We believe that it is important that we protect the privacy of the personal information that we collect and use.

This Privacy Notice describes how personal information will be processed by us when individuals visit any SWEP websites or when individuals otherwise engage with us due to our products and services. These websites are swep.net, swep.se, swep.de, swep.sk, swep.cn, swep.ru, swep.fr, swep.jp, swep.kr, swep.com.br (the ‘Websites’). Before using the Websites, you should read this Privacy Notice.

If you are an employee of a SWEP Group company you should refer to the employee privacy notice provided by your employer.

The Privacy Notice also describes your rights as an individual and how you can contact SWEP if you have any concerns regarding our use of your personal information.

1. Who we are

2. The personal information we collect

3. What do we do with the personal information we collect

4. Lawful bases

5. Sharing your personal information

6. How long will we hold your personal information

7. International data transfers

8. Links to other websites

9. Rights concerning your personal information

10. Marketing

11. Security

12. Cookies used on the Websites

13. Contact

14. Complaints

15. Changes to the Privacy Notice

1. Who we are

The Websites are controlled by SWEP International AB, registered at 556287-5392, Box 105, 261 22 Landskrona, Sweden. However, if you are dealing with or have contacted any of the SWEP offices or sales representatives directly in other countries, that respective office or sales representative is also responsible for the processing of your personal information.

2. The personal information we collect

Personal information is any information that can be used to identify an individual. We collect the following personal information through the SWEP website:

(i) Contact information — that is, information such as your full name, email address, mailing address, telephone number;

a. This information is collected on various forms on the website and is completely voluntary.

(ii) Information related to customer surveys, promotions, and/or offers (e.g. preferences, demographics, interests, etc.), and

(iii) Information about the device you use to access the SWEP website (e.g. IP address)

When you visit our Websites, SWEP also uses cookies and active components (e.g. JavaScript) to track visitors' preferences and behavior to optimize the website. Therefore, we will collect personal information from you through these tracking technologies. Please see our section on Cookies below for more information.

We do not knowingly collect or allow the collection of personal data from persons under the age of 18. If you are the parent or guardian of a person under the age of 18 and believe that the person has provided personal data to us, please contact us at privacy@swep.net.

3. What do we do with the personal information we collect

We use the personal information collected in the following ways:

• to understand your needs, provide you with a better service and respond to your enquiries

• for the purpose of contract execution between us

• to provide advice and support to our customers and prospects

• to analyze how many unique visitors we receive to our Websites

• to administer any account, you have with us e.g. e-commerce customer account

• to enable your use of any online or offline services we provided e.g. SSP Calculation Software.

• to provide you with any newsletters we offer

• to improve the products and services we offer on our Websites

• for marketing-related purposes, subject to the provisions below

To the extent permitted by applicable law, we may also use your personal information as we believe to be necessary or appropriate:

• to comply with legal process

• to respond to requests from public or governmental authorities

• to enforce our Privacy Notice

• to protect the operations of the SWEP Group

• to protect the rights, safety or property of the SWEP Group or others

• to allow us to pursue available remedies or limit the damages that we may sustain

4. Lawful bases

We only use personal information where we can rely on a lawful basis as required under applicable data privacy laws.

The lawful bases we rely on are:

• Legitimate interest – we have a legitimate interest in contacting you when you provide us with your details, to manage our relationship with you and to monitor and improve the use of our Websites and to send you marketing communications.

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and on your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

• Consent – we will obtain your consent where we are required to do so under local law in order to send you marketing communications

• Compliance with a legal obligation – where we are required to collect and disclose your personal information because we are subject to a legal or regulatory obligation

We do not intend to collect any sensitive personal information (or special categories of personal data) which are personal information deemed more sensitive e.g. ethnicity, race, health information.

Where we rely on the legitimate interest lawful basis to use your personal information, you always have the right to object to our use by contacting us.

Where we rely on consent as the lawful basis to use your personal information, you always have the right to withdraw your consent by contacting us.

5. Sharing your personal information

Unless set out in this Privacy Notice, your personal information will not be disclosed to third parties outside the SWEP Group.

Unless set out in this Privacy Notice, we do not sell, distribute or in other ways make your personal information available for third parties for commercial purposes without your consent.

SWEP uses IT systems and software provided by third party suppliers. This means that these suppliers may process your personal information when they provide services to us. However, these third-party suppliers are processors and so may only process your personal information according to our instructions.

We may share your personal information with third parties if disclosure is required to comply with applicable laws or regulation; comply with legal process or a court order; to respond to requests from public and governmental authorities; necessary to enforce this Privacy Notice; necessary to protect your safety or security; necessary to protect our rights, the safety and security of the Websites or property or third parties; to allow us to pursue available remedies or limit the damages we may sustain.

We may share or transfer your personal information to a third party if SWEP enters into, or is involved in, a business transaction such as a merger, acquisition, reorganization or sale of some or all of its assets.

6. How long will we hold your personal information

In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six (6) years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see below), we will remove it from our records at the relevant time.

If you request to receive no further contact from us, we may keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

7. International data transfers

As the SWEP Group is a global organization we will transfer your personal information across borders. When a transfer of personal information across borders is required to comply with applicable law, we will implement appropriate safeguards (such as the European Commission approved Standard Contractual Clauses) to protect the personal information.

If you have any questions about the transfer of your personal information, please contact us.

8. Links to other websites

Our Websites may contain links to websites of other providers and third parties. Once you click on these links to leave our Websites you should note that we have no control over those other websites. We cannot be responsible for the protection and privacy of any personal information you provide whilst visiting those websites and such websites are not governed by this Privacy Notice, we recommend you visit each website to see in their privacy notice how they process personal information.

9. Rights concerning your personal information

Right to withdraw consent

You have the right to withdraw your consent to the processing of your personal information at any time. If you withdraw your consent and we are not otherwise able to lawfully retain your personal information, we will discontinue the processing for which you have given your consent and erase the personal information processed solely based on the consent.

Right to access

You have the right to obtain information on what personal information we have about you and how we process this personal information. You also have the right to receive a copy of this personal information.

Right to rectification and erasure

You have the right to have inaccurate personal information rectified and completed. In some cases, you may also have the right to have your personal information erased, for example if it is no longer necessary for the purpose for which it was collected.

Right to object and right to restriction of processing

You have the right to object to the processing of your personal information for, for example, (i) direct marketing purposes and (ii) where we process your personal information on the legal basis of legitimate interests. You also have the right to restrict the processing of your personal information, e.g. if you contest the accuracy of the personal information we hold on you and we need to restrict our use of the personal information while we verify its accuracy.

Right to portability

Where we process your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.

Please note that some of these rights only apply in limited circumstances.

10. Marketing

Where required by local law, we will obtain your prior consent:

1. In order to send you marketing communications about SWEP,

2. In order to provide your personal data to third-party service providers (including contractors who provide services to us) to assist with any of the uses of personal data described in this Notice,

3. In order to provide your personal data to SWEP Affiliates for their marketing purposes, and

4. In order to provide your personal data to third parties and other partners for join marketing efforts or their own marketing efforts.

Please note you always have the right to withdraw your consent.

We may use your personal data for our own marketing purposes, including but not limited to notify you of new services, offers or other information via mail, email, telephone, text message and other means.

If you do not want us to use your personal data for marketing purposes as described above, you may opt-out of such uses by notifying us in accordance with the procedure set forth below under the heading “Rights concerning your personal data”.

11. Security

SWEP uses technical and organizational security measures to protect your personal information from accidental or unlawful destruction, loss, alteration and disclosure. Our security measures are continuously improved in line with technological developments.

12. Cookies used on the Websites

Web cookies are small files that are placed on your computer or mobile device by a website when you visit it. They contain details of your browsing history on that website and distinguish you from other users. Cookies send data back to the originating website on each subsequent visit or allow another website to recognize the cookie. Cookies are useful because they allow a website to recognize a user’s device and, for instance, remember your preferences and generally improve your online user experience.

Although this Privacy Notice refers to the general term “cookie”, which is the main method used by the Websites to store information, the browser’s local storage space is also used for the same purpose and we may use other tracking technologies through the Websites such as web beacons, clear GIFs or pixel tags. We usually use such tracking technologies to count users who visit certain pages of the Websites and to deliver branded services as well as to help determine the effectiveness of promotional campaigns. As a result, the information included in this Privacy Notice is likewise applicable to all such tracking technologies that we use.

By clicking I Agree on the cookie banner when you visit each of the Websites you consent to our use of cookies as updated from time to time. In particular, you consent to cookies being stored on your computer and/ or mobile device. You can refuse to accept cookies via your browser settings. Please note that some features of the website may then no longer be available.

We set out below the cookies used on the Websites.

Google Analytics

The Websites use Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer and that allow an analysis of the use of the Websites by you. The information generated by the cookie about your use of the Websites is usually transmitted to a Google server in the USA and stored there.

However, since IP anonymization is activated on the Websites, your IP address will be shortened by Google beforehand within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of SWEP, Google will use this information to evaluate your use of the Websites, to compile statistical reports on website activity and to provide other services related to website activity and internet usage to SWEP.

You can prevent the storage of cookies by changing the cookie settings of your browser; however, please note that if you do this, you may not be able to use all the features of the Websites to the fullest extent possible. In addition, you may prevent the collection by Google of the data generated by the cookie by downloading the browser plug-in available under the following link and installing it: https://tools. google.com/ dlpage/ gaoptout? hl=en .

The cookies that Google uses have a different "lifespan"; some stay up to 2 years, some remain valid only during the current visit.

Hotjar

This website uses Hotjar, an analysis software of Hotjar Ltd. ("Hotjar") ( http://www. hotjar .com , 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe). With Hotjar it is possible to measure and evaluate the usage behavior on the Websites in the form of clicks, mouse movements, scroll heights, etc. The information generated by the tracking code and the cookie is transmitted to and stored by the Hotjar servers in Ireland.

The following information is collected:

The IP address of your device (IP addresses of visitors are always anonymized before being stored)

• Your e-mail address including your name and surname, if you have made it available to us through our website

• Screen size of your device

• Device type and browser information

• Geographic point of view (only the country)

• The preferred language to use on the Websites

Hotjar will use this information to evaluate your use of the Websites, to generate reports, as well as other services related to use of the Websites and internet evaluation of the Websites. Hotjar also uses third-party services such as Google Analytics and Optimizely to provide services. These third parties may store information that your browser sends during your visit to the Websites, such as cookies or IP requests. For more information on how to store and use Google Analytics and Optimizely data, please refer to their respective privacy policies - https://support. google.com /analytics /answer/6004245? hl=en-GB and https://www.optimizely. com/privacy/.

The cookies that Hotjar uses have a different "lifespan"; some stay up to 365 days, some remain valid only during the current visit.

You can prevent the collection of data by Hotjar by clicking on the following link and follow the instructions there: https://www. hotjar .com/opt-out .

Apsis Lead

This website uses Apsis Lead, an analysis software from APSIS International AB ("APSIS") ( http://www. apsis.com , Stormgatan 11, 211 20 Malmö, Sweden, Europe).

APSIS technology can identify training opportunities for future B2B relationships. This is done by evaluating the IP address and using the unique identifiers stored in cookies. The APSIS Lead Cookie has a maximum lifespan of 180 days.

Internet browsers normally accept cookies by default. However, most browsers let you turn off either all or third-party cookies. What you are able to do depends on which browser you are using.

The option to do this is usually found in the options, settings or preferences menu of your browser or mobile device.

Click on the links below to find out how to change your cookie settings in:

• Internet explorer

• Firefox

• Chrome

• Safari

• Opera

• iPhone and iPad

• Samsung

13. Contact

If you have any concerns regarding how we process your personal information, if you would like to request information about any Personal Information disclosed to third parties for direct marketing purposes, or if you require this notice in an alternative accessible format, please contact us at privacy@swep.net.

14. Complaints

If you have any concerns about our processing of your personal information, you have the right to lodge a complaint with your local data protection authority. In Sweden this is the Datainspektionen (see: https://www.datainspektionen.se).

15. Changes to the Privacy Notice

SWEP may change this Privacy Notice at any time to comply with applicable law and data protection regulations. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an updated notice on our Websites.

Version 2.0

Dated 210614