TePe Data Protection Policy


1.

At TePe we are concerned about your integrity, and it is important to us that you feel comfortable in sharing your information with us. We have chosen to be transparent regarding the use of your information, and in accordance with the GDPR (General Data Protection Regulation), we have now updated our privacy policy.

2. Background

TePe Munhygienprodukter AB, org.nr 556224-6487 (hereinafter "TePe", "we", "our", "us") respect your privacy. This data protection policy (the "Data Protection Policy") describes how we process your personal data when you interact with us commercially, including as a representative of our current or potential customers, suppliers, business partners, prospects, and users of our services, as well as when you visit our website or communicate with us on social media. The Data Protection Policy also describes your rights in relation to our processing of your personal data and how you can assert these rights.

If you have any questions or if you wish to exercise any of your rights as described under the heading “What rights do you have when we process your personal data?”, you are welcome to contact us.

3. In short: How we process your personal data

Here you can read a summary of how we process your personal data. If you want more information, you can read the detailed information in the tables below. They describe in detail our purposes, the personal data we process about you, our legal bases and retention periods, and how we share your personal data in different situations.

 

How we process your personal data

We process a variety of personal data about you, such as your name and contact details and your organization. Usually, we receive the personal data directly from you, but we can also receive it from your organization.

When we refer to “your organization” in this policy, we refer to your employer or the organization that you represent.

 

We process your personal data in the following situations:

If your organization is our current customer, supplier, distributor or partner, your personal data will be processed to enter into an agreement with your company and administrate our relationship

If you represent a potential customer, supplier or partner, your personal data will be processed to communicate with you, provide offers on our products and send you news and information, offers and invitations

If you interact with us on our social media accounts or via email or our website, your personal data will be processed to interact with you and answer any questions you might have

If you use our website, your personal data will be processed to provide you a functioning website and analyse how you use the website

 

If you receive marketing from us,

your personal data will be processed to invite you to events, send marketing and information about our products and send newsletters to you and analyse how our newsletters are used to improve and develop them

Depending on the relationship we have with you, we process your personal data for all or only some of the above stated purposes. A detailed description of our processing of your personal data is provided in the charts below.

In some situations, we share your personal data with other companies and organizations, for example our IT partners, authorities and providers of services for analysing our website.

We mainly process your personal data within the EU/EEA. In some instances, we will transfer your personal data outside of the EU/EEA to our suppliers that are located there. Such transfer only takes place when we can ensure an appropriate level of protection of your personal data.

 

 

Below you find a detailed description of your rights and how to exercise them. In summary you have the following rights: 

4. Your rights

 

  • The right to lodge a complaint with a supervisory authority,
  • The right to withdraw your consent,
  • The right to access,
  • The right to object,
  • The right to erasure,
  • The right to rectification,
  • The right to restriction of processing, and
  • The right to data portability

 

If you have any questions about these rights, or wish to exercise any of your rights, you are more than welcome to contact us.

 

Below you find information about:

Who is responsible for your personal data

Detailed description of how we are processing your personal data

Disclosure of your information

Where we are processing your information

Your consent to the processing

Balancing of interests’ assessments when processing personal data based on the legal basis “legitimate interests”

 

When we refer to “your organisation” in this Data Protection Policy, we refer to your employer or the organisation that you represent. We will only process data about you in your business role, which for example means that we will only send marketing to your company and not to you in your capacity as a private individual.

5. Who is responsible for your data

TePe Munhygienprodukter AB, org.nr 556224-6487, is the data controller for the processing of your personal data as described in this Data Protection Policy. We are data controller for the processing of personal data on all TePe websites as well as our social media accounts. That means that it is our obligation to make sure that all the processing is carried out in a safe manner and in accordance with applicable laws and regulations.

If you have any questions concerning our processing of your personal data or if you wish to exercise any of your rights, you are welcome to contact our Data Protection Specialist. The easiest way to do that is to send an e-mail to dataprotection@tepe.com. You can also contact us by post at [Bronsåldersgatan 5, 213 76 Malmö].

 

Detailed description of how we are processing your personal data

Below you can find a detailed description of why we process your personal data, what personal data we process, the duration and the legal basis for our processing.

You are under no obligation to share your personal data with us. However, if you choose not to share any personal data with us, we will not be able to sell or deliver products to you, provide you with customer service, send you marketing or otherwise interact with you for the purpose of providing our products and services.

Not all information below is relevant for you and therefore we have provided the information under different headlines. Read the headlines that are relevant for you, i.e., based on how you come in contact with us.

 

If your organisation is our current customer, supplier, distributor or partner

In the tables below you find information about how we process your personal data when your organisation is our customer, supplier, distributor or partner. If your organisation is our customer, we will market our products and services to you as described below.

We primarily collect your personal data directly from you. Additionally, your personal data may be obtained from your organisation if they designate you as their representative.

Purpose

To enter into a contractual relationship with your organisation and perform the contract


e.g., to fulfil our obligations and exercise our rights arising from any contract with your organisation

Personal Data

Name, contact information (telephone number and e-mail), organisational belonging, position in your organisation, information about the order your organisation have made and any other information you or your organisation provides to us.

Legal basis

Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to process your personal data to be able to negotiate and enter into a contract with your organisation and to administrate the contract 

Storage period

During our contractual relationship and thereafter as long as there are any outstanding rights or obligations deriving from our contractual relationship.

 

Thereafter, necessary information is stored (i) as long as there is any outstanding product liability in order to handle any complaints and warranty cases, normally at least five years and (ii) up to ten years, as long as you can take legal action against us, deriving from our contractual relationship, with respect to the regulation concerning statute of limitation.

Recipients: We will share your personal data with our IT-partners.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose.

If you represent a potential customer, supplier or partner

Below you will find information about how we process your personal data if you represent a potential customer, supplier or partner (i.e. a business lead). To market our products and services we may collect your personal data from the internet or a third-party service.

To contact and communicate with you as a representative of our previous customer, distributor or partner which we consider a potential customer, distributor or partner

Name, position at your organisation, telephone number, and e-mail address

Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to contact you in your profession as a representative of our previous customer, distributor or partner, which we think could be interested in our products again 

If your organisation previously has been a customer, distributor or partner of TePe we will store your personal data for three months after the customer relationship ended for marketing purposes.

We will stop processing your personal data for this purpose if we receive information that you no longer represent your organisation.

Recipients: We will share your personal data with our IT-partners.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose.

To send news and information, offers and invitations to you as a representative of our previous customer, distributor or partner which we consider a potential customer, distributor or partner

Name and e-mail address.

Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to be able to send relevant information to you as a representative of our previous customer, distributor or partner which we consider a potential customer, distributor or partner

You will receive news and information, offers and invitations from us for as long as you represent your company or until you tell us that you no longer want to receive news or information, offers and invitations from us

Recipients: We will share your personal data with our IT-partners.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose.

Provide offers on products and services

E.g. to create, estimate and provide offers on our products and services.

Name

Contact information (e.g., telephone number and e-mail address)

Position at your organisation

If to you personally:
Take steps at the request of you prior to entering into a contract, GDPR article 6.1.b.

 

If to a party for which you are a contact person:
Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to be able to provide offers on our products and service

Until the offer is denied or, if it is accepted, during our contractual relationship.

Thereafter, necessary information is stored up to ten years, as long as you can take legal action against us, deriving from our offer or our contractual relationship, with respect to the regulation concerning statute of limitation.

Recipients: We will share your personal data with our IT-partners.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose.

If you interact with us on our social media accounts or via email or our website

To communicate with you on our social media accounts such as accounts on Facebook or LinkedIn, e.g. if you comment on a post

 

To communicate via email or contact form on our websites

 

Answer your questions and give you the best service

Information you provide to us, e.g. name, which company you represent and contact information

 

If you visit our social media channels we also process:

 

Information from your profile on the social media in question (username and any picture you have chosen for your account) and information which you provide on our page or during our interaction

Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to process your personal data to communicate with you once you have contacted us.

Your comments and communication with us on our social media channels can be deleted by you at any time. We will remove posts or comments which are in breach of the rules of the platform or in conflict with legislation as soon as possible.

Communication with us via our websites or in e-mails will be stored during the matter for which you have contacted us and thereafter for us to be able to handle any questions, complaints or claims.

Your personal data will be removed if you ask us to remove it or if you yourself delete the content, but we will otherwise store the personal data on the social media platform until further notice

 

We will stop processing your personal data for this purpose if we receive information that you no longer represent your organisation.

Recipients: When you interact with us on our social media account, the social media platform that you use will process personal data about you as a user. These social media platforms will continue to process your personal data as independent controllers. Information about how long they store your personal data can be found in their respective privacy information.

We will also share your personal data with our IT-partners.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose. However, the suppliers of the social media platform that you use will be able to access and process your personal data as independent controllers from outside the EU/EEA. You can read more about this in their respective privacy information.

If you use our website

To provide and manage our website

- To make the website work, we use cookies that create a unique ID for your session and make the website work at its best by recognising you during your visit

 

- To customise the website to your device, we use a cookie that collects information about your device, which we use to customise the view of the website so that you see the website in the size appropriate to the device you are using

 

- Remember which language you want to see the website in

 

You can read more about our use of cookies in our cookie policy.

IP address

Information about how you use the website

Information about your device

Information about the language you have chosen for the website

Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to process your personal data to provide a functioning website

We will store your personal data for a period of 14 months after your visit on our website.

Recipients: We will share your personal data with our IT-partners.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose.

If you consent to analytics:

To analyse how you use our websites to improve our website and communication as well as marketing activities

To do this we use an analytic service from Google Analytics, which means that we use a random ID to distinguish your device from other visitors and to acknowledge patterns in how our websites is used. We at TePe will however not know who you are

An encrypted version of your IP address which we at TePe can’t connect to you as an individual

Unique ID and session number

Information about your device/browser (initial timestamp, last timestamp, current timestamp and your screen resolution)

Information about your activities on the websites, e.g. what you click on

Other information that Google has about you, e.g. information about from which site you found us

Consent, GDPR article 6.1.a

Your personal data will be processed based on your consent. You can withdraw such consent at any time by contacting us.


You can prevent Google Analytics from using your personal data by downloading and installing this
browser add on.

We will store your personal data for a period of 14 months after your visit on our website.

Google will continue to store your personal data for their own purposes and Google will inform you separately about such storing.

Recipients: If you consent, we will share your personal data with Google which provides the service to analyse the website. We will also share your personal data with our IT partners.

Transfers outside EU/EEA: Your personal data will be transferred to the United States when you use our website and have consented to us using analytic services from Google. Your personal data will be transferred outside the EU/EEA based on an adequacy decision regarding the United States recognised by the European Commission (the EU-US Data Privacy Framework). You can find Google’s certification here, by e.g. searching for the company.

If you receive marketing from us

To market and inform about our business

E.g. to invite you to our events, to communicate relevant news and information within our practise areas to you, to communicate relevant information about us and our products and services to you, to inform about and present products or service offers and promote new products or services that are closely related to the products or services already purchased or used.

Identity information

Contact information

Employment information

If you are a customer or its contact person

Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to process your personal data to inform about our business through marketing

 

If you are a prospect or its contact person (or otherwise)

Consent, GDPR article 6.1.a

If you are a customer or its contact person

During our contractual relationship and thereafter as long as there are any outstanding rights or obligations deriving from our contractual relationship.

Otherwise

For as long as we have your consent. We will refresh your consent as appropriate.

To send information about news, marketing, offers and invitations (“newsletters”) to you who have chosen to subscribe to our newsletters

 

To improve and develop our newsletters by analysing how you open them and what you click on in the newsletters

Email address

Name

Address

Country

 

Information about how you open our newsletters and what you click on

IP-address

E-mail address

Legitimate interest, GDPR article 6.1.f.

 

Our legitimate interest to process your personal data to send you the newsletters you have stated that you wish to receive. 

 

Consent, GDPR article 6.1.a

 

We will only process your personal data for this purpose if you consent.

You have the right to withdraw your consent at any time by contacting us. Your withdrawal of consent shall not affect the lawfulness of the processing before its withdrawal.

You can choose to unsubscribe or object to receiving newsletters and marketing at any time. If you object to receiving marketing from us, we keep track of this in our “unsubscribe-list” to avoid sending you any further marketing material.

Recipients: We will continue to store and use your personal data for marketing purposes for as long as you interact with us and twelve months thereafter. We will delete your personal data if you continuously choose to not answer when we contact you.

You can choose to unsubscribe or object we keep track of this in our “unsubscribe-list” (see below) to avoid sending you any further marketing material.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose.

To comply with marketing legislation

If you have stated that you do not wish to receive marketing from us, we will store such information in an “unsubscribe-list” to make sure we do not send any marketing to you

Name

Email address

Legal obligation, GDPR article 6.1.c

 

The processing is necessary to comply with legal obligations which we are subject to, i.e. marketing law which require us to not send marketing material to individuals who have objected to receiving such marketing.

 

We cannot make sure you will not receive marketing from us without processing your personal data for this purpose and you are therefore required to provide your personal data to us.

You will be listed in our “unsubscribe-list” until further notice.

Recipients: We use third parties which on our behalf and on our instructions help us administrate our marketing and, therefore, will have access to your personal data.

We will also share your personal data with our IT partners.

Transfers outside EU/EEA: We will not transfer your personal data for this specific purpose.

If you choose not to provide us with certain personal data or limit our right to process your personal data, that may result in that we cannot fulfil our obligations to you or to the party you represent and that you, or the party you represent, cannot assert your, or its, rights against us.

 

If you do not want to receive marketing information from us

 

As described above, we may process your data to invite you to our events, to communicate relevant news and information within our practise areas to you, to communicate relevant information about us and our services etc. If you do not want to receive such communication, you are welcome to email us at our contact information.

8. Disclosure of your information

To whom may we disclose your information?

Your personal data is initially collected and processed by us, and we do not sell your personal data. This means that your personal data will be handled by our employees, but only by the personnel in need of such access to conduct their work.

 

To conduct our business, we need to work with chosen suppliers and partners which then will process your personal data in accordance with the provisions below. We are responsible for any sharing of your personal data to such suppliers or partners, and in the event of such sharing or transfer we will take every reasonable legal-, technical- and organizational action in order to make sure that your personal data is handled in a safe manner and that the level of security is adequate.

 

Any recipient of your personal data that process your information on our behalf are bound by processor contracts which includes, among other things, provisions that such party shall follow our instructions, take the measures that we find necessary, observe confidentiality, and respect this Data Protection Policy.

  • Our group of companies. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) who carries out processing on our behalf in order to conduct our business in the most efficient way, insofar as reasonably necessary for the purposes set out in this policy.
  • To ensure good and secure IT operations, we will store your personal data, anonymized, when possible, within our IT systems. This means that we share your personal data with our IT suppliers. We only share your personal data with our IT partners if it is necessary for them to fulfil their obligations towards us according to our agreement with them.
  • Advisers, suppliers, subcontractors and other business partners

 

We may disclose your personal information to any of our insurers, professional advisers, agents, suppliers, subcontractors or business partners insofar as reasonably necessary for the purposes set out in this policy. Hence, we might share your personal data when a third party provide us with services such as providing, hosting and maintaining IT systems, technical support, marketing, etc. on our behalf.

 

  • Other

We may disclose your personal information:

(a) to the extent that we are required to do so by law or a court order;

(b) in connection with any ongoing or prospective legal proceedings;

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

 

  • If you receive our newsletters, we will share your personal data with the company which helps us send newsletters. The information contains personal data but will only be processed on our behalf and on our instructions as stated in the parties’ data processing agreement.
  • If you use our website and have given your consent, the following parties will process your personal data
    • Google, which provides the service to analyse the website, and
    • The companies which provide the marketing services we use, such as Google (including YouTube), Facebook, LinkedIn, and other marketing tools.
  • If you interact with us on social media or visit our social media accounts, the social media platform that you use will process personal data about you as a user. The social media platforms are independently responsible for the processing of your personal data and will inform you separately about how they process your personal data.
  • For corporate transactions

 

If we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control we may transfer your information as part of this process.

9. Where are we processing your information?

As a general principle, we only process your personal data within the EU/EEA. In some situations, however (as further set out below), your personal data will be transferred to and processed by a company within our company group or by a supplier, subcontractor or other business partner that processes personal data outside the EU/EEA. In that case we will make sure that such processing is based on a decision from the European Commission establishing that the country in question ensures an adequate level of protection or appropriate safeguards that ensure that your rights are protected or based on another ground for such transfer in accordance with GDPR.

 

Your personal data will be transferred outside the EU/EEA in the following cases:

  • To our IT-suppliers that are located outside of the EU/EEA. However, to protect your personal data and minimize the risk of it being transferred outside the EU/EEA, we ensure that your personal data is stored exclusively on servers of our IT suppliers that are situated within the EU/EEA.
  • If you visit and communicate with us on our social media channels (e.g., Facebook and Instagram), your personal data will be transferred outside the EU/EEA. One reason being that many of these companies are based in the United States.
  • If you visit our websites and have consented to analytics and marketing, your personal data may be transferred outside the EU/EEA to the companies which provide the service to analyse the website and provide the marketing services, e.g., Google (including YouTube), Meta,

 

We also rely on an adequacy decision regarding most transfers to the US, when our American suppliers are certified under the EU-US Data Privacy Framework. You can find the adequacy decision for the US here. For example, Google and Meta are certified under the EU-US Data Privacy Framework. You can find their certifications by searching for their names on the Data Privacy Framework website.

 

In the absence of an adequacy decision, or when our transfer is not protected under an adequacy decision, we and our suppliers will instead rely on Standard Contractual Clauses (Article 46.2 c GDPR) module 1 and module 2, and supplementary security measures for the transfer of personal data outside of the EU/EEA. We will rely on the Standard Contractual Clauses when your personal data is processed in a country without an adequacy decision. The use of Standard Contractual Clauses is an effort to provide a safe transfer of your personal data. You can find the Standard Contractual Clauses here.

 

If you want to know more about where your personal data will be processed, please feel free to contact us.

10. Your consent to the processing

In some situations, we process your personal data after you have given your consent to the processing. These situations are described above, and you can withdraw your consent at any time by contacting us. If you withdraw all or part of your consent, we will cease processing for that purpose. Your withdrawal of consent does not affect the lawfulness of the processing based on your consent, prior to its withdrawal.

 

Balancing of interests’ assessments when processing personal data based on the legal basis “legitimate interests”

As we state in the tables above, for some purposes, we process your personal data based on our “legitimate interest”. By carrying out a balancing of interests’ assessment concerning our processing of your personal data, we have concluded that our legitimate interest for the processing outweighs your interests or rights which require the protection of your personal data.

If you want more information in relation to our balancing of interests’ assessments, please do not hesitate to contact us. Our contact information can be found at the beginning of this Data Protection Policy.

 

Your rights

In accordance with the GDPR, you have certain rights that you can exercise to affect how we process your personal data– see below for more information.

 

If you have any questions regarding your rights or want to exercise any of your rights, please contact us by using the contact details above. You can also find more detailed information about your rights and when they apply at The Swedish Authority for Privacy Protection (IMY).

  • Right to complainArticle 77 of the GDPR

    You have the right to lodge a complaint with the competent supervisory authority if you consider that the processing of your personal data violates the GDPR. In Sweden, the competent supervisory authority is The Swedish Authority for Privacy Protection (IMY).
  • Right to withdraw your consent – Article 7.3 of the GDPR

    You have the right to withdraw your consent at any time by contacting us. You can always withdraw the consent you give on the website directly on the website.
  • Right of access – Article 15 of the GDPR

    You have the right to obtain confirmation as to whether we are processing your personal data or not. You can make a request by contacting us. If we are processing your personal data, you also have the right to obtain a copy of the personal data processed by us as well as information about our processing, such as the purposes of the processing and for how long your personal data is stored.
  • Right to object – Article 21 of the GDPR

    You have the right to at any time object to our processing of your personal data for direct marketing purposes (including profiling) and to processing of your personal data that is based on a legitimate interest (including profiling).
  • Right to rectification of processing – Article 16 of the GDPR

    You have the right to have inaccurate personal data concerning you rectified without undue delay. You also have the right to have incomplete personal data completed.
  • Right to erasure (“the right to be forgotten”) – Article 17 of the GDPR

    Under certain conditions, you have the right to have your personal data erased by us without undue delay. For example, if you withdraw your consent and there is no other legal basis for the processing or if the personal data is no longer necessary for the purposes for which they were collected or processed.
  • Right to restriction of processing – Article 18 of the GDPR

    Under certain conditions, you have the right to request that we restrict our processing of your personal data. For example, if you contest the accuracy of the personal data, or if the processing is unlawful and you oppose the erasure of the personal data and instead request the restriction on the use of the personal data.
  • Right to data portability – Article 20 of the GDPR

    If we process your personal data based on your consent or to fulfil a contract, you have the right to receive personal data concerning you. This right applies to personal data that you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transmit those personal data to another controller, where technically feasible.

Our Data Protection Policy was updated 2025-04-04