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Privacy Policy 

Last updated: 20 June 2023
Data controller: Hups AB
Registration number: 556936-2717
Address: PO BOX 19, 761 22 Norrtalje, Sweden
How we respect your privacy:
When you use our website and services, and access, subscribe to, and attend our programs, (jointly referred to as our “sites”) we work hard to protect your information. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. To make our website work properly, we sometimes place small data files called cookies on your device. To find out more, please read our Cookie Policy below. This website and our services are not directed toward children (as defined by local law), nor do we knowingly collect information from children (as defined by local law) without parental consent except where in compliance with applicable laws.
  • Gender
  • Age
  • Email address
  • City
  • Country
  • Name of Employer
  • Company
  • Work title and position
When you interact with us, we may collect the following data depending on the situation and your query:
  • Forms filled out on the website
  • Correspondence with you by phone or email
  • Orders for programs and other products
  • Your interaction on the website, such as filling out forms, sending and receiving messages with others
  • Reporting a problem
  • Requesting support
  • Technical data, such as, IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  • Data about your visits on our website (clickstream, date, time, etc.)
  • Data about page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page
  • Information about your devices, device identifiers, and from which devices you visit our website and make use of the service, which may include mobile network information (including phone number), IP address, language and time zone, operating system, hardware version, device locations (including country specific geographic locations)
  • Information that is the result of a combination of the data you provide us and the personal data we automatically obtain about you from your use and interactions with our website.

Source, purpose and legal basis:
We collect information in different ways. Some information is collected directly from you, such as your name and contact information. Other types of information is collected from you passively, via tracking tools such as cookies and web beacons (please read our Cookie Policy below). We also collect information about you from third parties, such as our Sales Agents, our partners for providing our products and services to you and our customers. We use your personal data for the following purposes: Providing our services. We may use some or all of your personal data for the purpose of administering and performing the agreement with you, for example ordering access to courses and giving you access to attend  courses; Promoting our services. We may use your personal data, such as your name, email address and country, for  marketing purposes on the legal basis of our legitimate interest to promote  our services and new courses that we deem to be similar to the courses you have attended or shown interest in and that we reasonably believe may be of  interest to you; Developing our services. We may use your personal data for internal research and service development purposes as well as for historical reference on the legal basis of our legitimate interest to develop our services as well as to  keep historical references to see trends over time; Direct marketing by us. We may use your personal data, such as your name and email address, for direct marketing purposes in relation to courses you are attending as well as for the purpose of providing you with information about upcoming courses and new  products, on the legal basis of your consent.About our balance of interest assessment.

‍About our balance of interest assessment:

‍When we state above that we rely on our legitimate interests as a legal basis for our processing of personal data, we have made a so-called legitimate interest assessment. That is a balance of interest assessment through which we have determined that our legitimate interests for the processing outweighs your interests and rights not to have your personal data processed. Please contact us if you want more information on how we have made this assessment.

‍Transfers of your personal data outside the European Economic Area:

‍Our sharing of your personal data in accordance with this Privacy Policy may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it. As a safeguard, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. In addition to this, we will implement requirements and safeguards that may be required by law. You may be entitled, in accordance with applicable law, to request a copy of relevant safeguards implemented. Please contact us at for any questions in this regard.

‍Who we share your personal data with:

We may share your personal data with our affiliates and with selected third parties.


‍Our affiliates and group companies, namely Nimocon AB.

‍Service providers:

We commit to entering into data processing agreements with each and every service provider that, when relevant, processes personal data on our behalf.

‍Business partners:

‍Our sales agents and co-operation partners with whom we enter into partnership with. We commit to entering into data processing agreements with each and  every business partner that, when relevant, processes personal data on our behalf.

‍Third parties:

‍Any tentative third-party buyer of our business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. All or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. To any other third party where lawful.

‍How we keep your personal data safe:

‍We protect your personal data from all kinds of threats: loss, alteration, unauthorized disclosure or access. We do this in a variety of ways depending on where we store and use it. Occasionally, we might have to transfer your personal data to service providers and business partners located outside the European Economic Area. We do our best to keep your personal data safe in these cases. Please read section 2 in this Privacy Policy on how we may transfer data outside of the European Economic Area and the safeguards we apply. How long we keep your personal data. We keep your personal data for as long as the personal data is relevant for use by us for the purposes as indicated in this Privacy Policy. Please note that personal data that has been published online might be downloaded and shared by individuals. In such cases, we do not control the source and will be unable to delete the personal data. We might also store your personal data longer than stated above if it is necessary because of legal requirements that we are subject to.

‍Your privacy rights:
‍You have many rights regarding your personal data. Read more about them below. If you would like to exercise them or learn more about them, feel free to contact us. You can find contact details at the top and end of this Privacy Policy. Please note that some of the rights may not be applicable to you.

‍Right of access:
‍You have the right to obtain confirmation as to whether or not we process your personal data, and, if we do, request access to your personal data as well as  information in relation to our processing. If you have any questions or would like to learn more about what personal data we process, you are always welcome to contact us and we will provide you with further information.

Right to rectification:
‍If you believe we store incorrect personal data, such as misspelt or previous names and/or addresses, you can ask us to correct this.

Right to erasure/right to be forgotten:
‍You have the right to request that we permanently erase your personal data from our records.

‍Right to restrict the processing activities:
‍You have the right to restrict our processing activities in certain situations. This means we will continue to store your personal data, but we will temporarily stop any other processing. Why would you want to do this? For example, if you have asked us to fix incorrect personal data. In this situation you may want us to stop processing until the personal data is correct.

‍Right to data portability:
‍In certain situations, you have the right to ask us to send your personal data in digital form to you or directly to another controller.

Right to object:
‍You have the right to object to the processing of your personal data, even when we have a legitimate legal reason to process it. You can do this when we process your personal data on the basis of our legitimate interest, and you believe your personal interest outweighs ours. If you do not want us using your personal data for direct marketing purposes, including profiling, we will comply in any case.

‍Right to withdraw consent:
‍In case the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before this withdrawal. Please note that all  aspects of an initiated marketing campaign cannot be stopped once initiated upon a withdrawal of consent.

Right to lodge a complaint with a supervisory authority:
‍If you are not satisfied with the way we treat your personal data, you have the right to lodge a complaint against us to the relevant supervisory authority.

Links to third-party websites and social media services:
‍Our communication may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We do not accept responsibility or liability for these third-party sites. Some of the content and functionality on our website may be provided bysocial media services that are not affiliated with us. These services will authenticate your identity and provide you the option to share certain personal data with usand, depending on the service, you may be given the option to post to your social media profile page about your activities on our website to share with others within your social media presence.

‍Changes to this privacy policy:
‍Any material changes that we make to this Privacy Policy will be posted here prior to the changes becoming effective.

‍Who to contact:
‍If you have any questions about this Privacy Policy or our processing of personal data, feel free to contact us at

Cookie policy:
Last updated: 28 January 2022

Data controller: HUPS AB Registration number: 556936-2717

Address: PO BOX 19, 761 22 Norrtalje, Sweden

Contact email:
‍Use of cookies and tracking technologies:
‍This website uses cookies and other similar technologies (as described below) when you browse or use our services. A cookie is a small file of letters and numbers that we store on your browser or on your device if you agree. Cookies contain information that is transferred to your device. We use these technologies for the purpose of distinguishing you from other users of our website and services. This helps us provide you with a good experience when you visit our website. We also use these technologies to improve our website, identify you and protect your safety.

‍Types of cookies that we use
‍Type of cookie
Purpose of cookie

‍Strictly necessary:
‍These cookies are essential in order to enable you to browse our website and use its features. The information collected by these cookies relate to the operation of our website, for example website scripting language and security tokens to maintain secure areas of our website.

‍These cookies collect anonymous information about how you use our website, for example which pages you visit most often, whether you receive any error messages, and how you arrived at our website. Information collected by these cookies is used only to improve your use of our website and never to identify you. These cookies are sometimes placed by third-party providers of web traffic analysis services, such as Google Analytics.

‍These cookies assist us with ensuring that you receive assistance with any support requests that you may have during you user journey on our website. These cookies remember choices you make, for example the country you visit our website from, your language and any changes you have made to text size or other parts of web pages that you can customise, in order to improve your  experience of our website and to make your visits more enjoyable. The  information these cookies collect may be anonymized and cannot be used to  track your browsing activity on other websites. Please note that third parties (including, for example, external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies. We may use cookies to collect anonymised data on our visitors’ behaviour on the website. We may capture what website a visitor to our website has come from and what website they go to afterwards. We may also capture demographic data (e.g. the visitor’s location) and we may use that data to analyse visitor behaviour across websites. Almost all internet browsers are automatically set up to accept cookies. If you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. Limiting, blocking or deleting cookies may impact your user experience of our website, including access to certain personalised features.

Web beacons:
‍We, or our partners, may use a software technology called web beacons (also known as pixels) to help us understand what content and material is interesting and effective. Web beacons are similar to cookies and are used to let us know when content is viewed. Web beacons are embedded on web pages, and e-mail. We, or our third-party partners, may tie the information gathered by web beacons to the other information we collect about you.