LUNDBERG

& ASSOCIATES

Privacy Notice

Lundberg & Associates AB (“LA”) cares about privacy and protecting the personal data processed by the firm. All personal data is processed in accordance with applicable data protection legislation.Visits to our website can be made without the visitor having to provide any personal data or accept cookies. However, those who choose to submit a job application or elsewise contact us and will provide us with personal data.When persons are in contact with us or occur in connection with our engagements, this entails personal data being provided to us or obtained by us. Our support organisation also collects and processes personal data about contact persons of suppliers and other external parties. Below we describe how we collect, process and share personal data in such cases. Further down we also provide information about the rights of data subjects in relation to us as controller as well as our contact details.


What personal data do we process?

Much of our communication takes place by telephone and email, which essentially always entails the processing of personal data. Emailing or phoning us generally means that personal data that can be linked to individuals are provided.We collect the personal data provided to us in connection with our engagements or that are otherwise processed during the preparation or administration of an engagement. We primarily collect personal data directly from the individuals concerned. However during engagements we sometimes receive information about individuals involved without the information being provided directly from them. We may also supplement the personal data provided by obtaining information from private and public records and sources. Normally, there is no obligation to provide us with personal data. However, if we do not receive certain personal data, we will not beable to accept an engagement, since we will not be able to comply with our obligations, inter alia, to perform conflict of interest and money laundering checks. Our support organisation also collects and processes personal data when in contact with e.g. suppliers and other external parties.The personal data we process may consist of contact details (e.g. name, title, work address, telephone number and email address), identification details (e.g. passport details and date of birth /ID number), as well as invoicing information (e.g. account number and tax details). In specific engagements the personal data may also comprise other information, e.g. course of events or other circumstances, or other information relevant to the engagement.


What are the purposes of our processing of personal data?

We process personal data provided or obtained in connection with engagements so we can fulfil our obligations and safeguard our customers' interests, and also for administration in connection with engagements, as well as obligations which follow from law. Our support organisation also processes personal data so that we can manage and administrate our relationships with suppliers and other external parties.We may also use personal data as a basis for our market and client analyses, business and methodology development, as well as for statistical purposes, risk management, and marketing purposes.


What is the legal basis for our processing?

In relation to information about private individuals, the legal basis for processing personal data is performance of the contract which governs the engagement. In relation to representatives, business partners and consultants, foreign representatives, representatives and counsel of counterparties, etc., our processing of personal data is normally based on a balancing of interests. This entails that we consider it necessary to process the personal data for the purposes that concern our client's or, where applicable, our legitimate interests and that these outweigh any opposing interests or fundamental rights and freedoms.The processing of personal data in connection with the archiving of documents after an engagement has been concluded are based on our duty to comply with our legal obligations (e.g. under accounting and anti-money laundering legislation).We may have additional grounds for the processing in connection with the various engagements we have accepted.Processing of personal data relating to suppliers or their representatives and other external parties is based on our legitimate interest in administrating the relationship and performing our contractual obligations.When we process personal data in order to analyse and develop our business, and for marketing communication, processing is based on our legitimate interest in improving and marketing our business.


Who has access to the personal data that we process?

We employ appropriate technical and organisational security measures to help protect the personal data we process from loss and to guard against, inter alia, access from unauthorised persons.Transfers of data outside the EU/EEA are made in line with applicable data protection laws and for the purposes specified above. When personal data is transferred to the firm's international offices, the data may be transferred to countries outside the EU/EEA. Transfers of this type are normally based on the EU Commission's standard contractual clauses. Transfers to countries outside the EU/EEA may also occur within the scope of a given engagement insofar as is necessary to establish, exercise or defend our client's legal claims.LA will not disclose personal data to anyone outside LA, except where

  1. it has been agreed between us and the person whose personal data we process,
  2. it is necessary within the scope of a given engagement to safeguard our customers'rights and interests,
  3. it is necessary so we can fulfil a statutory obligation, comply with a decision of a public authority or a court of law,
  4. we engage an external service provider or business partner who performs serviceson our behalf. Such service providers and business partners may only process personal data in accordance with our instructions, and may not use personal data for their own purposes, or
  5. it is otherwise permitted by law.

How long will we keep personal data?

We do not save the personal data longer than necessary given the purpose of the processing, unless otherwise required or permitted by law.The personal data that may be processed before and during the performance of an engagement are subsequently saved for at least ten years from and including the date the engagement was concluded, or for a longer period as required by the nature of theengagement.


What are the rights of the data subject?

Lundberg & Associates AB, Reg No 559131-8802, with address Bäckmans väg 19, 444 55 Stenungsund, Sweden, is the controller of the personal data processing as described above. This means that we are responsible for ensuring that the personal data are processed correctly and in accordance with applicable data protection laws.Data subjects have the right to know what personal data we process about them. A data subject also has the right to request that we rectify or erase inaccurate or incomplete personal data about them (e.g. if the personal data are no longer needed for the purpose or if the consent is withdrawn). Data subjects are also entitled to object to specific processing of personal data and request that processing of personal data be restricted. Finally, data subjects have the right to receive, in machine-readable format, personal data they have provided, and have the data transferred to another party responsible for data processing.Restriction or erasure of personal data may mean that we are unable to meet our commitments. Anyone who is dissatisfied with how we process their personal data is entitled to report this to the Swedish Data Inspection Board (Sw. Datainspektionen), which is the supervisory authority for our processing of personal data.If you have any questions or complaints about how we process your personal data or wish to exercise any of your rights set out above, you are welcome to contact us by email at cathrin.lundberg@gmail.com or by post to the address above.

Terms & Conditions

T hese terms and conditions apply to all services provided by Lundberg & Associates AB (“LA”, “us” or “we”), By entering into an agreement with us, you are considered to have agreed to these terms and conditions.

1. Fees and expenses

We start an assignment by agreeing the price for our services. All fees are exclusive of value added tax, sales tax and similar taxes. Costs for travel or other expenses will be invoiced or we may i) ask you for an advance to cover expenses or ii) forward the relevant invoice to you for payment. In some cases we are legally obliged to provide information to the tax authorities about your VAT registration number and the value of the services we have provided to you. By engaging the us, you accept that we will provide such information to the tax authorities in accordance with current regulations.

2. Invoicing

Unless otherwise agreed, we invoice each month by sending an invoice by e-mail or by post. In certain cases, we will request a retainer before we commence work. The retainer will be used to settle future invoices. Our total fee for the engagement may be higher or lower than the retainer. Unless otherwise agreed, invoices are due 15 days after the invoice date. Our invoices will be addressed to you. Each invoice states the date it is due for payment. In the event of non-payment, interest on arrears will be charged from the due date until payment has been received in accordance with applicable law. 3

2. Invoicing

Unless otherwise agreed, we invoice each month by sending an invoice by e-mail or by post. In certain cases, we will request a retainer before we commence work. The retainer will be used to settle future invoices. Our total fee for the engagement may be higher or lower than the retainer. Unless otherwise agreed, invoices are due 15 days after the invoice date. Our invoices will be addressed to you. Each invoice states the date it is due for payment. In the event of non-payment, interest on arrears will be charged from the due date until payment has been received in accordance with applicable law.

3. Identification procedures

New customers may be asked for professional references. In certain engagements, we are under a statutory duty to ascertain our clients’ identity and ownership, and to obtain information about the nature and purpose of the matter, before work is begun. We may therefore ask you to provide us with information including evidence of your identity and/or the identity of any other person involved in the matter on your behalf, and, in the case of legal entities, the individuals having ultimate control over them (the beneficial owners), as well as information and documentation showing the origin of funds and other assets. 2 We are also obliged to verify the information provided to us, and for that purpose may obtain information from external sources. We are obliged to retain all information that we have obtained in conjunction with these checks. We are legally obliged to report suspicions of money laundering or financing of terrorism to the relevant financial intelligence unit. We are also prevented by law from informing you of suspicions or that a report has been, or will be, made to the relevant financial intelligence unit. Where there are suspicions of money laundering or financing of terrorism, we are obliged to decline or cease to act in the engagement. 5.4 We cannot be held liable for loss or damage caused to you directly or indirectly by our compliance with the obligations we have considered to be incumbent on us under Clauses 3, 5.2 and 5.3.

4. Data protection

We are a controller of personal data provided and obtained in conjunction with engagements or otherwise registered when preparing or administering an engagement. We may also supplement personal data by obtaining information from private or public registers.

5. Advice

Our advice is tailored to the circumstances in the specific engagement, the facts presented to us and the instructions you give us. Accordingly, you may not rely on the advice in any other engagement or use it for any purpose other than that for which it was given. Unless we agree otherwise, our advice in a particular engagement does not include advice on either tax or potential tax implications. Our advice is confined to legal matters in the specific engagement, and insofar as we provide mathematical calculations or express views or mention factors relating to non-legal matters, we accept no liability for any potential consequences of this. Our advice never implies a guarantee of a given outcome.

6. Limitation of liability

Our liability for loss or damage caused to you due to negligence or breach of contract on our part in performing our work is limited to a sum equal to three times the fee for the engagement or one million SEK, whichever is higher. We accept no liability to pay penalties or liquidated damages. The Limitation of our also applies to multiple instances of loss or damage if they have been caused by a single act or omission or the same type of act or omission. This applies regardless of when the loss or damage was caused or incurred. Our liability to you is limited to the loss or damage you incur. Among other things, this means that our liability will be reduced by all sums that may be obtained under any insurance maintained by or for you or under any contract or indemnity to which you are a party or a beneficiary, unless it is contrary to your agreement with the insurance provider or third party, or your rights against the insurance provider or third party are thereby prejudiced. We accept no liability towards any third party due to your use of documents or other advice from us. If, at your request, we agree that a third party may rely on a document produced by us or on advice provided by us, this will not increase or otherwise affect our liability, and we will only be liable to that third party to the extent we are liable to you. Any sum paid to a third party as a result of that liability will reduce our liability to you correspondingly and vice versa. If it is separately agreed that a third party may rely on a document produced by us or on advice provided by us, no client relationship will arise between us and that third party.

7. Working with other advisers

We have an extensive network of other advisers. If we instruct, engage and/or work together with other advisers, those advisers will be considered to be independent of us and we assume no responsibility or liability for recommending them to you or for advice given by them, unless we specifically agree otherwise. This applies whether the adviser has given the advice directly to you or via us. We do not accept liability for fees or expenses charged by such advisers, whether paid by us and charged to you as disbursements or whether forwarded to you for payment. Any authority to instruct advisers includes authority to accept a limitation of liability on your behalf. When we instruct other advisers we may, at your request, obtain fee quotes from them and/or agree fee arrangements with them. Although we will assist you in any discussions with other advisers, we do not assume any responsibility for such quotes and/or arrangements. If another adviser’s liability to you is more limited than our liability, any liability we may have to you as a result of any joint and several liability that we may have with the other adviser will be reduced by the compensation we would have been able to recover from that adviser if its liability to you had not been so limited (regardless of whether that other adviser would have been able to pay the compensation to us).


8. Intellectual property rights and confidentiality

Copyright and any other intellectual property rights in all work results that we generate for you belong to us, although you have the right to use the results for the purposes for which they are provided. Unless otherwise agreed, no document or other work result generated by us may be generally circulated or used for marketing purposes. If you permit us to engage or work with other advisers on the engagement, we are entitled to provide them with material and other information that we consider may be relevant so the adviser can advise or perform services for you.

9. Complaints and claims

No claim may be made more than six months after the date the last invoice was issued for the engagement to which the claim refers. If we or our insurers pay compensation to you for any claim, then, as a condition of the payment, you will be obliged to transfer the right of recourse against third parties by way of assignment or subrogation to us or to our insurers.

10. Miscellaneous

Communications

We communicate with you and other parties involved in an engagement in a variety of ways, including via the internet and e-mail. Although these are effective means of communication, they may involve risks for which we cannot accept any responsibility. During an assignment we may store documents and work results produced by us or by you or a third party electronically for easy access to information. After an engagement has ended, we will keep (and/or store) in a cloud-based service all relevant documents and all relevant work results generated in the engagement for a period we consider appropriate for the particular type of engagement.

Amendments

These terms and conditions may be amended by us from time to time. The latest version is always available on our website.

Language versions

These terms and conditions have been produced in Swedish and English and the Swedish version prevails.

Governing law

Swedish law governs these terms.