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.
In this chapter, we define the roles that are of relevance for the processing of personal data.
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
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.
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
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.
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.
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:
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).
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.
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).
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.
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. |
This chapter contains a list of all personal data held by Portfoliobox and the processing of such personal data.
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 Data Legal basis |
The user creates a student account Portfoliobox offers a special student account, which can be opened by students from our partner schools. |
Purpose Data Legal basis |
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 Data Legal basis |
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 Data Legal basis |
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 Data Legal basis |
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 Data Legal basis |
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 Data Legal basis |
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 Data If the customer is a company, the following data is
also saved: Time limit |
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 Data stored in Portfoliobox's database Data saved by ePay Legal basis |
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 Data Legal basis |
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 Data Legal basis |
Alternative payment via PayPal The customer wants to pay via its PayPal account. |
Purpose Data Data saved by PayPal Legal basis |
Alternative payment by bank transfer The customer wants to pay by bank transfer. |
Purpose Data Data saved by SEB Legal basis |
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 Data Legal basis Physical location |
Namecheap Portfoliobox purchases domain names for our customers via the Namecheap service. |
Purpose Data Legal basis Physical location |
Loopia Portfoliobox previously purchased domain names for our customers via the Loopia service. This service has now been replaced by Namecheap, but old domain names are still stored by Loopia. |
Purpose Data Legal basis Physical location |
ePay Portfoliobox uses ePay's payment solution to accept payments. |
Purpose Data Legal basis Physical location |
PayPal Portfoliobox uses PayPal's payment solution to accept payments of customers who do not want to pay by credit card. |
Purpose Data Legal basis Physical location |
Stripe Portfoliobox uses Stripe's payment solution to accept payments of customers who do not want to pay by credit card. |
Purpose Data Legal basis Physical location |
Find Creatives is a listing service that connects creatives with end customers. Members create a profile and complete it with the amount of personal data they see fit.
Other sub-services are included in Find Creatives. These may have their own names, brands and domains. It is clearly stated in these sub-services that they belong to Find Creatives.
List of sub-services:
- Sök Fotograf - www.sokfotograf.se
The user creates a Find Creatives account, using an email address or Facebook account |
Purpose Data (sign up data*) (Facebook-ld, Facebook-AccessToken) Legal basis |
The user creates and edits their profile Find Creatives is like an empty box that can be filled with content by the user. The user can add text, images, links and video clips. Portfoliobox has no control over the stored data. The user is responsible for the contents on his or her website. |
Purpose Data Legal basis |
The account is erased A member may 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 Data Legal basis |
Logs Technical errors and certain types of POST request that are sent to the server are logged. 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 Data Legal basis |
Both Portfoliobox and Find Creatives send email messages to customers for the various reasons described below.
Automatically processed customer emails These emails alternate depending on the status of the website. For example, a specific message may be sent to people who have uploaded over 30 images, and a different message may be sent to people who have not yet created any content. |
Purpose Data Legal basis |
Manually processed customer emails Portfoliobox regularly reviews its customers' websites and sends emails depending on the subjective status of the website. For example, an offer of assistance is sent to paying customers who have not yet managed to complete their websites. |
Purpose Data Legal basis |
Automatic campaign emails Various campaign messages are sent by the system. These emails alternate depending on the status of the website. For example, an offer may be sent to customers who have uploaded more than 30 images. |
Purpose Data Legal basis |
Manual campaign emails Portfoliobox regularly reviews our customers' websites and sends them offers and discounts based on subjective assessments. For example, customers who created particularly interesting websites may be offered a discount on an upgrade. |
Purpose Data Legal basis |
Newsletters with or without campaigns Roughly once a month, a newsletter is sent to all customers, with information on changes to Portfoliobox. The newsletter may also include campaigns, advice and other information. |
Purpose Data Legal basis |
Automatic email notices Portfoliobox may also send automatic emails to notify members of various events and warnings. For example, a notice may be sent that says how many visitors the user's profile has had. |
Portfoliobox offers support, customer care and debugging. This work is processed in several different systems. Stored data and the processing of data varies between systems, see the table below. All systems are online-based “cloud services”.
Gmail The customer contacts us with a request. |
Purpose Data Legal basis |
FreshDesk A ticketing system used for customer support. |
Purpose Data Legal basis |
The customer contacts us on Facebook with a request. |
Purpose Data Legal basis |
Sprout Social and other social media The customer contacts us with queries from various social media sites (such as Twitter, Facebook Instagram) |
Purpose Data Legal basis |
Skype The customer contacts us with a request. |
Purpose Data Legal basis |
Calendly To book meetings with customers |
Purpose Data Legal basis |
Mindomo The customer reports a bug. Portfoliobox stores information about the bug in Mindomo. |
Purpose Data Legal basis |
TypeForm The customer responds on a feedback form |
Purpose Data Legal basis |
Mailblast Mailblast is used to distribute newsletters and "mass emails" to many users at the same time. |
Purpose Data Legal basis |
HotJar A programme is activated in the customer's admin panel. This program records how the customer uses the product. |
Purpose Data Legal basis |
A cookie is a text file that is stored in the web browser. Portfoliobox och Find Creatives use several different cookies:
Session cookies are temporary cookies that cease to exist when the web browser is closed. Persistent cookies are stored in the web browser for a specific number of days. Third party cookies are added by third party websites (such as Google analytics) The cookies stored by Portfoliobox in the web browser are fundamental for the functionality of the service. For example, there are no "save buttons" in Portfoliobox. Instead, the content is saved in a cookie until it is sent to the database for permanent storage. The third party cookies used by Portfoliobox are from well-established services, such as Google Analytics. These cookies save comprehensive information on how the website is used. |
Purpose
Legal basis |
Portfoliobox is a service that can be used to private individuals and companies to create their own websites. The service can be compared to a “regular web hotel”, but with more advanced interfaces.
Just like with a regular web hotel, customers are responsible for the content on their own websites. Accordingly, it is up to the users to ensure that they comply with the data protection reform and do not store or process personal data in a manner that is inconsistent with the Regulation.
Portfoliobox cannot be held liable for any incorrect processing of personal data on the customers’ websites.
No incidents have occurred.