasons relating to your situation. In such an objection, Lowwi will assess whether we have legitimate grounds for the processing that outweigh your interest in protecting your privacy. If so, Lowwi may continue to process your personal data even though you have objected to the processing. Objection to direct marketing and analyses carried out for direct marketing purposes can be made without giving any reasons. In addition, you are given the opportunity to object to marketing in each individual digital mailing. If you object to direct marketing we will stop processing your personal data for that purpose and all types of direct marketing measures such as sending newsletters and offers. If you only object to personalised offers, marketing communications to you will be general, as it is difficult for us to determine which marketing is relevant to you if we are not allowed to analyse your personal characteristics.
11.2 If you believe that we process your personal data incorrectly you are welcome to contact us. Contact details are at the end of this policy. You also have the right to submit a complaint regarding the processing of your personal data to the Data Protection Authority, which is the supervisory authority responsible for the processing of personal data in Sweden.
You should always feel secure when you provide your personal data to us. Lowwi has therefore taken appropriate technical and organisational security measures to protect your personal data against improper or involuntary disclosure, use, unauthorised access, deletion, alteration or damage to your personal data. For example, all customer data are stored in a database that is protected by a firewall and access control so that only employees within Lowwi who need access to your data to perform specific tasks have such access.
13.1 The most recently updated version of Lowwi’s privacy policy is always available on our website. Our privacy policy always applies in the form and for the content published on the website.
13.2 Lowwi has the right to update the privacy policy at any time. If the privacy policy is changed, the updated policy will be published on Lowwi’s websites. We may also inform you by e-mail if there are major changes to the privacy policy. If you do not wish to accept the amended policy, you may terminate your account by contacting customer service; see contact details at the end of this policy.
Do not hesitate to contact us if you have any questions about this privacy policy or if you want more information about our processing of your personal data or if any information is incorrect and you want us to correct it. Contact customer service by sending an e-mail to [email protected]
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