Privacy Notice


Your privacy is important for us at Areim. On this page, you will find information about our processing of your personal data.

We process your personal data as part of our work, and we are committed to being transparent with the information we process about you and why. We have therefore prepared this privacy notice which describes our processing of your personal data.

The final responsibility for personal data processing lies with Areim AB, org. no 556719-4203 (“Areim”, “we”, “us” and “our”) as it is deemed the data controller for all alternative investment funds managed by it (the “Funds”), all subsidiaries wholly owned by the Funds and for all other entities operating within the Areim Group. This means that we are responsible for ensuring that the processing of your personal data as described herein is carried out in accordance with the rules set out in the General Data Protection Regulation (“GDPR”) and other applicable data protection and privacy laws and regulations (together “Privacy Laws”).

Areim has an internal personal data protection policy, based on the Privacy Laws. This internal policy applies to all situations where Areim processes personal data and must be adhered to by all Areim employees and consultants. Areim also maintains a so-called data processing register containing our personal data processing activities.

If you have any questions or complaints about the way we process your personal data, or wish to request exercise of your rights as a data subject, you are welcome to contact us by email at dataskydd@areim.se or by post to the following address: Areim AB, Regeringsgatan 30-32 B, 111 53 Stockholm, Sweden. You can find more information about what rights you have and how you may exercise them under the headline “What are your rights as data subject” below.

You can find directed information relating to our processing of personal data under the separate headings below.

The information on this page applies in general. In some cases, more specific information is provided in a separate contract or in another manner for other forms of involvement with Areim. Such information is intended to complement, and where appropriate, amend the information herein. 

What personal data do we process?

The personal data processed by us is often collected from you directly in conjunction with a contract being negotiated, prepared, or signed or otherwise through other direct contacts with Areim for instance through marketing activities, branch meetings and conferences, and other social arrangements. In some cases, to ensure that information is updated and accurate, Areim also collects personal data from generally available sources, such as from public and private registers to supplement the information collected directly from you.

To obtain information whether of a general or a specific nature regarding potential tenants, stakeholders, and other partners, Areim may from time to time collect personal data from generally available sources, such as public and private registers.

Areim also collects and processes personal data in contact with suppliers or their representatives and other external parties or in conjunction with press releases, recruitment processes and the fulfillment of its legal obligations.

Areim aslo collects and processes personal data in relation to potential and current tenants relating to the assets owned by the Funds.

The personal data we process in the above contexts may consist of contact details (e.g., name, title, employer, postal address, telephone number and email address), identification details (e.g., passport details and date of birth/ID number), and invoicing information (e.g., account number and tax details). We may also process personal data in the form of sound or image recordings in conjunction with marketing activities and other social events.

  • If you are a service provider providing services to us under an agreement, we may also save information that relates to the engagement including but not limited to your CV. We may also collect information relating to you that we find in public registers or social media.
  • If we have arranged or participated in an event, a conference or other social arrangement, we may save photos or films in conjunction with such the occasions, where you might be included, and use this for documentation or for marketing of future events.
  • If you’re a resident, or a lease holder of a commercial facility with a private company in one of our properties, we also collect and process your personal security number, your flat number or the identification code of your lease engagement, and information about your bank, bank account and any credit information used to fulfill our legal agreement. If necessary, we will also save information about you in relation to any incoming complaints or investigations that we carry out regarding breach of contract etc.
  • If you are a representative of an investor, or a potential investor or representative of such in one of our investment funds, we will due to regulatory requirements regarding measures against money laundering and financing of terrorism also collect and process data to understand whether you are 1) a beneficial owner of a company we are conduction business with, 2) a politically exposed person that might be subject to bribery or corruption, 3) or has been sanctioned by the European Union (“EU”) or the United Nations (“UN”) in the EU’s resp. the UN´s sanctions lists.
What is the purpose of our processing of personal data?

The main purpose of Areim´s processing of personal data is to be able to fulfill our obligations and exercise our rights in accordance with agreements, to take measures requested before or after an agreement has been signed, and to meet the requirements placed on Areim by law, other regulations or rules and official decisions. In certain cases, personal data may also be processed to exercise legal claims.

Areim also processes personal data for marketing purposes, statistics, system testing, market and customer analyses, in order to provide an overall understanding of Areim´s customer involvement and satisfaction. Additionally, personal data relating to existing and potential tenants, stakeholders and other partners may be processed to be further analyzed to develop and improve our business. Moreover, personal data may also be used to evaluate, develop, and improve our services, products, and it-systems for our customs in general.

We will only process your personal data for the purposes it was collected, and we will not share it with other persons or parties than as described herein this Privacy Notice.

Processing of personal data in conjunction with fulfillment of agreements and engagements

We may process your personal data in conjunction with entering into an agreement or administrating our current business relationship with you or the company you represent. Our processing of your personal data may be related to you being named as the contact person representing your employer in a business relation with us on the basis of an agreement, an assignment or to receive reports. In such a case we will use your name, telephone number, address and/or email address to contact you and your company to fulfill and exercise our contractual obligations and rights or business interests. In these cases, we will assume that your employer has informed you or has obtained the necessary consent from you to use your personal data in this way.

Lease agreements for commercial or residential facilities

If you have signed an agreement for lease of a commercial or residential property in one of our properties, we will use your personal data to contact your, provide rent notices, receive rent or fees, and to information you of any activities in the property, or to uphold or fulfill our legal rights and obligations under the agreement.

The legal ground relied upon for this processing is fulfilling rights and obligations under an agreement and/or, where applicable, Areim´s legitimate interest after balancing of interests has been carried out.

Processing of personal data in conjunction with fulfillment of legal obligations

We may process your personal data such as name, address, role/title, passport copy and information whether you are a politically exposed person and/or beneficial owner of an entity concerned to fulfill our legal obligations under mandatory laws for instance anti-money laundering measures, bookkeeping and tax requirements.

The legal ground relied upon for this processing is legal obligations under mandatory laws and Areim´s legitimate interest after balancing of interests has been carried out.

Processing of personal data in conjunction with issuing notice of interest

As a property owner we may from time to time offer the public or specific parties the possibility to buy a leasehold, or to rent an apartment or a facility, in one of our properties. If you have shown an interest, (for example at a viewing of a property) for our operation or otherwise contacted us personally, via our websites, or through a mediator, we may save your personal data to be able to get back to you if an occasion should arise that could be of interest for you. If you have shown an interest in participating at an event or a conference or other social arrangement that we arrange or partake in we might save your personal data to be able to invite you to a future event that we think might be of interest to you.

The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.

Processing of personal data in conjunction with press releases

We may process personal data by sending out press releases to individuals who have signed up to receive news from us via e-mail. In such cases, we may process name, email address, company and role/title details relating to such individuals.

The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.

Processing of personal data in conjunction with submitting interests or other forms

When you contact us via our or one of our properties´ website, we will save your contact details to be able to answer your questions or provide requested information.

The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.

Processing of personal data in conjunction with recruitment

We may process your personal data, in general such information which is stated in you CV, to administer our recruitment process and evaluate applicants, to manage certain legal aspects of recruitment and to be able to inform applicants of future career opportunities and events, provided the applicant has consented to such processing.

 

The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.

In case we want to store your personal data for future recruitment purposes, we will ask for your consent to this.

Processing of personal data in conjunction with electronic, IT and information, and personal data protection activities

We may use personal data to improve our services, protect or enhance our IT-security and to investigate or prevent trespassing or data breaches (e.g., by using cookies or IP-addresses, please see information about cookies).

The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.

Processing of personal data in conjunction with investigations, complaints, breaches, crimes, or litigations

It might happen that your personal data needs to be processed in order to ascertain or exercise responsibilities, to investigate possible breaches of contracts or crimes, or to defend our legal rights.
The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.

Who has access to your personal data?

We have taken appropriate technical and organisational security measures to protect the personal data we process from loss and unauthorised access, among other things. Only those who need to process personal data for the purposes for which they are processed have access to the personal data. Appropriate security measures we have taken include implementation of encrypted and private network connections (VPN connections) for all transmissions between our offices. We regularly review our security policies and processes to ensure that our systems are secure and protected.

Areim may share your personal data with our branch offices in Denmark, Finland and Norway and our sister company Areim Advisory (property adviser in Sweden), to be able to conduct our business and fulfill our obligations to our clients. In general, we do not share your personal data with parties outside the EU/EES area.

Areim does not sell personal data or other information about our relations to third parties.

Personal data processed within the IT-systems that we use to provide our services may be shared with IT-service providers outside EU/EES. This processing will in such a case be necessary to ensure our interests in providing qualitative and reliable services with secure techniques to you. We will ensure in agreements that the provider uses adequate technical and organizational measures to protect your personal data. Such providers will be obliged to fulfil contractual obligations which ensure that their processing of your personal data is compliant with the Privacy Laws. 

If you are a tenant or a leaseholder in one of our properties, your personal data will be shared with our accounting firm, with the payment service provider, with the property manager, and as necessary any maintenance providers. In case of litigation, legal processes or other circumstances that might require external advice, the personal data may also be shared with a legal firm, an authority or other relevant party.

We may also share personal data with authorities acting on their own mission in accordance with laws or authority decisions, for example Swedish Financial Supervisory Authority, Swedish Authority for Privacy Protection (”IMY”), the courts, the tax authority, or the police.

How long do we save your personal data?

In accordance with the Privacy Laws, Areim does not store any personal data longer than necessary for the purpose of the processing. We will only keep your personal data as long as necessary in order for us to achieve the purpose it was collected for or as required in order to comply with any mandatory retention periods under applicable law. To determine the retention periods, we consider the requirements of Privacy Laws, governmental regulations, and recommendations from authorities as well as any professional practices.

  • Areim is a licensed alternative investment funds manager (fund manager) under the supervision of the Swedish Financial Supervisory Authority. This means that certain information, including personal data, relating to our business, our services, business relations, clients etc. must be archived and retained for at least five (5) years, however, an even longer archiving period may be necessary.

 

  • Should the personal data be collected on basis of the Know Your Customer rules in the regulations for measures against money laundering and financing of terrorism the personal data will be saved for at least five (5) years. If the individual that the data belongs to has been subject to an investigation, in which case we are prohibited from informing the individual of this, it will have to be saved for ten (10) years.
  • The requirement to retain information regarding our fund management may mean that we are prevented to dispose personal data on you before the five (5) years have elapsed since collection if it is needed to fulfil rights and obligations under an agreement, or if they are subject to specific regulatory requirements.

 

  • Information needed for accounting and bookkeeping shall be saved in accordance with the Accounting Act for at least seven (7) years.

 

  • Information needed for investigation of incidents, any breach of contract, and any suspicion of crime in, or that concerns, our properties for the purpose of substantiating legal claims may be saved for two (2) years unless there is a dispute that requires longer processing. Reports of crime may only be saved for such time we are able to act.

What are your rights as data subject?

Areim is the controller of the processing of personal data described above. This means we are responsible for ensuring that the personal data are processed in accordance with current the Privacy Laws.

Data subjects have the right:

(i) to know what personal data we process about them;

(ii) to request that we rectify inaccurate or incomplete personal data about them;

(iii) to request that we erase their personal data (e.g., if the data are no longer needed for the purpose or if consent is withdrawn) or request that processing of the personal data be restricted;

(iv) to object to specific processing of personal data; and

(v) in some circumstances, to receive the personal data they have provided in machine-readable form, and to transmit them to another controller.

In some cases, restriction or erasure of personal data may also prevent us from meeting our commitments, e.g., to provide certain invitations or certain information. In the context of recruitment, restriction or erasure of personal data may prevent us from proceeding with a person’s application.

Anyone with objections about, or comments on, the way we process personal data has the right to contact or file a complaint with the Swedish Authority for Privacy Protection, which is the supervisory authority for our processing of personal data.

If you have any questions or complaints about the way we process personal data or wish to request exercise of rights as described above, you are welcome to contact us by email at dataskydd@areim.se or by post to the following address: Areim AB, Regeringsgatan 30-32 B, 111 53 Stockholm, Sweden.