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Bureau van Dijk Electronic Publishing AB, a Moody’s Corporation company of Brunnsgränd 7, 111 30 Stockholm, Sweden (“BVD Sweden”, “we”, “us”, or “our”) respects your privacy. This privacy notice explains how we process Personal Data collected from publicly available sources for regulatory compliance use cases.
“Personal Data” means information which identifies, or can be used to identify, a living individual.
BVD Sweden collates Personal Data from public sources for regulatory compliance use cases. Financial institutions and other entities (“End Clients”) with regulatory compliance requirements use the Personal Data to conduct regulatory screening of their customers or those with whom they are looking to do business, some of which are companies or other legal entities, and some are individuals or sole traders. End Clients use the Personal Data as part of their compliance with their legal and regulatory obligations including know-your-client (“KYC”), anti-money laundering (“AML”), and anti-bribery and corruption (“ABC”) obligations. We collect the Personal Data from public records. End Clients are responsible for ensuring that their use of the Personal Data complies with applicable laws and regulations. End Clients are responsible for how they use the results of a check performed using the Personal Data, for example, whether to do business with a customer. BVD Sweden does not make decisions on behalf of End Clients about individuals.
We collate the following types of Personal Data about politically exposed individuals and their family and close associates located in the Nordic region:
The Personal Data is limited to those necessary for the purposes. For example, without name and contact details, End Clients would be unable to look up individuals; without date of year of birth, it would be easy to mix up individuals with the same or similar names leading to cases of mistaken identity.
We do not obtain email addresses for individuals, and we rely on End Clients (who do hold contact details) to notify those individuals that they will run checks on them, if required under applicable law.
We source the Personal Data from public records, such as from the Swedish Tax Authority, the Swedish state personal address register (“SPAR”), the Swedish State Calendar, the Swedish Companies Registration Office (“Bolagsverket”), the Finnish Patent and Registration (“PRH”), the Finnish State Calendar, the Norweigan property owner register (“Grunnboken”), the Norwegian National Registry (“FREG”), the Norwegian company registry (“Brønnøysundregistrene”), the Danish Civil Registration System, the Danish Central Business Register, the Danish property owner register, and Krak’s “who is who*.
End Clients use the Personal Data to assist them with their legal, regulatory and compliance obligations in relation to KYC, AML and ABC.
We do not sell or otherwise disclose Personal Data we collect, except as described below or otherwise disclosed to you by us, End Clients, or the vendor or business partner that you represent, at the time the data is collected:
The Personal Data is stored for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure, and the applicable legal, regulatory, tax, accounting or other requirements.
You may also have the right to complain to your local data protection authority if you have concerns about how we process your Personal Data. However, we hope we can solve any queries or concerns you may have, so please contact us directly in the first instance.
The relevant legal bases for the use of your Personal Data are:
We have put in place measures to protect Personal Data which is transferred from the European Economic Area to the UK and the US. To transfer Personal Data outside of the EEA, BVD Sweden has put in place EU standard contractual clauses to ensure that an equivalent level of data protection applies. To request a copy of these clauses, please contact us as specified in the “Contact & Queries” section below. We may also transfer Personal Data to countries for which the EU Commission has issued an adequacy decision where applicable.
We take commercially reasonable steps to ensure that Personal Data is reliable, accurate, complete, and current for its intended purpose, primarily by accessing public records only.
If you have any questions or comments regarding BVD Sweden’s privacy practices you can do this via email at firstname.lastname@example.org or write to us at:
7 World Trade Center at 250 Greenwich Street
New York, NY 10007
Phone: +1-212-553-1653 or 1-866-995-9659
The most current version of this Privacy Notice will always be available here. You can check the “effective date” posted at the top to see when this Privacy Notice was last updated.