1. Introduction
Your privacy is important to us.
This policy explains how Junavie Limited (“Asavie,” “we,” “us”) collects, uses, and protects personal data. We are committed to processing data in compliance with the EU General Data Protection Regulation (GDPR) and other relevant data protection laws.
2. Our Roles: Data Controller vs. Sub-Processor
It is important to understand the two different roles we have when handling personal data:
- As a Data Controller: We determine the purposes and means of processing personal data for our own business needs. This applies to data related to our employees, job applicants, and business contacts from our customers and partners.
- As a Data Sub-processor: In many of our B2B relationships, we are a sub-supplier. Our direct customer is the Data Processor, and they are contracted by the ultimate Data Controller. In this supply chain, Asavie is a Sub-processor. We only process data on behalf of and on the instructions of our direct customer, as outlined in a Data Processing Agreement (DPA).
3. Asavie as a Data Controller
This section describes how we process data for which we are the Data Controller.
What Data We Collect, Why, and Our Legal Basis
For our Employees, we collect data such as name, address, personal identification number, contact details, and financial information. We process this data to manage the employment relationship, pay salaries, and comply with labor and tax laws. Our legal basis for this processing is the Performance of a Contract and Legal Obligation
For Job Applicants, we collect the information you provide in your CV and cover letter, such as name, contact details, education, and work history. This data is used to evaluate your application and manage the recruitment process. Our legal basis is Legitimate Interest. We will ask for your consent if we wish to retain your application for future opportunities.
For our Business Contacts, we collect names, business emails, business phone numbers, and job titles. We process this data to manage our B2B customer relationships, provide support, and for billing and contract administration. Our legal basis is our Legitimate Interest in maintaining a business relationship.
How Long We Keep Your Data
We store data for defined periods. Employee data is stored for the duration of employment; afterward, we retain only what is required by law (e.g., payroll information under the Swedish Bookkeeping Act for 7 years) before securely deleting the rest. For unsuccessful job applicants, we retain data for 24 months after the recruitment process ends after which it is deleted. Business contact data is retained for the duration of the business relationship and for up to 24 months afterward to finalize all business matters.
Who We Share Your Data With
We share employee data with trusted service providers located within the EU/EEA to manage payroll, expenses, and other HR-related tasks.
4. Asavie as a Sub-Processor
This section describes our role when processing network data on behalf of our customers.
- What Data We Process: In providing our services, we process a limited set of technical network identifiers necessary for network operation, including MSISDN, IMSI, IP addresses, and Cell-ID.
- International Data Transfers and SCCs: Our services are global, which means network data may be processed in data centers around the world. All international transfers of data outside the EU/EEA are conducted in line with GDPR requirements. The primary legal safeguard we use for this is the European Commission’s Standard Contractual Clauses (SCCs). These are legal contracts that obligate the data importer to protect data to a standard equivalent to GDPR.
- Sub-processor Transparency: A complete and updated list of all sub-processors involved in delivering our service is available to our customers as part of their Data Processing Agreement (DPA).
5. Security of Your Data
We use appropriate technical and organizational measures to protect the personal data that we process. Our Information Security Management System (ISMS) is built upon and we are committed to complying with the ISO 27001 standard, providing assurance of our commitment to securing your data.
6. Your Data Protection Rights
Under GDPR, individuals have rights regarding their personal data. These rights are primarily exercised by contacting the Data Controller (e.g., your employer, or the company whose service you are using). The main rights are:
- Right to Access: To request a copy of your data.
- Right to Rectification: To ask for inaccurate information to be corrected.
- Right to Erasure (“Right to be Forgotten”): To ask for your personal data to be deleted.
- Right to Restrict Processing: To ask for the use of your data to be limited.
Important Note on Service Viability: Please be aware that our services, when we act as a Sub-processor, depend on the processing of specific technical identifiers. A request for the erasure or restriction of these essential identifiers, if approved by the Data Controller, will prevent the network from recognizing the associated device. This would result in the permanent cessation of our service for that device, as it would be technically impossible to provide connectivity without this data.
7. Data from Our Website
We do not currently use cookies or analytics tools to collect personal data from visitors to our website, asavie.com outside of the contact form.
8. How to Contact Us
If you have any questions about this policy or how we handle your data, please get in touch.
- Company: Junavie Limited (CRO: 815136)
- Address: 77 Camden Street Lower, Dublin 2, Ireland
- Email for Privacy Inquiries: privacy@asavie.com
- Data Protection Officer: Per Johdet