Privacy policy
Privacy Policy
This Privacy Policy explains how TPG handles the personal data of customers and other people who interact with TPG as described below. If you have any questions about how we process your personal data, or you would like to exercise any of your rights, please contact us (see “Data controller and how to contact us”).
For information about the cookies and similar technologies we use on our website, see our Cookie Policy.
Below you can read more about how we process personal data. This policy is long, so feel free to use the summary and the contents list to jump to the section that interests you.
When we say “you” in this Privacy Policy, we mean you as an individual, or you as a company representative if you are acting on behalf of a business.
Summary
- If you shop with us, we process your personal data to handle your order, send you marketing after your purchase, find potential customers similar to you, ask for and publish reviews, and comply with accounting law.
- If you join the TPG Customer Club, we process your personal data to send you offers you may like, show you personalized offers when you log in, improve and develop our products and services, give you the benefits of a membership account, create and manage your membership account, and communicate with you about it.
- If you visit our website, we process your personal data to remember your choices and save your favorites, personalize the website for you, let you log in, and keep the website working. If you consent, we also process your personal data to improve our website and show you marketing you may find interesting.
- If you receive marketing from us, we process your personal data to send it to you. We analyze how you interact with our emails so that we can improve them.
- If you tag us in a social media post or use our hashtag, we process your personal data to share your post and photos.
- If you take part in our competitions or events, we process your personal data to manage your participation, publish photos, films and other content (if you have consented), and contact you about future events unless you have opted out.
- We also process your personal data to communicate with you if you have questions, complaints, legal claims or similar.
- Your rights: you have the right to lodge a complaint with the supervisory authority, to withdraw your consent, and to access, object, erasure, rectification, restriction of processing and data portability.
Contents
- Data controller and how to contact us
- Who processes your personal data
- Transfers of your personal data outside the EU/EEA
- Detailed information about how we process and store your personal data
- Legitimate interests
- Consent
- Your rights when we process your personal data
- Changes to this policy
Data controller and how to contact us
TPG AB, Swedish company registration no. 559447-4321 (“TPG”, “The Perfect Gloss”, “we”, “our” or “us”), is the data controller responsible for the processing of your personal data described in this Privacy Policy.
If you have questions about how we process your personal data or use cookies, or if you would like to exercise any of your rights described below, you are welcome to contact us:
- By email: support@tpgab.se
- By post: TPG AB, Box 1004, 26291 Båstad, Sweden
Detailed information about how we process and store your personal data
In this detailed description, you can read more about:
- where we get your personal data from,
- why we process your personal data,
- the categories of personal data we process,
- the legal basis for processing your personal data, and
- whether you are required to provide your personal data to us.
If you shop with us
When you place an order, we process your personal data for the purposes set out in the sections below. We also process your personal data to send you marketing after your purchase (unless you have objected). Read more under “If you receive marketing from us”.
Where do we get your personal data from? From you, when you place your order or contact us. We also generate some personal data ourselves when we analyze our emails.
Handling your order as a consumer
Purposes:
- Receive, register and process your order.
- Make it easy for you to complete your purchase.
- Send you relevant order-related emails, such as your receipt, order confirmation and delivery information (if you have chosen delivery).
- Process your payment, including sharing your personal data with your payment service provider.
- Deliver your order, including sharing your personal data with your carrier (if you have chosen delivery).
Personal data we process:
- Name
- Contact details (address, email address and phone number)
- Information about your order, for example which product you ordered
- Payment information
Legal basis: Performance of a contract. The processing is necessary for us to perform the contract for your purchase. You must provide this personal data in order to complete a purchase with us.
Handling your order as a business customer
Purposes:
- Receive and process orders for the company you represent.
- Send relevant order-related emails, such as a receipt and order confirmation.
- Send delivery information by email and deliver the order to the company you represent (if delivery has been chosen).
- Enable payment on behalf of the company you represent.
Personal data we process:
- Name
- Contact details (address, email address and phone number)
- Information that you or the company you represent provide to us
- Information about the order, for example which goods your company has ordered
- Payment information
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in administering the orders placed with us by the company you represent.
Finding potential customers similar to you (lookalike audiences)
Purposes:
- Find potential customers who resemble your profile.
- We share information about our members with Meta, which can then use that information to show our ads to people with a profile similar to yours.
Personal data we process:
- Information about your purchases
- Information about your online browsing behavior
Legal basis: Consent. We ask for your consent in order to find potential customers. You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out before you withdrew it.
Asking you to review your purchase and publishing your review
Purposes:
- Send you emails asking you to review the product you have bought.
- Publish your review, for example on our website, if you choose to consent to this.
Personal data we process:
- Name
- Email address
- Information about the product you bought, so that you can review it
- Information you provide in your review
Legal basis:
- Legitimate interests. The processing is necessary for our legitimate interest in being able to contact you with a request to evaluate us and our products, so that we can improve our products and range.
- Consent. We ask for your consent to publish the reviews you submit to us. You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out before you withdrew it.
Improving and developing our emails
Purposes:
- To improve and develop our emails, we analyze how you open them and what you click on.
- We collect your data using cookies and similar technologies. You can read more about how we use cookies in our Cookie Policy.
Personal data we process:
- IP address
- Email address
- Information about how you open our emails and what you click on
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in improving and developing our emails.
Complying with accounting legislation
Purpose:
- Comply with accounting legislation by registering, booking and archiving your payments and other transactions between you and us.
Personal data we process:
- Payment history, transactions and other material that forms part of our accounting records
Legal basis: Legal obligation. The processing is necessary to comply with mandatory law, namely accounting legislation.
If you join the TPG Customer Club
When you register a membership account and join the TPG Customer Club, we process your personal data as described below. The TPG Customer Club, including the membership account, is free of charge. Among other things, it gives you personalized and relevant offers and lets you log in to see your details and order history. You can find information about the marketing you receive as a member under “If you receive marketing from us”. If you have a business account, a colleague may have given us your personal data.
If you do not provide your personal data to us, we cannot create or administer your account or give you the benefits of being part of the TPG Customer Club.
Where do we get your personal data from? From you. We also generate some personal data ourselves when we analyze our emails.
Showing you personalized offers online (including profiling)
Purposes:
- Show you relevant product recommendations and other offers we think may interest you when you visit us while logged in.
- We tailor the recommendations to you based on other information linked to your account that we already hold about you and on how you use your account (for example your purchase and browsing history). This means that profiling* of your use of your account takes place.
Personal data we process:
- Name
- Purchase and order history
- How you use your account (for example how you click or search on our website)
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in showing personalized product recommendations and offers to you, or to the company you represent, as a member of the TPG Customer Club.
*Profiling: Your personal data is used for what is known as profiling, so that we can show you the offers we think suit you best and provide personalized marketing. We do this because otherwise we could not show you relevant offers and marketing, and you would instead see offers that are not relevant to you. You have the right to object to profiling. You can read more about your right to object below, where your rights are explained in detail.
Improving and developing our products and services
Purposes:
- Give you the opportunity to influence our range and services by taking part in our product and service development.
- Send you invitations to take part in surveys.
Personal data we process:
- Name
- Contact details (address, email address, phone number)
- Information you give us in surveys
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in improving and developing our products by inviting you, as a member of the TPG Customer Club, to take part in our product development and surveys.
Giving you the benefits of a membership account
Purposes:
- Make shopping easier by letting you manage questions about your current order while logged in as a member.
- Give you a better overview of your orders by providing features to view and track your current and past purchases (including digital receipts).
Personal data we process:
- Purchase and order history
- Information about your past purchases
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in offering you, or the company you represent, as a member of the TPG Customer Club, a feature where you can manage current orders and see your or your company’s past purchases (including digital receipts).
Creating and managing your membership account
Purpose:
- Create and manage your membership account.
Personal data we process:
- Your name
- Email address
- Your password
- Any other personal data linked to your account
Legal basis: Performance of a contract. The processing is necessary for us to fulfil our obligations to you and to provide secure login. If you do not provide your name, contact details and password, you will not be able to create an account.
Communicating with you about your membership account
Purpose:
- Send you information relating to your TPG Customer Club account.
Personal data we process:
- Name
- Email address
- Phone number
- Information about your purchases
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in being able to communicate with you, or the company you represent, as a member of the TPG Customer Club.
If you visit our website
Below we describe how your personal data is processed when you visit our website. To collect personal data for analytics and marketing as described below, we use cookies and/or similar technologies. Our information about cookies, which you can find in our Cookie Policy, explains in more detail how this works.
Where do we get your personal data from? From your device (for example your phone, computer or tablet) during your visit. If you consent, our providers also use information they already hold about you to carry out analytics and to show you offers from us that may interest you.
Analyzing how our website is used – if you consent
Purposes:
- Analyze how you use our website using cookies. We do this to improve the website’s functionality, to tailor the website to our visitors and to draw conclusions about our visitors.
- To do this, we use, among other things, the analytics service Google Analytics, which uses a random ID to tell your device apart from other visitors and to identify patterns in how our website is used.
- We are only interested in how visitors interact with us at an overall level. We at TPG do not know who you are and do not take any steps to find out.
Personal data we process:
- An encrypted version of your IP address that we at TPG cannot link to you as an individual
- Information about how you use our website, for example what you click on, how long you stay and how many times your device has visited our website, which gives us the basis for counting our total number of visitors
- The region you use our website from
- Your device and browser, for example your screen resolution
- Other information that Google and other analytics services hold about you, for example which website or other channel you used to find us
Legal basis: Consent. We obtain your consent through our Cookie Tool when you visit our website. You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out before you withdrew it. You can opt out of Google Analytics by, for example, downloading and installing this browser add-on.
Showing you offers from us on other websites and social media – if you consent
Purposes:
- Market our products by showing you offers and new products we think may interest you. We show marketing tailored to you on other websites and social media that you visit.
- We may show offers using advertising services from, for example, Meta (Facebook and Instagram), Google and TikTok. We do this based on analysis of our website, through cookies or similar technologies, and on information these parties already hold about you.
- We tailor the marketing to you based on information the advertising services already hold about you and on your earlier browsing history with us. This means that profiling* of your browsing history takes place.
Personal data we process:
- An encrypted IP address that we at TPG cannot link to you personally
- The region you use our website from
- Information about how you interact with our website or our ads, for example which pages you visited after clicking on our ad, and analysis of how and when you use our website, such as whether you add something to your cart, make a purchase or search for something
- Information the advertising services already hold about you, for example which website you found us from
Legal basis: Consent. We obtain your consent through our Cookie Tool when you visit our website. You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out before you withdrew it. You can find more information about your choices on Instagram here, and on Facebook here, where you can choose which ads you want to see under “Ad settings”.
*Profiling: Your personal data is used for what is known as profiling, which the advertising services use to show you the offers they and we think suit you best and to provide personalized marketing. We do this because otherwise we could not show you relevant offers and marketing, and you would instead see offers that are not relevant to you. You have the right to object to profiling. You can read more about your right to object below, where your rights are explained in detail.
Remembering your choices and saving your favorites
Purpose:
- Remember your choices, for example whether your device has given consent, which country version of the website and which currency you want to see, and which products you have put in your cart.
Personal data we process:
- Information about your choices on the website, for example which products you have put in your cart or your consent choice, including when you responded to our consent request
- Your geographic location (so that we can save your language and currency preferences)
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in remembering your choices.
Enabling login
Purpose:
- Keep you logged in so that you can use your TPG account.
Personal data we process:
- Information about your login
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in letting you use your TPG account.
Essential functionality so that the website works
Purposes:
- Make sure our website works properly and securely.
- Adapt the website to how you use it, for example so that you can use the chat without us confusing you with other users.
Personal data we process:
- Information about your device, for example your IP address and the type of device you use (phone, computer or tablet)
- Information you enter in the chat
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in providing a well-functioning website.
If you receive marketing from us
If you receive marketing from us by email, SMS or post, we process your personal data as described below.
Where do we get your personal data from? If you receive our emails and SMS messages, we have received your personal data from you and have generated some personal data ourselves when we analyze our emails. If you receive postal mailings from us, we have obtained your personal data from publicly available sources.
Sending newsletters and other marketing
If you have shopped with us
Purposes:
- Send newsletters and other marketing to you as a customer.
- We only send marketing to you if you did not object to receiving it when we collected your personal data, or at a later time.
- To improve our emails, we analyze them as described below.
Personal data we process:
- Name
- Email address
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in sending marketing, relying on the so-called “soft opt-in” rule, to customers who have shopped with us as individuals or whose company is a customer of ours, and who did not opt out of marketing when we collected their personal data. You can opt out of marketing from us at any time. If you do, we keep your personal data on our suppression list.
If you are a member of the TPG Customer Club
Purposes:
- Members of the TPG Customer Club receive personal offers from us. This is of great value to Customer Club members and is a promise from us as part of membership.
- This applies only if you did not opt out of marketing when you joined the TPG Customer Club or in connection with a purchase, and have not objected to marketing since.
- We tailor the marketing to you based on other information linked to your account that we already hold about you and on how you use your account (for example your purchase history). This means that profiling of your use of your account takes place.
- To improve our emails, we analyze them as described below.
Personal data we process:
- Name
- Email address
- Phone number
- Address
- Purchase and order history
- How you use your account (for example how you click or search on our website)
- Information about products you have put in your cart
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in sending newsletters and personalized offers to you, or to your company, relying on the so-called “soft opt-in” rule. You can opt out of marketing from us at any time. If you do, we keep your personal data on our suppression list.
If you have signed up for our newsletters
Purposes:
- Send direct marketing (such as newsletters and invitations).
- To improve our emails, we analyze them as described below.
Personal data we process:
- Name
- Email address
- Phone number
Legal basis: Consent. We ask for your consent to send you marketing and invitations. You can withdraw your consent or unsubscribe from our marketing at any time. Withdrawing your consent does not affect the lawfulness of any processing based on consent carried out before you withdrew it.
If you have attended one of our events
Purposes:
- Contact people who have attended our events to invite them to future events or to market us and our products.
- To improve our emails, we analyze them as described below.
Personal data we process:
- Name
- Email address
- Phone number
- Any other information you have given us
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in marketing our events and products. You can opt out of marketing from us at any time. If you do, we keep your personal data on our suppression list.
Profiling: Your personal data is used for what is known as profiling, so that we can show you the offers we think suit you best and provide personalized marketing. We do this because otherwise we could not produce relevant offers and marketing for you, and you would instead receive offers that are not relevant to you. You have the right to object to profiling. You can read more about your right to object below, where your rights are explained in detail.
Improving our emails
Purposes:
- To improve and develop our emails, we analyze how you open them and what you click on.
- We collect your data using cookies and similar technologies. You can read more about how we use cookies in our Cookie Policy.
Personal data we process:
- IP address
- Email address
- Information about how you open our emails and what you click on
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in improving and developing our emails.
Sending postal mailings to you
Purpose:
- Send marketing by post to addresses in areas that we consider to be relevant recipients of our postal mailings.
Personal data we process:
- Name
- Address
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in sending marketing to addresses in relevant areas. You can opt out of marketing from us at any time. If you do, we keep your personal data on our suppression list.
Complying with marketing legislation
Purposes:
- If you have told us that you do not want to receive marketing, or you have withdrawn your consent to marketing, we store your email address on a “suppression list” to make sure we do not market to you.
- This is not personal data that we actively process: we do not look at your email address and do not use it for anything other than making sure you do not receive marketing from us.
Personal data we process:
- Email address
- Phone number (where applicable)
- Information that you no longer want marketing from us or that you have withdrawn your consent to marketing
Legal basis: Legal obligation. The processing is necessary to fulfil our obligation under marketing legislation to make sure you do not receive mailings that you have asked not to receive.
If you tag us in social media posts or use our hashtag
If you tag us in social media posts or use our hashtag, we process your personal data as described below.
Where do we get your personal data from? From the information you have published on social media.
Sharing your social media posts and photos on our website
Purposes:
- Send you a request asking whether we may use your content in our marketing on our website.
- Share your content on our website and on our social media, if you consent.
Personal data we process:
- Name
- Username, for example on Instagram
- Your social media content, for example your photos from Instagram
Legal basis: Consent. We ask for your consent for the personal data we process for marketing purposes and to share your content on our website. You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out before you withdrew it.
If you take part in a competition or event with us
If you take part in a competition or event with us, we process your personal data as described below. We also process your personal data to send marketing after events. Read more under “If you receive marketing from us”.
Where do we get your personal data from? From you, through your participation in a competition, through your event registration and from your social media. We also generate some personal data ourselves when we analyze our emails.
Managing your participation in competitions and events
Purposes:
- Communicate with you if you take part in a competition or event (for example answer questions, confirm your event registration or send evaluations after events).
- Check that you are eligible to take part in the competition, for example if there is an age requirement.
- Select winners and deliver prizes, for example by checking that your entry meets the competition requirements.
Personal data we process:
- Name
- Contact details (for example address, email, phone number)
- Information provided in competition entries (for example information about your order)
- Information provided in event evaluations
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in running and managing your participation in our competitions and events, and in sending evaluations after you have attended an event.
Publishing audio and visual material from our events (marketing)
Purposes:
- Publish photos, films and other content from competitions and events, for example photos of winners or of the event, in our digital channels and on our website for marketing purposes, provided that we have obtained your consent.
- Before and during our events, we clearly inform you about photo, film and sound recording.
Personal data we process:
- Photos, films and sound recordings in which you may appear as a participant
Legal basis:
- Legitimate interests. The processing is necessary for our legitimate interest in marketing our events.
- Consent. If you are the main focus of photos or of video and sound recordings, we process this personal data based on your consent. You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out before you withdrew it.
To communicate with you and respond to questions, complaints, legal claims or similar
If you make a return, contact us (for example via social media or our customer service) or otherwise communicate with us, we process your personal data as described below. We get your personal data from you when you contact us, or from your purchase.
If you use social media, the social media platform you use (for example Facebook) will also process your personal data. We therefore recommend that you read our information below together with the information you find on that platform.
Handling customer service cases
Purposes:
- Communicate with you.
- Respond to any questions.
- Identify you when you contact us.
- Investigate complaints and support cases.
Personal data we process:
- Name
- Contact details (address, email address and phone number)
- Your correspondence with our customer service
- Information you provide in our chat
- Information relevant to handling your case, for example information about your purchase or about the request you have made to us
- If you contact us through social media (for example Instagram), we also process information from your profile (username and the picture you have chosen for your account)
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in communicating with you and handling customer service cases by responding to and investigating your questions, complaints and feedback. You must provide this personal data to us, otherwise we cannot help you with your case.
Handling claims, complaints and similar matters
Claims
Purpose:
- Handle any claims.
Personal data we process:
- Name
- Contact details (address, email address and phone number)
- Information from our communication with you in connection with your claim (for example about a defect in a product and the steps we have taken in a return or warranty case)
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in being able to defend ourselves against a possible legal claim.
Right of withdrawal, returns, recalls, warranties and complaints
Purpose:
- Handle the right of withdrawal (right to cancel), returns, product recalls, warranties and complaints smoothly and in accordance with applicable consumer rules and our contract with you.
Personal data we process:
- Name
- Contact details (address, email address, mobile number)
- Information relevant to handling your case (for example information about your purchase or about the request you have made to us)
- Information from our communication with you (for example about a defect in a product and the steps we have taken in a return or warranty case)
Legal basis:
- Legal obligation. The processing is necessary to fulfil legal obligations under applicable mandatory consumer protection legislation and other mandatory rules.
- Performance of a contract. The processing is necessary for us to perform the contract for your purchase. If the personal data is not provided, we cannot help you with, for example, a warranty case.
- Legitimate interests. The processing is necessary for our legitimate interest in handling your questions, complaints and other claims efficiently and in a customer-friendly way.
Purchases made on behalf of a company
Purpose:
- If you have made a purchase on behalf of the company you represent, we process your personal data to handle any questions and returns in accordance with the agreement we have with that company.
Personal data we process:
- Name
- Contact details (address, email address and phone number)
- Information that you or the company you represent provide to us
- Information about the purchase, for example which goods your company has ordered
Legal basis: Legitimate interests. The processing is necessary for our legitimate interest in handling your questions and returns in accordance with the agreement we have with the company you represent.
How long do we keep your personal data?
We delete personal data on an ongoing basis and do not keep your personal data for longer than is necessary for the purpose for which it was collected. Some personal data we must keep for longer – for example, information about your purchase, to meet the requirements of the Swedish Accounting Act or other mandatory consumer legislation.
You can influence how long we keep some of your personal data. For example, you can opt out of marketing from us at any time, or delete an account you have with us. If you opt out of marketing, your details are kept on our suppression list to make sure we do not send you marketing.
- Social media posts. If you have tagged us in a social media post and we have shared it, the post stays on our website or our social media account until further notice. We regularly remove content that is no longer relevant (which varies from post to post), or when you contact us and ask us to remove the post or your personal data.
- Orders. If you shop with us, we actively process the personal data linked to your purchase for a few days to administer and handle your order so that you receive the goods you ordered. After that, information about your purchase is stored for a period so that we can smoothly, and in accordance with applicable consumer rules, handle any questions about your purchase, returns, warranties and complaints. Some personal data is stored for longer to comply with the Accounting Act: personal data that forms part of our accounting records is kept for seven years (until the end of the seventh financial year).
- Membership. If you become a member, we keep your personal data until you delete your account. This means, among other things, that you will receive personalized marketing from us until you close your account with us, unless you object to receiving our marketing before then. If you have not made a member purchase or logged in to your membership account for 24 months, your membership will automatically end and your personal data will be deleted.
Who processes your personal data?
Your personal data is primarily processed by us at TPG. In some cases, however, we share your personal data. This applies in the following situations:
- Website visits. If you visit our website and give your consent, your personal data is processed by the services we use on the website (for example analytics and marketing services such as Google and Meta). You can see information about the services we use in our cookie tool, which you can find via the “Cookie Settings” link in the website footer (the “Cookie Tool”). These recipients process personal data on our behalf as our data processors. In some cases, however, they act as independent controllers, for example for the further processing of your personal data. If so, they will inform you separately about the processing for which they are themselves responsible.
- Payments. If you place an order with us, your personal data is processed by our payment service provider, which receives the personal data you provide so that it can handle your purchase. Depending on the payment option you choose at checkout, exactly which data the provider processes, and how, may vary. You can find information on our website about which payment service provider(s) we use.
- Delivery. If you place an order with us, we share your address with our carrier so that we can deliver your products. The carrier only receives the address your product is to be delivered to. Which carrier processes your personal data depends on the choice you make at checkout. You can find information on our website about which carrier(s) we use.
- Reviews. After your purchase you will receive a request to write a review. We use a service to manage your reviews. The service processes your personal data on our behalf as our data processor.
- Emails. If you receive any of our emails, we use our email service provider, which processes this personal data on our behalf as our data processor. It processes your personal data to send and analyze our emails.
- Social media. If you contact us via social media, if we share your social media posts or if you take part in a competition on social media, the social media platform we use (for example Instagram) will have access to your personal data.
- IT providers. So that we have functioning IT systems and can run our business efficiently, our IT providers will process your personal data, for example Shopify, which provides our e-commerce platform. These IT providers process personal data on our behalf as our data processors.
If you would like more information about how we share your personal data, please contact us.
Transfers of your personal data outside the EU/EEA
Our processing means that your personal data is shared with certain providers that process it outside the EU/EEA. Below you can read about when our service providers process personal data outside the EU/EEA.
- If you visit our website, your personal data will be shared with the providers we use. For example, if you have consented, we share your personal data with Google, Meta, TikTok and other social media platforms through the analytics and marketing services we use. You can find information about the providers we use on the website in the Cookie Tool. These parties process your personal data as independent controllers and share your personal data outside the EU/EEA. You can read more about how these companies transfer personal data in each company’s privacy policy.
- If you contact us via social media, your personal data is processed outside the EU/EEA, because it is processed by, among others, Meta when you have chosen to be active on Instagram or Facebook.
- If you receive our emails, your personal data is transferred outside the EU/EEA when we use our email service provider.
- To run our business, we use IT providers, which means that your personal data is transferred outside the EU/EEA, for example to the USA.
We have minimized the information that external parties have access to and have taken several measures to reduce the risks when your personal data is transferred outside the EU/EEA – all to make it as difficult as possible for anyone outside the EU/EEA to understand which personal data is concerned.
It is of the utmost importance to us that all transfers outside the EU/EEA take place in accordance with data protection legislation (the “GDPR”). When your personal data is transferred outside the EU/EEA, this takes place on the basis of a so-called adequacy decision by the European Commission under Article 45 of the GDPR. This means that the EU has assessed that a certain country provides adequate protection for your personal data. The arrangement between the EU and the USA is called the EU-US Data Privacy Framework. For example, Google and Meta are certified under the EU-US Data Privacy Framework. You can find their certifications here by searching for each company.
As mentioned above, some of the recipients we use transfer personal data to a country outside the EU/EEA that does not have an adequacy decision and/or where the recipient is not certified under, for example, the EU-US Data Privacy Framework. This applies, for example, when we use TikTok’s advertising services, which may mean that personal data is transferred to China. In most cases, such recipients will transfer your personal data on the basis of the European Commission’s Standard Contractual Clauses (Article 46.2(c) of the GDPR). You can find the Standard Contractual Clauses here. The Standard Contractual Clauses contain different modules depending on the roles of the party transferring and the party receiving the personal data. Module 3 (processor to processor) will most often be used, otherwise Module 1 (controller to controller) or Module 2 (controller to processor). If the legislation of the country outside the EU/EEA where the recipient operates affects how the Standard Contractual Clauses are intended to work, we and our providers will take additional safeguards to ensure adequate protection of your personal data.
If you would like to know more about the safeguards we implement when transferring your personal data, please contact us.
Legitimate interests
As stated above, we process some of your personal data on the basis of legitimate interests as the legal basis. This means that we have assessed that our legitimate interest in carrying out the processing outweighs your interests and fundamental rights not to have your personal data processed. Our legitimate interest in each case is set out in the sections above. If you would like to know more about how we made these assessments, please contact us.
Consent
In some situations we process your personal data after you have given your consent. These situations are described above, and you can withdraw your consent at any time. If you withdraw all or part of your consent, we will stop the processing for that purpose. Withdrawing your consent does not affect the lawfulness of any processing based on consent carried out before it was withdrawn.
Your rights when we process your personal data
Under the GDPR you have certain rights in relation to TPG’s processing of your personal data – see more information below.
If you have any questions about your rights or would like to exercise any of them, please contact us using the contact details above. The Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) also has more detailed information on when your rights apply and which exceptions there are.
Right to lodge a complaint – Article 77 GDPR
You have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your personal data infringes the GDPR. In Sweden, the competent supervisory authority is the Swedish Authority for Privacy Protection (IMY). If you live in Norway, you can also lodge a complaint with the Norwegian Data Protection Authority (Datatilsynet).
Right to withdraw consent – Article 7(3) GDPR
You have the right to withdraw your consent at any time by contacting us using the contact details above. If you choose to consent in our Cookie Tool on the website, you can always withdraw your consent directly on the website.
Right of access – Article 15 GDPR
You have the right to obtain confirmation of whether or not we process your personal data. You can submit a request by contacting us using the contact details above. If we process your personal data, you also have the right to receive a copy of the personal data we process, together with information about the processing, for example the purposes of the processing and how long the data is kept.
Right to object – Article 21 GDPR
You have the right to object at any time to your personal data being processed for direct marketing (including any profiling) and to processing of your personal data that is based on legitimate interests (including any profiling).
Right to rectification – Article 16 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 (“right to be forgotten”) – Article 17 GDPR
Under certain conditions you have the right to have your personal data erased by us without undue delay. For example, this applies 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 it was collected or processed.
Right to restriction of processing – Article 18 GDPR
Under certain conditions you have the right to require us to restrict our processing of your personal data. For example, this applies if you contest the accuracy of the personal data, or if the processing is unlawful and you oppose erasure of the personal data and instead request restriction of its use.
Right to data portability – Article 20 GDPR
If we process your personal data based on your consent or in order to perform a contract, you have the right to receive the 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 this personal data to another controller, where this is technically feasible.
Changes
We may make changes to this Privacy Policy to reflect changes in our business, on our website or in our services, or because of applicable law. The latest version of the Privacy Policy is always available on the website. In the event of relevant or material changes to this Privacy Policy, we will notify you of the changes we have made.
This Privacy Policy was adopted by TPG on 28 October 2026.

