We care about your personal integrity.

In this privacy policy we describe how your personal data is processed when you use our services, become a client and/or sign up to be a receiver of any of our newsletter and/or other communications. We also describe the rights that you have as a signed-up receiver of any of our newsletters.

Hilbert Group AB (”the Company”, ”we”, ”our” or ”us”) is an investment company specialising in digital assets. Within digital assets the company deals with asset management, proprietary trading, equity investments and data & analytics. We mainly process your personal data in order for you to use our services, to communicate and present offers as well as enhancing and develop our services.

The Company acts as controller in relation to the personal data processing described in this privacy policy. If you have any questions related to the processing you can direct those to the Company. You will find our contact information at the end of this privacy policy.

Aside from this privacy policy we may, in specific situations, provide complementary information relating to personal data processing to you. Any such information will apply in addition to what is stated in this privacy policy. We may also ask for your consent to carry out certain processing.

In order for us to provide our services to you, you need to submit the personal data described in this privacy policy. If not, we may not be able to provide our services to you.

1. When we process personal data

We process personal data mainly during the following situations:

  • When you use our
  • To communicate and provide product/service
  • To enhance and develop our services.

In the following we will describe how we process personal data during these situations as well as your rights according to the GDPR.

2. Our use of your personal data

A. When you use our services

We process your personal data when you use our services.

In the schedule below we state the categories of personal data that we process when you use our services, our purpose and the lawful basis applicable to the processing. You will find more specific information relating to other processing situations under sections B-C below.

Categories of personal data Purpose Lawful basis for processing
1. Contact- and identifying information E.g. name and e- mail address. To provide you with our services and to enable communication with you regarding your use of the services. The processing is necessary to enter into or to perform a contract with you.
2. Correspondence. E.g. your communication with us regarding your use of our services.
3. The personal data stated under sections 1-2 above. To protect us from or to make legal claims. E.g. if you were to have any legal claims directed at us, or if the opposites apply. If the processing is necessary in order to perform a contract (e.g. if we consider you to violate the agreement between us) we will rely on that as a legal basis. If such a claim were to be unrelated to the agreement we rely on a balancing of interest, where our legitimate interest is to enable us to protect us against legal claims or to make such claims.

How we collect the personal data

We collect the personal data stated in the schedule above from you. Where applicable, we may also collect and verify/validate any basic identity information from third parties.

If you have granted your consent in accordance with the above, we collect information from our collaborating partners Eklips.se.

Recipients of personal data

We will only share personal data with third parties to the extent necessary to provide our services, if you have asked us to, or in accordance with law.

The personal data is shared with Modular Finance in their capacity as processors.

The personal data is also shared with public authorities if required by law. If the Company or a part thereof where to merge with, or be acquired by, another company the personal data may be shared with such company.

Storage of personal data

The personal data is stored for as long as the client/user relationship prevails or up until such point the client/user withdraws their consent to the storage of their data, please refer to Section 1 below for further information related to our processing related to your consent. The personal data that we are required to process in accordance with law will be stored in compliance withsuch requirements. Personal data that is processed in order for us to establish, exercise or defend us against legal claims will be stored in accordance with any statutes of limitations.

Processing outside the EU/EEA

We strive to have all processing of personal data within the EU/EEA.

When we share your personal data with e.g., an IT-supplier who is active outside the EU/EEA, your personal data may be processed outside the EU/EEA. If and when your personal data is processed outside the EU/EEA we ensure that there is an adequate level of protection and that sufficient safeguards are taken (e.g. by way of the European Commission’s standard contractual clauses). The European Commission’s standard contractual clauses are available at their web site.

B. Communication and offers

We will process your personal data in order to inform you of the Company´s and, as applicable, our collaborating partners services. Your personal data is processed in order for you to receive relevant and customised communication and marketing.

In the schedule below you will see the categories of personal data that we process in order to communicate with you and present you with offers, the purposes for such processing and the applicable lawful basis.

Categories of personal data Purpose Lawful basis
1. Contact-         and        identifying Offers           and/or           personal Balance of interest. Our legitimate
information E.g., name, personal communication. E.g., in order to purpose is to send you relevant, and
identity number, phone number provide you with marketing (e.g., as         applicable,         customised
and e-mail address. newsletters)     and      any      other communication and/or marketing.
  customised marketing.  
2. Customer surveys. E.g., personal
data you   submit   to   surveys    
regarding our services.    

Something about communication by way of electronic marketing

As a user of our services, we may send you electronic marketing (e.g. by e-mail) and customised communication regarding our services. If you do not want such information, you can oppose such processing of personal data by choosing to unregister via the link in those communications.

If you do not wish to receive such customised communication, you can choose to not grant such consent or to revoke a given consent via the link in such communication.

How do we collect the personal data

Please refer to section A above.

Recipients of personal data

The personal data is shared with Modular Finance in their capacity as data processor and information distributor.

Storage of personal data

The personal data is stored in accordance with section A above. If you oppose the processing for direct marketing your personal data will no longer be used for such purpose.

Processing outside the EU/EEA

Please refer to section A above.

Profiling

While using the services we sometimes use your personal data for profiling purposes in order to enable us to send you customised communications and marketing. This means that we assess some of your personal characteristics by automated processing of your personal data, such as personal preferences and behaviour. This assessment is based on information you have provided. If you have any questions in relation to our profiling measures please do not hesitate to contact us.

C. Enhancing and developing our services

We will process your personal data in order to enhance and develop our services.

In the following we will state the personal data that we will process due to enhance and develop our services, the purposes for such processing and the applicable lawful basis.

Categories of personal data Purpose Lawful basis
1. Contact-        and        identifying Enhance and develop our services. Balance of interest. Our legitimate
information E.g., name, personal   purpose is to produce statistics in
identity number, phone number   order to   enhance   our   services,
and e-mail address.   develop   new    services    and    to
    understand user behaviour and the market.
2. Correspondence.       E.g.,     your communication with us regarding
your use of our services.    

How do we collect the personal data

Please refer to section A above.

Recipients of personal data

The personal data is shared with Modular Finance in their capacity as data processor and information distributor.

Storage of personal data

Please refer to section A above.

Processing outside the EU/EEA

Please refer to section A above.

1. Consent

In certain situations, we may ask for your consent in order to carry out a processing, as is described in section 2 above. We may ask for your consent to:

  • Sent customised communication and/or marketing, to the extent such communication contains profiling measures or is related to our collaborating partners services.

You may revoke a given consent at any time. A revocation does not affect the lawfulness of any processing carried out before the time of revocation. Due to a revocation, we will cease to process the personal data, if there is no other applicable lawful basis for said processing.

You can revoke a granted consent by contacting us at: privacy@hilbert.group

2. Security

We adhere to sufficient safety and security measures in order to safeguard your personal data from any unauthorised access, use, changes and distribution. To exemplify, any processing is carried out where there is present physical safety as well as IT-systems with sufficient IT-security.

In case of any processing carried out by other legal persons than us, but by our instructions, we ensure that these are bound by a proper data processing agreement. We also require that appropriate technical measures are taken in order to ensure the security and secrecy of the personal data, as well as compliance with applicable laws and regulations.

3. Your rights

As a registered person you have rights related to how the processing of your personal data may be carried out. For instance, you have the following rights:

  • Right to You are free to, at any time, obtain information regarding the categories of personal data that we as controller process about you.
  • Right to You may request a list of the personal data that we process about you.
  • Right to You may demand rectification of any inaccurate or incomplete personal data that we process regarding you.
  • Right to You may request that we erase your personal data. This right is applicable to the following situations:
    • The personal data is no longer necessary for the purposes they are collected for or in other ways processed.
    • You object to the processing and there are no overriding legitimate grounds for the
    • The personal data is processed
    • The personal data must be erased for compliance with a legal

In some situations, we may be prevented from immediate erasure of some of your personal data due to e.g., the establishing of, exercising of or defence against legal claims.

  • Right to restriction of the processing. You may request that the processing of certain personal data may only be carried out for specific purposes. This right is applicable in the following situations:
    • You contest the accuracy of the personal data and for a period enable us to verify the accuracy of the personal data.
    • The processing is unlawful, and you oppose the erasure of the personal
    • We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise, or defence of legal
    • Pending the verification whether our legitimate grounds override yours in the event you have objected to the
  • Right to object. You may object to our processing of any of your personal data. If you object, we may no longer process the objected personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
  • Right to object to direct You may object to direct marketing.
  • Right to data In some situations, you may request and receive your personal data to use elsewhere. This is only applicable to personal data that you yourself have provided us with and the processing is on the need to perform a contract with you and the processing is carried out by automated means.
  • Right to Please refer to Section 4.

You make request to exercise your rights at any time by contacting us at privacy@hilbert.group

4. Right to complain

If you consider our processing of your personal data to be in violation of the GDPR or applicable legislation you may submit a complaint to the Swedish Authority for Privacy Protection (IMY).

5. Contact information

If you have any questions or remarks regarding our processing of your personal data you may contact us at: privacy@hilbert.group

Hilbert Group AB

Company reg. no 559105-2948 Birger Jarlsgatan 2

P.O. Box 545 SE-114 11 Sweden

This privacy policy is updated from time to time. This privacy policy was last updated: July 2021.