Privacy Policy

This policy (the “Privacy Policy”) constitutes a part of Accumeo AB’s (“Accumeo”) Terms of Use and pertains to the processing of personal data within the business. The Privacy Policy describes how Accumeo collects, processes, and protects your personal data. It applies from the moment it is published on Accumeo.com. Updates to the Privacy Policy will be published on Accumeo.com, and You will receive information via email in the event of significant changes to the Privacy Policy.

Personal data refers to information that directly or indirectly can identify a natural person but does not include information that has been anonymized or aggregated in such a way that it (even with the help of other information) cannot identify a specific natural person. The definitions stated in the Privacy Policy shall have the same meaning as in the Terms of Use unless otherwise indicated by the context.

Accumeo is the data controller and is therefore responsible for the processing of personal data carried out through the Platform and within the framework of the services provided under the Terms of Use, as well as ensuring that the processing is conducted in accordance with the principles outlined in the Privacy Policy.

When you register an account via Accumeo.com and accept the Terms of Use, you agree to share certain personal data with Accumeo and thereby consent to the information being transferred and stored on our servers in Sweden or in other countries inside or outside the EU/EEA.

2.1 Information provided by You

Accumeo collects and stores information provided in connection with registration on the Platform and information you provide when using the Platform, such as when completing a transaction or utilizing other services or tools that Accumeo provides or may provide in the future. The information includes, for example:

1. Information provided to Accumeo when registering as a member on the Platform, consisting of an email address, and in some cases, a telephone or mobile phone number, as well as first and last name.
2. In cases where a transaction is made through the Platform and personal identification number, financial information such as bank account number, and possibly your registered address are provided.
3. Information about your use of the Platform.
4. Information regarding whether payment for transactions has been made.
5. Information and/or correspondence sent to Accumeo, such as feedback or details provided to Accumeo’s customer service.
6. Documentation requested by Accumeo to fulfill its obligations regarding anti-money laundering and counter-terrorism financing. For example, you may need to confirm your registered address, verify your identity, and answer questions through Accumeo’s KYC form.

2.2 Information automatically collected by Accumeo

When you use the Platform, other services provided by Accumeo, click on links in newsletters from Accumeo, or on the Platform, information is automatically collected from your computer, mobile phone, or other device used to access the Platform. This information is only associated with the individual Investor if the Platform is used by a registered Investor. The information consists of connection details, page view statistics, IP address, traffic to and from the Platform, advertisement data, referring URL, and standard log information from web logs.

2.3 Information from third parties

Accumeo may obtain additional information about you from a third party, such as vendors or data providers, and add this information to Accumeo’s records about you. The information may include credit information, information from courts, and/or authorities. However, such information is collected only to the extent permitted by applicable law.

Accumeo processes your personal data with the purpose of providing you access to the Platform, managing daily business needs, for monitoring and analytical purposes, offering the opportunity to use Accumeo’s services and tools, providing customer service and relevant information from Accumeo, including transactions, as well as for marketing purposes. Accumeo may process personal data in connection with dividend payments to shareholders and reporting to the Swedish Tax Agency, in accordance with applicable tax legislation. The basis for Accumeo’s processing of your personal data is Accumeo’s legitimate interest, the fulfillment of the agreement constituted by the Terms of Use between Accumeo and You, and compliance with applicable laws and regulations.

By accepting Accumeo’s Terms of Use and thereby the Privacy Policy, you consent to Accumeo processing your personal data for the following purposes:

1. Providing You access to the Platform and offering customer service, information about Your account, enabling the execution of transactions, and granting access to the tools and services that Accumeo may offer at any given time.
2. Sending information about content on the Platform, relevant information regarding previous transactions, informing about updates to the Platform, the Terms of Use, the Privacy Policy, or Accumeo’s services.
3. Administering, providing, developing, and ensuring the technical functionality of the Platform to offer you a secure and efficient experience of the Platform and its associated services.
4. Monitoring that the Platform is not used in violation of the Terms of Use and safeguarding Accumeo’s or others’ rights according to the Terms of Use, for example, to prevent, detect, and investigate security incidents, potentially prohibited, or otherwise illegal activities.
5. Using cookies or other tracking technologies to provide the services and/or collaborating with third parties such as advertising or analytics companies to provide the services.
6. Marketing Accumeo’s products and services or products from selected Accumeo partners via email or other means.
7. Compiling statistics, conducting market and customer analyses, as well as general business and methodology development.
8. Enabling financing or transfer of all or parts of Accumeo or its business.
9. Conducting checks against the EU sanctions lists, UN sanctions lists, and PEP lists, among others, as well as fulfilling other obligations arising from laws, regulations, or internal policies.

If you do not wish to receive communication from Accumeo, you can contact Accumeo at info@accumeo.com and object to the processing. If you withdraw your consent to the processing of personal data or the disclosure of information for the purposes specified in the Privacy Policy, this may result in Accumeo being unable to provide you access to the Platform, the services, or the customer support that Accumeo offers under this Privacy Policy and the Terms of Use.

Accumeo does not sell or disclose your personal data to third parties for marketing purposes (beyond what is stated in section 3 above) without your explicit consent. Accumeo discloses your personal data to fulfill legal obligations and maintain adopted policies. Your personal data will only be disclosed in accordance with applicable laws and regulations.

To fulfill obligations under the Terms of Use and for the purposes outlined in section 3 above, Accumeo may share your personal data with:

1. Any future affiliated companies of Accumeo for the provision of shared content and services, to detect and prevent violations of Accumeo’s policies, to provide guidance on affiliated companies’ products, websites, tools, or services, and in accordance with applicable law.
2. Subcontractors used by Accumeo to operate the business, including but not limited to IT providers, cloud service providers, any loan agent representing You in a transaction, payment institutions or other companies handling incoming and outgoing payments related to transactions, dispatching status updates on ongoing transactions or other communications sent to You, and for the operation of the Platform.
3. Regulatory authorities, law enforcement agencies, other authorities, or authorized third parties, to respond to inquiries related to criminal investigations or other activities that may impose liability on Accumeo or you. To the extent permitted by applicable law, Accumeo will disclose information that is relevant and necessary for any investigation, such as name, personal identification number, email address, and IP address.
4. Information about Investors to other investors or a potential acquiring company in the event that Accumeo is to be sold or merged with such a company.

If your personal data is to be used or disclosed for purposes other than those stated in the Privacy Policy, Accumeo will inform you accordingly.

When you visit or use the Platform and/or other tools or services, such as email, Accumeo and its providers may use cookies, web beacons, and similar technologies to store information to create a faster and more secure experience for you.

Your password is the key to your account and should consist of unique numbers, letters, and symbols. You must not disclose your password to any third party. You are responsible for all activity that occurs through your account and must immediately inform Accumeo if Your password has been compromised for any reason.

You can review and modify certain personal data in the account settings on the Platform and must immediately update or notify Accumeo’s customer service if your personal data changes or is incorrect. Accumeo will fulfill your legal rights regarding the ability to request correction or deletion of your personal data.

Accumeo stores and processes your personal data on Accumeo’s servers in Sweden and in other countries within or outside the EEA. Accumeo undertakes to provide appropriate protection for your personal data when information is transferred to a location outside the EEA. You acknowledge that your personal data may be processed and transferred to a country outside the EEA.

Accumeo employs physical, technical, and organizational security measures, based on the volume and sensitivity of the personal data processed, to prevent unauthorized processing, including but not limited to unauthorized access, acquisition, and use of, or loss, deletion, or other damage to your personal data. Examples of security measures used by Accumeo include encryption and anonymization of data, firewalls, and access controls for personal data.

At your request, Accumeo will close your account and delete your personal data as soon as possible. Data deletion will be carried out in accordance with applicable law. Accumeo may also shut down accounts that are used in violation of the Terms of Use.

Personal data associated with closed accounts will generally be deleted or anonymized after the account has been closed. However, Accumeo may retain personal data related to closed or inactive accounts in the following situations:

1. Accumeo has a legitimate business interest and it is not prohibited by law.
2. To handle a dispute and/or ensure that Accumeo’s Terms of Use are upheld.
3. When Accumeo is legally required to retain personal data, such as for compliance with anti-money laundering regulations.
4. To take other actions permitted by law.

Regardless of the circumstances concerning your personal data, the data will be handled securely and only for as long as necessary to fulfill one of the purposes outlined in the Privacy Policy.

You have the right to obtain detailed information about which personal data Accumeo processes about you by requesting a register extract. The request must be made in writing, and no compensation shall be provided to Accumeo. You also have the right to request correction or blocking of incorrect personal data or that personal data about you be deleted. Additionally, you have the right to request your personal data in a structured and machine-readable format to transfer the data to another data controller. You have the right to object to the use of your personal data for direct marketing, and you can withdraw your consent by contacting Accumeo at info@accumeo.com.

If you wish to exercise any of these rights, you should contact Accumeo at info@accumeo.com and provide your full name and the email address used during registration. When a piece of information is changed or deleted, you will be informed of the change within one month. Data that cannot be deleted will be pseudonymized.

If you have any questions or would like to learn more about the personal data we process about you, you can contact us at: info@accumeo.com.