This policy relates to the processing of personal data that V.S. VisitSweden AB or its subsidiaries or representation offices in different countries (‘Visit Sweden’ or ‘we’ or independently “Visit Sweden-company”) obtains: in conjunction with the performance of our services; through you/your organisation in its capacity as, for example, our cooperating partner; through visiting our websites www.visitsweden.com, corporate.visitsweden.com or our social media channels (primarily Facebook, Instagram, WeChat and YouTube), via electronic mail, SMS, telephone; or that we may receive from our cooperating partners, or from a third party. This policy also describes processing relating to the provision of the image bank ”Image Bank Sweden” (http://imagebank.sweden.se).

We care about your personal privacy. This policy regulates how we collect, use and protect data about you and how you can exercise your rights. Please contact us if you have any questions or comments regarding this Personal Data Policy.

With reference to law, we refer below to the General Data Protection Regulation (GDPR) and other applicable Swedish data protection legislation.

1. What data do we collect about you?

‘Personal data’ means data relating to you that can identify you.

You can usually use our websites without providing us with any data. There may be a request for data about you on some pages, for example, if you register to receive electronic newsletters, reports, webinars or the like. The personal data that we process about you will normally come from you or from someone within your organisation in conjunction with entering into a cooperation agreement or the like. You may also have provided data about yourself to a Visit Sweden-company, which has been transferred to one or more other Visit Sweden-companies or to our cooperating partners that is forwarded to us. Furthermore, we use data about you that we have obtained from other sources provided by a third party, e.g. marketing and sales activities companies.

The personal data about you that may be affected is:

Personal data and contact details (name, address, email address and telephone number, demographic information and – when clearly justified considering the purpose of the processing or the importance of secure identification – personal identity (ID) number)

Technical data about your unit or Internet connection (IP address, cookies, electronic images, videos and similar track and trace technologies on websites and in email communication and also your geographic location and login details)

Information about your user behaviour (for example, your search patterns on the website, your response time for pages and how you use our services). Our websites and our email communication may include an electronic image (‘web signal’ or ‘pixel tag’)

User-generated information (content that you voluntarily register or publish, for example in conjunction with competitions and newsletter applications)

2. Purpose and legal basis

It is a precondition for our processing of your personal data to be lawful that there is a legal basis for doing so, i.e. that it is necessary to perform a contract with you or a legal obligation to which we are subject, or that the processing is done following a balance of interests or that you have given your consent to specific processing. The following are examples of the purposes for which we process your personal data and the legal basis on which this is done.

One of our primary purposes for collecting personal data is to be able to perform and administer our services, either directly by us ourselves or through one or more Visit Sweden-companies, our cooperating partners, such as to provide ourselves with information about the circumstances of a specific matter, protect the interests of you and your organisation, for reporting and invoicing purposes and also, as regards personal data from our cooperating partners, to administer or perform contractual obligations.

Legal basis: The performance of a contract or legal obligation, or if you are a representative, employee or otherwise represent an organisation that is on the verge of or has entered into a contract with us – legitimate interest. Visit Sweden’s legitimate interest in the above-mentioned processing of personal data is to be able to perform contractual or legal obligations.

Another main purpose is to be able to offer you a good service through adapted services and to deliver better services with more relevant content. We use the data we collect to provide you with information about services you request but also to be able to better understand our customers and cooperating partners. We conduct, among other things, customer surveys to achieve this. Customer and market analyses and also processing for statistical purposes are performed at an amalgamated level and are not intended to identify individual customers.

Legal basis: Legitimate interest. Visit Sweden’s legitimate interest in the above mentioned processing of personal data is to be able to offer you/your organisation better services and also to provide you with relevant information about the services.

We may use data about you to provide newsletters and also news information and marketing related to our services, both general and customer-specific, inform you about campaigns, special offers and other information about our activities or services that we offer ourselves or through our cooperating partners and that we think may be of interest to you or your organisation. We may thus later use the data about you for direct marketing, unless you/your organisation have instructed us not to do this. However, if you are a private individual we will only use your data for electronic direct marketing if you have consented to us doing so.

You have an opportunity at any time to object to us using your personal data for marketing purposes by contacting us in the manner described in Clause 11 below, or directly in our electronic mailing.

Legal basis: Legitimate interest or consent. Visit Sweden’s legitimate interest in the above-mentioned processing of personal data is to be able to offer you/your organisation better services and also to provide you with personally adapted offers and other relevant information.

3. Information about cookies and how we collect data about you

We use cookies, electronic images, videos and similar track and trace technologies on our website and in our email communications. Read our cookie information, on our homepage, for further information about how we use cookies and the like.

We also obtain personal data in conjunction with the performance of our services or from you/your organisation in our capacity as cooperating partner or the like. You personally decide whether you want to provide most of the other personal data beyond this, for example, by registering for our newsletter, by sending email messages to us or through social media activities or if you/your organisation provide data to us in some other way. One Visit Sweden-company may also possibly obtain data about you from one or more other Visit Sweden-companies, our cooperating partners or another third party.

4. Who do we disclose your data to?

We process your personal data with great caution, and your data is only used by us, other Visit Sweden-companies, our cooperating partners, and by selected third parties.

Third parties that we engage to help us to conduct our business (for example, for customer surveys and mailings) only have permission to use your personal data on our behalf and for the specific tasks they have to perform following our instructions, acting as a data processor for us. They are obliged to keep your personal data confidential and secure. If and as stated by statutory you are entitled to get a list of any processors that process your personal data on our behalf.

We may also forward your personal data to one or more other Visit Sweden-companies, our cooperating partners and other third parties, who in that case generally act as independent controllers, to be able to offer better services and for marketing purposes, to enable them to perform a service for us or you/your organisation, for example, regional tourism organisations, their industry, and other tourism industry actors, our operators, media agencies, postal or service companies for delivery of, for example, mailings or public authorities where such is required according to law.

We may also possibly disclose personal data for other special reasons, e.g. when we have reason to believe that the data is necessary to identify, contact or bring proceedings against someone who may have intruded into our website or in some other way infringed or encroached upon our rights or property, or the rights of other visitors, when we are acting in good faith and are convinced that legislation requires us to disclose personal data.

The transfer of personal data to countries outside the EU/EES requires the country in question to have a contract with the EU/EES, that the country is deemed to have sufficient data protection legislation, or that we have concluded an agreement with the third party in question about them being compelled to apply the clauses approved by the EU Commission relating to the protection of personal privacy. You will find a list of approved third countries and standard clauses on the website of the EU Commission or the website of the Swedish Data Protection Authority concerning the transfer of data to third countries.

5. Your rights

You are entitled to request information about Visit Sweden’s processing of the personal data relating to you. You should clearly state in such a request what information you wish to receive (for example, what categories of specific personal data we process about you and for what purpose). The request must also be in writing and be personally signed. We will respond to your request as soon as possible and within one month. In the event that we cannot fulfil your request, we will notify you of this, stating the reasons why. We will send the information to your population register address.

Visit Sweden will, at your request or on its own volition, rectify personal data about you that is incorrect and, when necessary, supplement the same and/or restrict the processing of your data.

If you consider that the data about you is incorrect or incomplete, you are entitled to ask for it to be rectified in the manner prescribed by law. We will rectify or update the data about you as quickly as reasonably possible.

You are also entitled, in the manner prescribed by law, to have the data about you removed or request that we restrict the processing of your personal data and also to withdraw any consent. You are also entitled, in the manner prescribed by law, to have the personal data you provided to us transferred (ported).

Please note that it may be required that we retain necessary personal data in conjunction with erasure, withdrawal of consent or porting to be able to fulfil our obligations by law or contract. It may also be permitted for us according to law to retain certain personal data to satisfy our business needs.

You are entitled to object to such processing of your personal data that we do pursuant to a balance of interests. We must then, after you have specified the processing to which you are objecting, demonstrate that there are overriding interests. You are also entitled to object at any time to the processing of your personal data carried out for direct marketing.

6. How long do we save your personal data?

We will only save your personal data for as long as it is necessary for the purposes prescribed by this Personal Data Policy or for as long as is required by law or contract. Your personal data is thinned out or rendered anonymous when it is no longer relevant for the purposes for which it has been collected or is no longer required according to law or contract.

7. What do we do to protect your data?

All personal data that Visit Sweden handles is processed in accordance with the legislation concerning the processing of personal data applicable at any given time. The personal data is stored in operating environments that use security measures to prevent unauthorised access. Reasonable standards for the protection of personal data are complied with. The measures are taken with a view to preventing unpermitted or unlawful processing of the data about you and unintentional loss or destruction of, or damage to, this data.

If a personal data breach is detected, this will, in the manner prescribed by law, be notified to the Swedish Data Protection Authority and also to you when and in the manner prescribed by law.

8. Links to other websites

Please note that there may be links to other websites on Visit Sweden’s website and channels in social media. If you follow such a link, this may mean that you visit other websites that have other rules for the protection of privacy than the provisions of this Personal Data Policy.

9. Image Bank Sweden – Image Bank of Visit Sweden and the Swedish Institute

To present and market Sweden abroad, Image Bank Sweden (imagebank.sweden.se)

is administered by the Swedish Institute and Visit Sweden. To the extent images and videos show identifiable individuals, material in the image bank may constitute personal data. As such, if images and videos of you exist in the image bank this means that your personal data is processed through the provision of the image bank.

If you have entered into a modelling agreement or in any other way have participated in a photo shoot, your image was added to the image bank in agreement with the photographer, image bureau or other responsible entity that you have been in contact with in relation to your participation. The processing of personal data consisting of the provision of images and videos is based on the necessity of the performance of a contract regarding your participation if you have entered into such contract. Alternatively, processing is legally based on purposes of the legitimate interests of Visit Sweden and its partners to present and market Sweden abroad, which are assessed in light of and weighed against what we know of your interests, fundamental rights, freedoms and the protection of your personal integrity. In this balancing of interests, after careful consideration Visit Sweden has found that your interests and basic rights does not outweigh our interests and require protection in this context and that Visit Sweden can provide image(s) in which you are identifiable in the image bank based on our legitimate interests.

If you have questions or objections to our processing of personal data, please contact us at GDPR@visitsweden.com. As registered, you are entitled to request a limitation of our processing. Such request will be evaluated by Visit Sweden. If you have entered into an agreement regarding your participation this can affect our evaluation. If no request is made, images and videos are stored for a period of time as stated in individual contracts or agreements with photographers and/or models.

Individual persons, organization and corporations may use the image bank to present and market Sweden abroad and will do so under the image bank terms of use. Such external party will be responsible for its own use.

In addition to what is stated above, this Personal Data Policy is also applicable to the processing of personal data relating to the image bank and as such, your rights, our contact information and other information is available under the other sections of this document.

10. Amendment of the Personal Data Policy

This Personal Data Policy may be updated by us. If there are significant amendments to this Personal Data Policy, we will notify you by putting a clear message on our website or in some other appropriate way. We invite you to read through this Personal Data Policy to keep yourself informed about how we process your personal data.

11. Complaints

Please notify us as soon as possible if you consider that the processing of your personal data has been dealt with incorrectly. You also have the option to make a complaint to the Swedish Data Protection Authority about our personal data processing.

You may be entitled to damages if you consider that you have suffered a loss because our processing of your personal data has taken place in violation of the law. You can then request damages from us or institute proceedings at a court.

12. Contact details

V.S. VisitSweden AB, corporate identity (ID) number 556500-7621, or the Visit Sweden-company in the country in which the collection of your personal data takes place, is the controller for the processing of your personal data as shown above, unless otherwise expressly stated in conjunction with the collection of your data. Please contact the controlling Visit Sweden-company directly, or us in accordance with the following if you have any questions about the policy or our processing of personal data.

Email: GDPR@visitsweden.com

Postal address: Visit Sweden, Box 3030, SE-103 61 Stockholm

Telephone: +46 (0)8-789 10 00

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Image Bank Sweden is administered by the Swedish Institute and Visit Sweden. It is a cooperative effort with Business Sweden, and the Swedish Government Offices, including the Ministry for Foreign Affairs, the Ministry of Culture and the Ministry of Enterprise, Energy and Communications.

You can use the images in Image Bank Sweden for free when you want to present Sweden abroad. If you want to download or share an image, please read our Terms of Use Image Bank Sweden will be continuously updated with new pictures, so hopefully you will find something new every time you visit.

Read our Privacy Policy.

Acceptance of the Terms and Conditions of Use means that the user has read all the Terms and Conditions below. The Terms and Conditions of Use are binding on all users. The user must at all times note that an image may be subject to alternative conditions, additional conditions, which, if so, are provided in connection with the downloading of the image. In such cases, the additional terms shall prevail over these Terms and Conditions of Use. User means the person, organization or company that uses the image or video.

The images and videos in Image Bank Sweden are hereinafter referred to as the “asset” or “assets”.

Terms and Conditions in brief:
These Terms and Conditions of Use are binding on all users.

• The assets from Image Bank Sweden may be used for the purpose of presenting Sweden abroad in an editorial context. Marketing of products or services is prohibited (exception marketing intended to increase travel to Sweden). Please note Limits of use in each asset for exceptions.
• Assets in the image bank may not be used in Sweden for a Swedish target audience.
• In conjunction with the use of an asset, the name of the photographer (and the artist) shall be indicated in the following manner: name of photographer (artist) / imagebank.sweden.se
• The user of an asset must download the asset from Image Bank Sweden and accept the Terms and Conditions of Use. An asset from Image Bank Sweden may not be transferred to third parties.
• The downloaded asset may be used only once. If the asset shall be used again, it must be downloaded anew, since new Terms and Conditions may be applicable.
• The person, company or organization which uses an asset from Image Bank Sweden is responsible for compliance with the Terms and Conditions of Use.

Personal Data

Assets showing identifiable individuals may constitute personal data. As such, use of and participation in any material or other images in Image Bank Sweden, is subject to our Privacy Policy.

Use of images from Image Bank Sweden

Assets from the image bank may, unless other terms and conditions have been specified for a particular asset, be used free of charge for the purpose of promoting Sweden abroad or to a foreign target audience in Sweden in an editorial context. Foreign target audience means, for example, use in connection with an international conference in Sweden, or by a Chinese student in Sweden who blogs in Chinese. The above-stated applies to both printed and digital use.

Marketing of products or services for the purpose of increasing travel to Sweden is permitted. (For example, it is permissible for airlines, hotels, universities, tour operators and guides to market their services abroad to attract customers and guests to travel to and in Sweden.)

Merely using an asset without clear reference to Sweden is not deemed to promote Sweden and is, therefore, prohibited. Nor is the fact that a company has Sweden or references to Sweden in its company name, profile, payoff or the like sufficient basis for use.

Assets may not be used in a context aimed at Swedish audiences in Sweden. However, use for Swedish-speaking audiences abroad is permitted.

The above-mentioned Terms and Conditions shall apply in conjunction with the restrictions set forth below.

The above-mentioned Terms and Conditions of Use also apply to the following organizations: Swedish Institute, Visit Sweden, the Swedish Foreign Ministry and Business Sweden. For any additional terms and conditions for these organizations, see Sharing Sweden

Please note Limits of use for exceptions.

User

The user is solely responsible for all use. The user is also required to hold the organizations responsible for the image bank harmless from claims from rightsholders due to any use which violates these Terms and Conditions.

Rights, limitations, and data storage

The user acquires a non-exclusive and non-transferable right to use the assets from Image Bank Sweden. Assets may not be assigned, licensed, rented or otherwise copied or distributed to third parties. The right to use the asset must be exercised within six (6) months from the downloading of the asset. The user may not store the asset for other than the specific use which was contemplated at the time of downloading. Otherwise, in order to ensure that it remains available and to obtain any new Terms and Conditions associated with the asset, the asset must be downloaded from Image Bank Sweden again before it may be used.

Each of the organizations behind Image Bank Sweden reserves the right to prohibit a specific user from using the asset provided and to withdraw rights to certain individual assets without any further explanation. In conjunction with such a withdrawal, the user shall delete the downloaded asset, and, to the extent that it is possible, remove the asset from where it is used.

Indication of Name

The photographer's name and Image Bank Sweden shall be indicated as close to the asset as possible, as follows: name of photographer (artist) /imagebank.sweden.se.

Where no indication of name has been provided, the user may be charged for the omission of the creator’s and/or rightsholder’s name.

Disclaimer

The organizations responsible for Image Bank Sweden shall not be liable for loss of access to images, due to technical faults, force majeure or other circumstances.

The organizations responsible for Image Bank Sweden shall not be liable for inaccurate image information, which is due to incorrect information supplied by third parties.

Improper use

Assets from Image Bank Sweden may not be used in any manner inconsistent with Swedish or international law. The assets may not be used in any manner or context which might be perceived as offensive, misleading or illegal (for example, pornographic or obscene). The assets may not be used in such a manner that may offend or be defamatory to the photographer and/or people depicted in the asset.

The user is liable for any claims for damages which may arise as a result of claims brought by copyright holders or people depicted in the asset due to improper use.

Copyright

All material in Image Bank Sweden is protected under the Copyright Act. This means that all copyrighted content, structure, design, selection, language, graphics, images, videos, as well as all code, html, javascript, or the like is protected and not transferred to the user.

Disputes

Disputes concerning the interpretation or application of these Terms and Conditions shall be adjudicated under Swedish law by the Stockholm District Court.

This website is run by Swedish Institute and Visit Sweden. We want as many people as possible to be able to use this website, and this document describes how Imagebank.sweden.se complies with the accessibility regulations, any known accessibility issues, and how you can report problems so that we can fix them.

How accessible is Imagebank.sweden.se?

We are aware that some parts of this website aren’t fully accessible. See the section on non-accessible content below for more information.

How we tested this website

We perform continuous internal and external testing of Imagebank.sweden.se. The last assessment was made on 4 June 2020.

Technical information about this website’s accessibility

This website is mainly compliant with the Swedish accessibility regulations and WCAG 2.1 level AA. Non-compliant content is listed below.

General issues

• All HTML does not validate. We are currently working on fixing this for future updates.
• Headlines are visually cut when using browser zoom on small screens, making them difficult to read and understand. We are currently working on fixing this for future updates.
• Every page has the same page title. We are currently working on fixing this for future updates.
• Some links are missing a unique description. We are currently working on fixing this for future updates.
• The (human) language of the webpage is not defined. We are currently working on fixing this for future updates.
• Some error messages are to generic. We are currently working on fixing this for future updates.

Issues with usage without vision (blindness)

• The image bank thumbnails (the mini version of each image) has no description. We are currently working on fixing this for future updates.
• In some scenarios, e.g. doing a search or trying to select multiple categories, there is no method to bypass repeating blocks. We are currently working on fixing this for future updates.

Issues with usage with visual impairment (including colour blindness)

• Some hyperlinks only use color as a visual cue (making them difficult to distinguish from the rest of the text). We are currently working on fixing this for future updates.

Issues with usage with physical impairment

• There are some issues operating our website from the keyboard - focus is sometimes not visible and the focus order is not always sequential. We are currently working on fixing this for future updates.
• In some scenarios, e.g. doing a search or trying to select multiple categories, there is no method to bypass repeating blocks. We are currently working on fixing this for future updates.

What to do if you can’t access parts of this website?

If you need content from this website that is not accessible for you, but is not within the scope of the accessibility regulations as described above, please contact us and tell us:

• the web address (URL) of the content
• your name and email address
• the format you need

Reporting accessibility problems with this website

We’re always looking to improve the accessibility of this website. If you find any problems that aren’t listed on this page or if we’re not meeting the requirements of the accessibility regulations, contact us and let us know about the problem.

Enforcement procedure

The Agency for Digital Government is responsible for enforcing the accessibility regulations. If you’re not happy with how we respond to your complaint, contact the Agency for Digital Government to lodge a complaint. The statement was last updated on June 25th 2020 .