Privacy Policy

The purpose of this document (hereinafter “Privacy Policy”) is to inform Users with regard to personal data, considered as any information that allows the identification of a natural person (hereinafter “Personal Data”), collected from the website www.lagalene.com (hereinafter, the Application).

The Data Controller, as identified below, may amend or simply update, wholly or in part, this Privacy Policy informing the Users about the changes. The amendments or updates shall be binding as soon as they are published on the Application. Therefore, the User is invited to read the Privacy Policy at every access to the Application.

If the User does not accept any amendments to the Privacy Policy, the User must terminate the use of the Application and he may ask the Data Controller to remove his Personal Data.

1. Personal Data collected by the Application

The Data Controller shall collect the following categories of Personal Data:

  1.  Voluntary contents and information provided by the User
    •  Contact information and contents: Personal Data that the User voluntarily provides to the Application during use, such as personal details, contact information, login credentials to services and / or products provided, interests and preferences, personal interests and preferences and any other personal contents, etc.

If the User does not communicate Personal Data, for which there is a legal or contractual obligation, will be impossibile to the Data Controller to provide, in whole or in part, its services. It will be impossible also in case that Personal Data is necessary requirement for the use of the service or for the contract conclusion.

The User who communicates to the Data Controller third parties Personal Data, is directly and exclusively liable for their origin, collection, processing, communication or disclosure.

  •  Data and contents automatically acquired while using the Application
    •  Technical Data: the computer system and the software procedures functional to this Application may acquire, in the course of their ordinary activity, any Personal Data whose communication is implicit in the use of internet communication protocols. Such information is not collected to be associated with identified Users, however, those Data, due to its nature, may identify Users in the Processing and through the association with Data held by third parties. This category includes IP addresses or domain names used by Users who connect to the Application, addresses of Uniform Resource Identifier (URI) of the requested resources, time of the request, method used submitting the request to the server, size of the file obtained, etc.
    •  Usage Data: Personal Data may be collected relating to the use of the Application by the User, such as the pages visited, the actions performed, the features and services used by the User.
    •  Personal Data collected through cookies or similar technologies

Application uses cookies, web beacons, unique identifiers and any other similar technologies to collect Personal Data regarding pages, visited links and other actions, performed while using our Services. They are stored for being communicated back to the same websites at the next visit of the User.

The User may read the complete Cookie Policy at the following address: www.lagalene.com/cookiepolicy.

2 Purposes of the processing

 Collected Personal Data may be used for the performance of contractual and pre-contractual obligations and legal obligations as well as for the following purposes:

  •  EXTERNAL management of payments via credit card, bank transfer or other means: to manage Users’ payments through external platforms that collect payment data without allowing the owner of the Application to access it.

Personal Data is communicated to Paypal

  •  Remarketing and behavioural targeting: to show advertisements which are more relevant to the User on the basis of his browsing behaviour and his preferences.

Personal Data is communicated to Facebook, Google

  •  Transfer of data to third parties for marketing purposes: to sell Users’ data to third-parties for marketing purposes’ autonomous treatment.

Personal Data is communicated to SDA

3. Personal Data processing methods

The Processing of Personal Data is performed with paper, IT and/or digital tools, with methods of organizations and with logics strictly related to the indicated purposes.

In certain cases, subjects other than the Data Controller who are involved in the organization of the Data Controller (such as personnel management, sales personnel, system administrators employees, etc.) or who are not (as IT companies, service providers, postal couriers, hosting providers, etc.) may access to Personal Data. These subjects, will be appointed, where necessary, as Data Processors by the Data Controller and will have access to Users Personal Data whenever required, and shall be contractually obliged to keep it confidential.

The updated list of Data Processors may be requested via email at the email address support@lagalene.com.

4. Legal basis for the processing

 User’s Personal Data is processed on the following legal basis:

  1. user’s consent for one or more specific purposes
  2. processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures
  3. processing is necessary to comply with a legal obligation to which the Data Controller is subject
  4. processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Data Controller
  5. processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by a third party
  6. processing is necessary for the purposes of the vital interest pursued by the Data Controller or by a third party

It is always possible to ask the Data Controller to clarify the legal basis of each processing at the following mailing address support@lagalene.com.

5. Place

Personal Data are processed in the operative offices of the Data Controller and in any other place in which the parties involved in the Data processing are located. For further information, you may contact the Data Controller at the following email address support@lagalene.com or at the following mailing address Italian Lifestyle srl, viale Lombardia 9, 20131 Milan, Italy .

6. Security of processing

The Data Processing is performed through adequate methods and tools to ensure the Personal Data security and confidentiality, as the Data Controller has implemented appropriate technical and organizational measures which guarantee, in a provable way, that the Processing complies with the applicable law.

7. Period of storage of Data

Personal Data will be stored for the time necessary to perform the purposes for which they have been collected.

In particular, Personal Data will be stored for the whole duration of the agreement, to fulfil the inherent and consequent obligations, for the compliance with law provisions and for defensive purposes.

When the Processing of Personal Data is based on the User consent, the Data Controller may store Personal Data until the withdrawal of such consent.

Personal Data may be stored for a longer period of time in order to perform a legal obligation or public Authority order.

All Personal Data shall be deleted or stored in a form that shall not allow the identification of the User within 30 days from the end of the storage period. At the expiration of such period, the right to access, rectify, erase and of portability of Personal Data can not be exercised.

8. Automated individual decision-making

All collected Data shall not be subject to automated individual decision-making, including profiling, which may produce legal effects concerning the User or may significantly affect the User.

9. Rights of the User

The Users may exercise specific rights with respect to Personal Data processed by the Data Controller. In particular, the User has the right to:

  1. withdraw its consent at any time;
  2. object the Processing of its Data;
  3. access its Data;
  4. monitor and request the rectification of Data;
  5. obtain a restriction of Processing;
  6. obtain the erasure or remotion of its Personal Data;
  7. receive its Data or obtain the transfer to a different Data Controller;
  8. lodge a complaint before the supervisory authority for the protection of personal data or start legal proceedings.

In order to exercise their rights, the Users may send a request to the contact information of the Data Controller indicated in this document. These requests are free of charge and performed by the Data Controller in the shortest possible time, in any case no later than 30 days.

  1. Data Controller

 The Data Controller is Italian Lifestyle srl, with registered office in viale Lombardia 9, 20131 Milan, Italy, Tax Code/VAT Code it10068080968, e-mail support@lagalene.com.

Latest update: 28/10/2019

Klarna Privacy Policy

At Klarna, we care about your privacy. We therefore collect and process personal information responsibly and with your privacy in mind. This Privacy Notice describes how Klarna Bank AB (publ) (“Klarna”) collects and uses your personal data when you use any of Klarna’s services (the “Service” or collectively, the “Services”) and become a customer. . Examples of our Services are when you make payments with one of our payment options, when you contact us, when you use the Klarna web portal and mobile application (the “Klarna Apps”) or when your personal data is automatically entered at at checkout. Furthermore, this Privacy Notice describes your rights regarding the processing of personal data and how to exercise them.

It is important that you read and understand the content of this Privacy Notice which applies to all personal data that Klarna processes, except as provided in Section 1.

Some of our Services will provide you with access to content and functionality offered by other companies or organizations other than Klarna (“Third Party Services”). This happens, for example, when connecting to third party sites from our websites, when accessing third party sites while using the web browser in the Klarna App. This Privacy Policy does not apply to the collection and use of the user’s personal data in third party services, and Klarna is not responsible for the processing of your personal data by such third parties.

“We”, “our” or any other reference “to us” means Klarna Bank AB (publ) a company registered in the Swedish Commercial Register under number 556737-0431 and headquartered at Sveavägen 46, 111 34 Stockholm (Sweden). For the purposes of European legislation on the protection of personal data, we act as the data controller of the personal data received from users, or otherwise concerning users and collected by us and we are responsible for the use of user data in accordance with applicable laws regarding data protection.

  1. More information about Klarna’s privacy
    The processing of your personal data by Klarna Ident and Klarna Open Banking in the execution of the Services takes place in compliance with the provisions of the privacy policies relating to those services, which are presented to you when you use them. Those separate disclosures apply in lieu of the information given here. Other specific privacy notices may be provided for selected campaigns or offers available for a limited time, and will in these cases be presented together with them.

If you are a Klarna employee or have applied to work with us, or are employed at a store we cooperate with, Klarna’s processing of your personal data is subject to other privacy notices and you will be provided with relevant information depending on of the relationship that binds you to Klarna. Contact us using the information in Section 13 below if you would like a copy of the relevant privacy statement about you.

  1. What data do we use?
    2.1 The personal data you provide

The user can provide us with information about him when using a Klarna Service, such as when choosing a payment method from those offered by Klarna, when contacting us or using the Klarna App. Therefore, the user is invited to remember that in order to provide the Services correctly, it is necessary to provide their personal data.

Depending on the Services chosen, the following personal data may be processed:

Identification data and contact details – name, date of birth, social security number, educational qualification, billing and shipping address, e-mail address, mobile number, nationality, salary, audio recordings, photos and video recordings of you and yours identity card etc.

Payment data – credit or debit card data (card number, expiration date and CVV code), current account number etc.

Particular categories of data – the user can, at his complete discretion, provide us with information concerning him constituting “particular categories” of personal data pursuant to EU Regulation 2016/679 (“GDPR”), of which, for example, they are part data relating to religious beliefs, political opinions or philosophical beliefs, trade union membership, data relating to health, biometric data or to the person’s sex life or sexual orientation. The user will never be asked to communicate this type of personal data in order to access our Services. This category of personal data may only be provided to us on a strictly voluntary basis and with the explicit consent of the user. Please refer to paragraph 5 for information on how to withdraw consent.

The user can change their profile information as well as contact details and other editable settings at any time, using the Klarna App or by contacting us.

2.2. Your personal data collected by Klarna

Depending on the Service you choose to use, Klarna may collect the following information about you, either directly or through third parties (such as credit rating or fraud prevention agencies, agencies and databases of public consultation):

Identification data and contact details – name, date of birth, social security number, educational qualification, occupation, gender, billing and shipping address, e-mail address, mobile number, nationality, etc.

Information on goods and / or services – data concerning goods or services purchased or ordered by the user, including, for example, the types of goods or the identification numbers of the shipment.

Financial Information – Financial information collected from third parties regarding income, any loans, negative payment reports, a previous payment or credit acceptance.

Information regarding the interaction between the user and Klarna – the way in which the user uses the Services, including data regarding outstanding debts and the history of debts as well as the history of Klarna’s repayments; technical data such as page response times, download errors, personal preferences; customer interaction with Klarna’s customer care service etc.

Recorded telephone conversations – we record telephone conversations made by the user to customer service.

Information regarding the interaction between the user and the shops – the user’s relationship with the shop where he purchases, such as information regarding the receipt of the goods and the type of shop.

Device information – such as IP address, language settings, browser, time zone, operating system and platform and screen resolution. Please refer to paragraph 11 below for more information on how we collect data from the user’s device or store it on the same.

Information from external lists relating to sanctions and politically exposed persons (PPE) – we can analyze user data by comparing them with those in the lists of persons subject to sanctions and the so-called “Politically Exposed Persons” (PPE). These lists contain information such as name, date of birth, place of birth, occupation or position and reason for inclusion in those lists.

Specific information on the Services: to provide the user with some of our Services, we may collect and process additional personal data not covered by the above categories. Please refer to Section 4 for additional personal data processed for the relevant Service.

  1. Type, purpose and legitimacy of the processing of personal data
    Depending on the Services used, Klarna may process personal data for the purposes listed below, on the legal basis indicated for each purpose. Please refer to Section 4 below for more information on how we process user data in our Services.
  1. Processing of specific personal data for certain Services
    This paragraph indicates the processing operations of the user’s personal data carried out specifically for certain Services. Please refer to the terms and conditions of the relevant Service for further information regarding our Services and their characteristics.

4.1 Klarna’s Credit Services

The following Services have as their object the provision of credit in favor of the user: Deferred payment (invoice), Immediate payment (in the case of direct debit), Financing, the Klarna card and the disposable card (both available in the ‘Klarna app). For the purpose of providing these Services, we carry out an assessment of the user’s creditworthiness, based on the identification data and contact details provided by the user, information regarding the interaction between the user / customer and Klarna and financial information. Financial information includes information obtained externally from credit rating agencies, such as income and payment reports. Please refer to paragraph 7 for more information on our creditworthiness treatment.

The Klarna Card and the disposable card

When the user applies for the Klarna card and the disposable card (available in the Klarna App), Klarna conducts a credit assessment of the user / customer in the same way as it does with respect to other credit. If the customer owns the Klarna Card, the customer’s creditworthiness assessment is constantly updated, and is based on the customer’s interaction with Klarna.

We share data regarding the user and his purchases when the user uses the Klarna Card with VISA and with the members of the VISA circuit, as necessary to carry out transactions with the card, prevent fraud and follow the applicable rules. If the user renews the Klarna card or receives a new one, we transfer this information to VISA so that VISA informs third parties where the user has stored his card data (for example in the case of recurring transactions).

In addition, in the event that the user adds the Klarna Card to the e-wallet, we may need to share the user’s data with the e-wallet service provider as described in the privacy policy of that provider.

4.2 The user clicks on one of our promotions or event announcements published by third parties on social media

If you click on one of our promotions or event announcements posted by third parties on social media, we may receive the contact details about you provided in connection with your profile used on that social media (such as name, email address and telephone number and any other relevant commercial information such as company name, address and business sector).

4.3 Klarna accounts (savings and payment accounts)

If you have an account with Klarna, Klarna will also process your transaction and fund data. If the user transacts or makes payments to other accounts, Klarna will pass the user’s name and account number to the recipient and to the recipient’s financial institution.

In addition, if the user has made payments to a Klarna account, Klarna will process the data received from the bank that the user used for the transaction including the user’s name and account number.

4.4 The user experience offered by Klarna under the Terms of Services
In order to offer the user an easy shopping experience, before and after it, Klarna offers the services described below, which are also described in greater detail in the Klarna Terms of Services. The use of these Services involves the processing of the user’s personal data as indicated below:

Operations history

We save information relating to goods and services purchased by the user through our Services, or those that we have been allowed to access otherwise, in order to show them to the user.

Automatic filling of information

The automatic filling of user contact information can be done in two ways: through user interaction and / or through cookies.

Automatic filling through user interactions

When the user uses the Services, we may ask for the user’s identification data and contact details, such as name, address, telephone number, e-mail address, date of birth and / or identity card number. We will keep this information in our systems and, on his return, the user will only have to provide some contact details such as telephone number, e-mail, zip code or identity document (depending on the country) in order to allow us to fill in automatic the remaining fields with the additional data.

Automatic filling through cookies

A further method of automatic data filling takes place through the installation of a Klarna cookie on the user’s device (computer, tablet, mobile phone) which allows the user to decide to save their data such as name, address, number of phone, email, date of birth, identity card number and card details on the Klarna platform. In this case, we will use cookies to import the data already stored by Klarna when the user uses our services with the same device. Later, we will automatically fill in the data when the user interacts with Klarna.

Disabling the automatic fill function

If the user does not want to use the autofill function, he can contact us to disable this setting. The user can also change their settings directly through the Klarna App or in the purchase process at a store. Finally, the user can delete the cookies from their device thus also eliminating ours.

Pre-selected preferred payment methods

Klarna can establish the user’s preferred payment method for purchases, and pre-select it for him. This procedure, however, does not affect the payment methods available to the user. To this end, Klarna processes the data of the interactions between the user and Klarna, such as data regarding the payment methods chosen in the past, the purchase, the amounts and the shop. This data processing constitutes a profiling activity. Please refer to paragraph 6 for further information on profiling.

Offers and benefits

In order to offer users offers and benefits such as discounts, special events, product pre-sales, promotions, commercial offers, samples, giveaways, etc., we take into consideration information relating to the interactions between the user and Klarna (such as the number of purchases in a certain period of time) and the data to contact and identify the user. These are activities that may involve profiling activity. Please refer to paragraph 6 for further information on profiling.

This data will form the basis for Klarna’s marketing and customer analysis, for the development of business and business processes, as well as for statistical purposes.

As part of the offers and benefits program, Klarna, its suppliers and subcontractors (on behalf of Klarna) may use this data for the communication of offers and benefits to the user via postal mail, SMS, e-mail, social media and other digital channels. Klarna and their respective suppliers and subcontractors will not use any direct marketing channel for this purpose (e.g. email or text messages) if the user has opted out to receive direct marketing actions (or if the user has not expressed the opt-in if the same is required by national legislation).

To express the opt-out to receive offers and benefits, the user can cancel through the link indicated in the e-mails sent by Klarna or by contacting Klarna (see paragraph 13).

The Klarna App

If the user uses the Klarna App, some additional personal data will be processed (for example, the information uploaded by the user based on his consent) in order to guarantee the provision of the Services he decides to use within the App, as shown below. In addition, when the user chooses to redeem the rewards or participate in specific offers, the provider of these offers may deduct the use of Klarna’s services by the user. The personalization of content constitutes a profiling of user data, an integral part of the Klarna App for assistance with online purchases; for more information see Section 6.

Articles and personalized advertisements: the user will be able to see articles and personalized advertisements based on previous purchases, contact details and identification data, data on goods or services, data relating to the interaction between the user and Klarna, data relating to the interaction between the user and the stores, to data concerning the device and to specific data relating to the service.

Sponsored Links: If the user clicks on a sponsored link promoting a store, product or service, the user will be redirected to the store’s website through a third party, a so-called “affiliate network” (for further explanation please see paragraph 7.14). The affiliate network could place a tracking technology on the user’s device containing the data relating to the user’s click of the sponsored link in the Klarna App and which is then used to track the user’s visit to a store in order to to calculate a potential commission to Klarna.
Klarna personalized overview: you can view the overview for consulting the status of purchases made with Klarna and their history, access any refunds and pay or extend the payment terms.

Personalized shopping collections: If you have shared with Klarna information, topics, products and services that interest you in general, Klarna will use this information to provide you with personalized shopping collections, where you can find customized products and services tailored to your needs. interests.
Shipping and parcel tracking: in some cases, the user can trace the path of shipments.

Ability to “follow” the shops: if the user decides to “follow” a shop, he receives information on offers related to that shop. Klarna will automatically evaluate whether those purchases guarantee access to discounts or other offers under the current offer.

Credit Services: We may offer credit to users based on previous purchases.

Shopping with a disposable card: shopping through the Klarna App is one of the ways to use Klarna’s payment methods in almost all stores through a disposable card. When the user uses the disposable card, Klarna collects information regarding purchases and shows them to the user on the App.
Customer support: when the support service is contacted through or in connection with the Klarna App, we will have access to the information provided by the user.

Email Connect: If you have connected your email account to the Klarna Email Connect service, Klarna will regularly access your email account to extract other information related to the goods and services and the interaction between you and the stores, to upload such information to the Klarna App. The user can deactivate the service at any time by removing Klarna’s access.

Find the store: the user can decide to share their location with Klarna, in which case they will allow them to use this information to show nearby stores. The user can revoke their consent by deactivating sharing on their device. Klarna will not keep the user’s location after showing them the shops.

The in-app web browser: The Klarna App contains a web browser in which you can access store websites and online stores and then shop with Klarna payment methods even with stores that do not yet use our methods of payment. Klarna collects information on the use of the browser by the user in order to provide relevant offers. In addition, the websites visited by the user can set their own cookies and other tracking technologies on their device.

Visual search: the user can choose to upload product photos, either by taking a photo of the product or by choosing a photo from the library of their phone, and Klarna will try to find products similar to those uploaded to show the user.

Wish List: the user can choose to add products and services in the Klarna App to their Wish List, to be able to find them later, or keep track of their prices. He can also share his Wish List with other people, such as friends and family, who will then be able to see his profile photo and username. In some cases, if you are logged in to a store’s website, the link to a product or service that you have chosen to add to your Wish List may include personal information such as your e-mail address.

Connected bank accounts (the Personal Finance Service): Using this service will allow the user to get an overview of their finances, including not only their transactions with Klarna, but also with their connected bank accounts. When you choose to use this Service, Klarna will process information regarding the external account and other accounts (such as card accounts) that you choose to connect, and will collect personal data such as account number, bank, transaction history, account, funds and available goods. Based on this data, Klarna will display and provide the user with the tools to control his finances through offers designed on his specific situation (based on profiling, as explained in paragraph 6). This is accomplished by comparing the expenses with those of other users of the Service. Based on this comparison, Klarna, together with its partners, can offer ways to minimize fixed and non-fixed costs.

Profile picture: the user can choose to upload a profile photo to the Klarna App, in which case he gives his consent for the picture to be shown in various Klarna interfaces (such as in the Klarna checkout in a store, or in the Klarna App). Klarna interfaces can also be installed in store apps. The photo could also be shown to others if the user shares his device with others (with the use of automatic filling through cookies), or if he chooses to share the content of his Klarna App with others. The user can withdraw his consent at any time in compliance with paragraph 5, and Klarna will therefore delete the image.

  1. Withdrawal of consent
    In cases where Klarna processes the user’s personal data on the basis of consent, even explicit (for example if a power of attorney is presented that allows another person to access your data, or in the case of a declaration of vulnerability of the customer or in case of uploading of particular data in our Services), the user can revoke the consent at any time by contacting us or deleting their data uploaded in the Klarna App. The withdrawal of consent will not harm the user as these data are not required for the purpose of providing the Services.
  2. Profiling and automated decision making
    “Profiling” consists in the automated processing of personal data aimed at examining certain personal characteristics of the user, such as aspects of his financial situation or his preferences, such as purchase preferences. We use the profiling of users’ personal data that we have in order to make individual or automated decisions regarding the user for the purposes indicated below.

Decisions without legal effect or of similar significance

Klarna makes the following decisions without legal effects or of similar significance for the user:

predict commercial content potentially of interest. The user can always oppose this type of commercial proposal and unsubscribe from marketing or profiling by contacting us. Please refer to paragraph 3 for further information on the processing of personal data for marketing purposes;

decide which loyalty rewards best suit the user. Please refer to paragraph 4.4 “Offers and benefits” for further information;

decide the most appropriate way to inform the user about his outstanding debt position. Please refer to paragraph 3 for further information;

select the content to be displayed to users in the Klarna App. Please refer to paragraph 4.4 “The Klarna App” for further information;

select the order in which the different payment methods should be presented to the user at the in-store checkout.

In addition, some of our Services (such as connecting bank accounts and other similar accounts with the Klarna App), use profiling in order to be able to provide the applicable Service to the user, such as for example communicating relevant financial information to the user or a range of offers, in accordance with the terms of the Service.

Decisions having legal effect or of similar significance

Automated decision-making having legal effect or automated decisions with similar relevance means that some decisions in our Services are based solely on automatic means, without any interaction from our employees and have a significant impact on the user as a consumer. Through automated decisions, objectivity and transparency in the decisions in the offer of those Services are increased.

We use this type of automated decision making when:

we decide to approve the user’s request to use a credit service;

we decide not to approve the user’s request to use a credit service;

we decide whether the user is engaging in behavior involving a risk of fraud or money laundering, if our processing operations reveal that the user’s behavior is attributable to money laundering or fraudulent behavior, or that the behavior of the ‘user is inconsistent with previous uses of the Service or in the event of a suspected and deliberate misrepresentation of their identity. If applicable, Klarna also checks whether a particular customer is on a so-called anti-money laundering list or not.

Please refer to paragraph 3 for further information on the type of data processed for these purposes.

The user always has the right to contest an automated decision that has legal or similar effects (together with the related profiling) by contacting us through the e-mail address referred to in paragraph 13. A Klarna employee will then deal with the case .

  1. Disclosure of User Information
    We may need to share users’ personal data with the categories of recipients listed below for the purposes listed below. The recipients and the purposes for which the data are communicated depend on the Services used by the users. When we share your personal data, we take all reasonable contractual, legal, technical and organizational measures to ensure that the user’s personal data are treated with an adequate level of protection and in compliance with applicable law.

7.1 Suppliers and subcontractors

Klarna may share your personal data with the suppliers and subcontractors it uses to provide the Services. Suppliers and subcontractors are companies authorized to process data received from Klarna or on behalf of Klarna. By way of example, this category includes software and data retention service providers, payment processing service providers and business consultants.

7.2 Shops

Klarna shares personal data with the stores visited by the user or from which the user makes purchases (which could include companies in the store group, if the user has been informed by the store). This is done to allow the shop to execute and manage the purchase and administer the relationship with the shop or its group, for example by verifying the identity of the customer, sending the goods, managing queries and disputes, sending relevant offers and fraud prevention. Personal data shared with a store will be subject to the privacy policies.

7.3 Payment Service Providers (“FSP”) and Financial Institutions

FSPs provide stores and Klarna with services for accepting and handling electronic payments through a variety of payment methods, including credit cards, and payments by direct bank debit, wire transfer etc. Some stores use FSPs with which they share user data for payment processing. Sharing is carried out in compliance with the privacy policies of the shops. Stores may also, for the processing and administration of payments, require us to share user information with FSPs. Some FSPs collect and use user data independently, in accordance with their respective privacy policies. This is the case, for example, when using an e-wallet.

Additionally, in order to execute transactions, Klarna may share your data with other financial institutions when you transact with your account.

7.4 Credit rating agencies

If you request to use a credit service (refer to paragraph 4.1 for the specification of the relevant credit services), the user’s personal data may be shared with credit rating agencies (“ARC”). evaluate your credit score in relation to the credit request, to confirm the user’s identity and contact details and to protect the user and other customers from fraud. Such sharing constitutes a credit check.

In Italy, Klarna sends your address, date of birth and social security number to the credit rating agencies in order to have your profile verified.

Our checks affect the credit rating agencies’ assessment of your credit profile. In addition, Klarna shares information about your repayments (including late repayments and uncontested missed payments) with credit rating agencies, and such data may be included in the credit default files, which may also influence the assessment. carried out by credit rating agencies, and be consulted by third parties. Credit rating agencies process your data in accordance with their own privacy policies; below you can find a list of credit rating agencies we cooperate with.

The user’s attention is drawn to the fact that Klarna only keeps the creditworthiness assessment received from an ARC in the data script format. We therefore recommend that you request a copy of the evaluation directly from the ARC if you wish to view it legibly.

7.5 Fraud Prevention and Identity Verification Agencies

The user’s personal data may be shared with fraud prevention agencies and for identity verification for the purpose of verifying the user’s identity, the accuracy of the data provided and the prevention of criminal activities. The agencies we cooperate with in Italy are listed here. The user’s attention is drawn to the fact that these companies process data in accordance with their own privacy policies.

7.6 Klarna Group Companies

User data may be shared with other Klarna group companies, based on Klarna’s legitimate interest in conducting its business.

7.7 Social media companies

If the user contacts us through social media such as Facebook or Twitter, his data will be recorded and processed by these companies in parallel with us, in accordance with the respective applicable privacy policies.

7.8 Subject holding power of attorney provided by the user

Klarna will share the user’s data on the basis of the consent given, if it has received a power of attorney from the user in favor of a third party. This sharing will be carried out on the basis of the user’s consent.

7.9 Google

When the user uses Google Maps in the checkout (for example, by searching for the user’s address in the appropriate search section) or the Klarna App, Google will process the user’s information subject to the terms of service and policy on Google Maps / Google Earth privacy. Furthermore, when the user uses the Klarna App through a browser, Google collects information on his device through the reCAPTCHA service implemented therein, sometimes in combination with any information entered in the reCAPTCHA service. Google will process this information in accordance with its privacy policy. Klarna processes this data on the basis of its legitimate interest in carrying out its business, since the reCAPTCHA service prevents the misuse of its Services.

7.10 Authority

Klarna may communicate the necessary data to police, tax or other authorities if required by law or by the user in certain circumstances or if necessary to manage tax deductions. By way of example, communications required by law are those relating to anti-money laundering or terrorist financing prevention obligations.

7.11 Logistics and transport company

Klarna may share the user’s personal data with logistics and transport companies for the delivery of goods or if the user has expressed the choice to track / monitor the shipment. By way of example, we may share contact details and identification data and the shipping number. Please note that logistics and transport companies will process the data in accordance with their own privacy policies.

7.12 Partners in the Personal Finance Service and in the Offers and Benefits program

If you choose to participate in offers and benefits that Klarna provides in the Personal Finance Service or through the Offers and Benefits Program, Klarna may share personal data necessary to allow you to access offers made in cooperation with our partners (this includes the fact that you are a customer of Klarna). Information on what data is shared is provided with each offer.

7.13 Debt Collection Agencies and Other Pending Credit Buyers

Klarna will be able to share user data in the event of the transfer of outstanding credits to third parties or of assignment for the collection of such credits, for example to debt collection agencies. This sharing of personal data is carried out on the basis of our legitimate interest in carrying out the credit collection and assignment activity. Debt collection agencies or any other purchaser may process the user’s personal data in accordance with their own privacy policies or on behalf of Klarna.

Debt collection agencies or any other purchaser may also report the user’s unpaid debt to credit reference agencies, which may affect his credit score and ability to obtain credit in the future.

7.14 Affiliate Networks

Klarna may share information that the user has clicked on sponsored links (ie links that promote shops, products or services) with so-called “affiliate networks”. This sharing occurs when you click on a sponsored link, as you are redirected to the store’s website through the “affiliate network”. The affiliate network may place tracking technology on the user’s device that contains the information that he has clicked on a sponsored link in one of Klarna’s interfaces, in order to track his visit to a store to calculate potential commissions. in Klarna. Affiliate networks may process your personal data in line with their own privacy policies.

7.15 Transfer

If Klarna buys or sells any credit, business or asset, it may share the user’s personal data with the possible buyer or seller of the credit, business or asset.

If Klarna itself or substantially its entire company is acquired by a third party, personal data of Klarna’s customers may be shared.

  1. Klarna stores your personal data
    We are committed to the processing of personal data within the EU / EEA area. In certain circumstances, for example when we share your personal data with a Klarna Group company, supplier or subcontractor based outside the EU / EEA, your personal data may also be transferred and processed. in a location outside the EU / EEA area. If the store where the user makes the purchase is located outside the EU / EEA area, the sharing of personal data with the store will also involve the transfer of data outside the EU / EEA area.

We ensure that an adequate level of protection of personal data is maintained and that adequate protection measures are taken in accordance with applicable data protection legislation such as the GDPR, when your personal data is transferred outside the EU / EEA area. These safeguards consist in ensuring that the third country or the State in question is subject to an adequacy decision by the European Commission, or implements standard contractual clauses of the European Commission.

  1. Duration of the processing of personal data
    We process user data for the period of time necessary to achieve the purposes of the processing. These purposes are described in this Privacy Notice. Therefore, the user’s personal data will be kept even if a purpose is no longer valid if so required for different purposes, and exclusively for the same. In particular:

if you have accepted the Klarna Terms of Services and for the duration of validity of those Terms (by asking us or giving us instructions for deleting data for example by virtue of the right to erasure / to be forgotten), we will process the necessary personal data to the provision of the Services to the user, including without limitation data relating to previous purchases;

we process the user’s personal data relating to credits in stock, for the purpose of new creditworthiness assessments for a period of 90 days from the date of the search;

we process personal data relating to debts for the purposes of the new assessment of creditworthiness for a period of 3 years from the date of extinction of the debt by means of settlement, write-off or assignment made by Klarna;

we keep telephone records for a period of 90 to ensure quality assurance;

we process the user’s personal data in compliance with applicable laws, such as consumer protection, banking, anti-money laundering and accounting legislation. Depending on the applicable law, the user’s personal data may be kept for a maximum period of 10 years from the conclusion of the relationship with the customer.

  1. User rights with respect to their personal data
    Right of access to information. The user has the right to obtain information on how their data is processed. We fulfill this obligation with this Privacy Policy, through the information available on the website and with our responses to requests sent to us by the user.

Right of access to data. The user can request a copy of his data if he wants to know what data concerning him is. We can provide a copy of this data in electronic format (ie, “data portability”).

Right of rectification. The user has the right to obtain the correction of inaccurate or incomplete data concerning him.

Right to cancellation (to be forgotten). The user has the right to request the deletion of their personal data, for example when they are no longer necessary for the purposes for which they were collected or when consent has been revoked. As specified in paragraphs 3 and 9 above, Klarna must nevertheless comply with some legal obligations that prevent us from immediately deleting some of the user’s personal data.

Right to limit data processing or to object to data processing. If the user believes that the data is incorrect or that it is being processed illegally, he has the right to ask us to stop processing. The user can also oppose the treatment when he believes that there are circumstances that would make this treatment unlawful. Furthermore, the user can always object to our use of his data for direct marketing.

Right to challenge an automated decision. The user has the right to contest an automated decision made by Klarna. See Section 6 for more information on how Klarna uses automated decisions.

Right to withdraw consent. As required by Section 5, in cases where Klarna processes the related data on the basis of your consent (explicit or not), the user can revoke their consent at any time.

Rights to apply post-mortem instructions. The user has the right to give (or designate the person authorized to do so) instructions on the storage, deletion and communication of personal data after death).

Right to lodge a complaint. The user has the right to lodge a complaint with a National Supervisory Authority or the Swedish Data Protection Authority. The complaint to the Swedish authority can be forwarded through the website https://www.datainspektionen.se/other-lang/in-english/.

Check the service settings. In the Klarna App, Klarna allows the user to customize preferences for certain Services, for example with reference to the ability to receive notifications or personalized commercial proposals. We will always respect the user’s choices.

  1. Cookies and other tracking technologies
    We use cookies and similar tracking technologies to offer a pleasant and personalized experience in our online interfaces, such as on our website, the Klarna App and the checkout of stores that cooperate with Klarna. The user can find information regarding the tracking methods used by Klarna, and accept or reject the tracking technologies in the related interface.
  2. Update of the Privacy Notice
    We are constantly working to improve our offer of Services, in order to provide the user with an increasingly pleasant experience. This includes both changes to existing Services and the offering of new Services over time. For this reason, it is important to read this Privacy Policy every time you use a Klarna Service, as the processing of the user’s personal data may be different from the last time the Services were used.
  1. How to contact us
    Klarna Bank AB (publ) is a company registered in the Swedish Commercial Register under number 556737-0431. Klarna’s head office is at Sveavägen 46, 111 34 Stockholm (Sweden).

Klarna has a data protection officer and a team of data protection specialists exclusively dedicated to data protection and privacy. Klarna also has a dedicated team of customer support specialists for data protection matters. Further information can be requested by writing to privacy@klarna.co.uk.

Klarna Bank AB (publ) is subject to Swedish data protection law. More information about Klarna can be found at www.klarna.com.

The owner of the user’s personal data is Klarna Bank AB (publ), a company subject to Swedish data protection law. For more information on Klarna, visit https://www.klarna.com/international/.

Last updated: December 3, 2020

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