GDPR Details - Portfoliobox

1. Introduction

This document summarises Portfoliobox Stockholm AB’s processing of personal data.

Portfoliobox protects your personal privacy. We always strive for a high level of data protection and aim to comply with the rules and principles in the General Data Protection Regulation.

2. Roles

In this chapter, we define the roles that are of relevance for the processing of personal data.

2.1 Controller

Aktiebolaget Portfoliobox Stockholm AB is the controller.

Portfoliobox Stockholm AB
556894-4382
Rånövägen 30
168 39 Bromma, Sweden
Email: info@portfoliobox.net
Telephone: +46 702 57 90 16

2.2 Processors

Any subcontractors who process personal data on behalf of Portfoliobox are referred to as processors. Portfoliobox monitors the processors with regard to security and confidentiality.

2.3 Supervisory authority and complaints

At Portfoliobox, all decisions on the processing of personal data are made in the office in Sweden. Accordingly, the Swedish Data Protection Authority is the competent supervisory authority.

If a data subject is of the view that errors have been made in the processing of his or her personal data, a complaint can be submitted to the Swedish Data Protection Authority.

Before contacting the Swedish Data Protection Authority, please contact Portfoliobox with any complaints.

Swedish Data Protection Authority
www.datainspektionen.se
Telephone: +46 8 657 61 00
Email: datainspektionen@datainspektionen.se

3. Basic principles and rights

3.1. Principles for the processing of personal data

Portfoliobox complies with the following basic principles:

• No personal data are collected or processed without a legal basis;

• Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject;

• Personal data may only be collected for specified, explicit and legitimate purposes, as listed in Chapter 5 below;

• Personal data must not be processed in a manner that is incompatible with these purposes;

• Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

• The personal data collected must not be processed if they are too old to be relevant for the initial purposes;

• Personal data shall be correct and kept up to date;

• Personal data must not be stored for longer than is necessary;

• Personal data shall be protected, including against unauthorised or unlawful processing and against loss, destruction or damage.

3.2. The data subject’s rights

Portfoliobox has procedures for personal data that are consistent with the data subject’s rights:

Right to information

• Information on the processing of personal data is provided both at the time of registration and when requested by the data subject;

• The data subject is informeded in case of any incidents, such as in case of a data breach;

• The information is provided to the data subject free of charge and in an accessible format.

Right to rectification

• The data subject has a right to supplement personal data that are missing or inaccurate.

Right to erasure

• The data subject may request that his or her data are erased;

Right to restriction of processing

• Restriction means that the data is marked so that in the future, they can only be processed for certain limited purposes.

Data portability

• The data subject may request to have his or her personal data exported in a machine-readable format.

Right to object

• The data subject has a right to object to the processing of personal data;

• If an objection is made against direct marketing, the personal data must no longer be processed for such purposes.

Complaints

• The data subject has the right to complain about an incorrect assessment. Complaints should primarily be sent to Portfoliobox, but if the data subject remains unhappy with the treatment, a complaint can be submitted to the competent supervisory authority.

4. Procedures

The general guidelines and principles form the basis for all processing of personal data. Portfoliobox has implemented the following procedures for the processing of personal data:

4.1. Organisational security measures

Portfoliobox strives to achieve a good level of security for personal data, including the use of the following security measures:

• Data minimisation;

• Password management;

• Monitoring and training of employees;

• Encrypted computers equipped with antivirus software;

• Images of personal data are only used if there is an agreement in place;

• All customer communication contains a footer with a link to the personal data policy;

• Anonymisation is applied when personal data are communicated internally (if possible).

4.2. Technical security measures

Portfoliobox continuously strives to improve the security of the technical systems, including by using the following measures:

• Pro-active efforts to prevent data breaches;

• HTTPS;

• Two-step authentication, whenever possible;

• No open APIs;

• Development and test servers are free from personal data;

• External services and plug-ins are reviewed;

• Architects and system developers have received GDPR training.

4.3. In case of incidents

According to the data protection reform, a personal data breach is defined as a breach of security leading to the accidental or unlawful destruction, loss or alteration of the processed personal data.

If a personal data breach is discovered, it is reported to the product owner or to an employee who is considered to have a good overview of the system in question. This person is then responsible for notifying the breach within 72 hours. Thereafter, the incident shall be archived and added to the archive of historic incidents in this document (Appendix 1).

4.4. Special rules for children

Children under the age of 16 are not allowed to use Portfoliobox and the Data Protection Regulations concerning enhanced protection of children's personal data is therefore not actualized.

If Portfoliobox would let children under the age of 16 create an account, we would also need to obtain consent from a parent or guardian. This is considered risky and complex and would require considerable administrative work to ensure the accuracy of the certificate. For this reason, we are introducing an age limit on all of Portfoliobox’s services.

5. Risk analysis

Portfoliobox continuously reviews the risk of storing and processing data. The following risks are considered to be the greatest:

Risks	Descriptions & consequences
Hacking	All computer systems with internet access are at risk of hacker attacks. Portfoliobox is constantly working on the security of our computer systems, implementing the latest security procedures and updating vulnerable software. Portfoliobox does also not store sensitive data or data that might be considered attractive to a hacker. For example, we do not store any personal or sensitive data, credit card details or personal identity numbers or decrypted passwords.
Passwords	According to research, the most common reason for a data breach is inadequate password management. Accordingly, proper password management is the single most important factor to prevent data theft. Portfoliobox uses secure procedures for passwords.
External software	External plug-ins and services used by the company are reviewed to ensure that they do not entail security risks or place the processing of personal data at risk.
Computer breaches	Employee computers are equipped with antivirus software.
Lack of knowledge and carelessness	Training on GDPR is provided to our employees.

6. List of personal data and processing

This chapter contains a list of all personal data held by Portfoliobox and the processing of such personal data.

6.1. Portfoliobox

Portfoliobox is an online service that can be used by people to create their own websites. The user registers at www.portfoliobox.net and creates the website directly in the web browser.

Location for storage

• All text-based data added by the user is stored in Portfoliobox’s database, which is located in Ireland. Images and files that are uploaded are stored on the file server that is closest to the customer. If the customer is located in the EU, the files are stored in Ireland. If the customer is located in the US, the files are uploaded there. Possible locations for file storage include the west coast of the US, the east coast of the US, Sao Paolo, Ireland, Singapore, Tokyo and Sidney. Portfoliobox also uses a CDN network, which means that data is cashed (stored temporarily) for 30 days in Amazon’s cloud. The location of this temporary file cannot be specified.

Time limit

• As data is used continuously for the customer’s website, it will not be removed unless erased by the customer. Customers are in control of their own data and can edit most of data in the administration interface. If a customer erases his or her entire account, all information is erased (except receipts). Portfoliobox caches the data in a CDN network, which means that a temporary file is stored in Amazon’s cloud. This file is always erased automatically after 30 days. This means that if a customer erases a file, it takes 30 days before it is completely erased from the CDN network.

Legal basis

• When the user creates an account, the person accepts that Portfoliobox stores and processes personal data according to the information stated below.

Upon registration

The user creates an account, using his or her email address

Purpose
The user wants to create a website

Data
Customer ID, reference URL, reference partner, first name, last name, country, email address, password (encrypted), user name, IP (Facebook-ld, Facebook-AccessToken), (Flickr-ld, Flickr-oauth-token, Flickr-user-name)

Legal basis
Agreement (Legitimate interest in case the user is a legal entity)

The user creates a student account

Portfoliobox offers a special student account, which can be opened by students from our partner schools.

Purpose
The user wants to create a website and use the student discount

Data
The name of the school, the end date of the education, and other data according to the above.

Legal basis
Agreement

A person registers a partner school

Students can only create student accounts with Portfoliobox if their school is registered as a partner school.

Students and teachers may notify their interest in registering their school. Portfoliobox will then contact the teacher in charge for further processing.

Purpose
Register a new partner school

Data
The name of the school, the teacher's name, the teacher's email address, the teacher's telephone number (optional)

Legal basis
Agreement with a school
(A legitimate interest in processing contact information)

Regular website creation

The user creates a website

Portfoliobox is like an empty box that can be filled with content by the user. The user may add text, images, links, PDF files and other files. Portfoliobox has no control over the stored data. The user is responsible for the contents on his or her website.

Purpose
The user creates a website

Data
Text, images, files, films with or without personal.

Legal basis
The user is personally responsible for the content of his/her website. (In case Portfoliobox is processing data, the legal basis is the agreement with the user.)

Changes and regular erasure

The user can change and remove content.

Removed data is deleted from the database and any files are removed from the server.

Purpose
The user wants to make changes to the website

Data
-

Legal basis
Agreement

The account is erased

The customer can erase the account from the administration interface. The account will then be marked for erasure and all data will be erased after a number of days.

Purpose
The user wants to remove the website

Data
-

Legal basis
Agreement

Logs

Portfoliobox logs technical errors and certain types of POST request that are sent to the server. This is important for the discovery of technical errors and security threats, such as DDOS attacks. The logs are erased after a short time.

Purpose
Security and product improvement

Data
IP, error data, POST data

Legal basis
Agreement

Payments

Generation of receipts

For every payment received, a receipt is generated. The receipt is saved as a PDF file on Portfoliobox's server. The information on the receipt will also be saved in Portfoliobox's database.

Purpose
Used as supporting documentation for the accounting

Data
Customer ID, Order ID, link to the PDF file, price, customer country, customer IP, ePay ID, the customer's incomplete credit card number

If the customer is a company, the following data is also saved:
Company name, address, VAT number

Time limit
The receipt is saved in accordance with the prevailing regulations and laws governing accounting.

The user purchases a PRO subscription

The user upgrades his or her account and registers a payment card for future payments of subscriptions.

The user makes a credit card payment via Portfoliobox's payment solution, ePay. Portfoliobox does not administer, and has no ability to receive, information on the credit card data. If the payment succeeds, a unique subscription number is sent to Portfoliobox.

This unique subscription number will be used when Portfoliobox charges the customer for the next subscription period.

Purpose
To receive the benefits of the Portfoliobox PRO

Data stored in Portfoliobox's database
A receipt is generated (see above) ePay subscription ID, incomplete credit card number, credit card expiry date, date of payment

Data saved by ePay
Order ID, card type (e.g. Mastercard), amount, transaction ID, date

Legal basis
Agreement

Payment of subscription

When the subscription period is to be renewed, the user's subscription ID is used to process a payment via ePay.

Purpose
The customer wants to keep his or her PRO account for another subscription period

Data
A receipt is generated (see above)

Legal basis
Agreement

The user downgrades to the free version

All information about the customer's credit card is removed and the subscription is erased from ePay.

Purpose
The user no longer needs an upgraded account.

Data
-

Legal basis
V

Alternative payment via PayPal

The customer wants to pay via its PayPal account.

Purpose
The customer wants to buy a Portfoliobox service but prefers paying by PayPal.

Data
A receipt is generated (see above)

Data saved by PayPal
Name, address, country, telephone number, amount, date, email address, email

Legal basis
Agreement and balancing legitimate interests

Alternative payment by bank transfer

The customer wants to pay by bank transfer.

Purpose
The customer wants to buy a Portfoliobox service but prefers paying by bank transfer.

Data
A receipt is generated (see above)

Data saved by SEB
Name, address, amount, date

Legal basis
Agreement

List of external services used in Portfoliobox

Amazon AWS

Portfoliobox uses Amazon's cloud services for its infrastructure. Amazon provides servers, file servers, databases and other server services.

Purpose
Running Portfoliobox

Data
All programmes, files and data

Legal basis
Agreement