Prime Penguin AB, 559062-5264, (“Prime Penguin”, “we”, or “us”) respects our customers’, partners’ and suppliers’ privacy. This privacy policy describes how we as a data controller collect and use personal data (as defined in the General Data Protection Regulation (EU) 2016/679, the “GDPR”) in connection with use of our Services. This privacy policy also describes your rights as a data subject and how to enforce them.

Please do not hesitate to reach out to us if you have any questions or comments on our processing of personal data. Reach us by sending an e-mail to or contact us at Prime Penguin AB, Mäster Samuelsgatan 45, Stockholm, Sweden.

In cases where we process data on behalf of you or your employer as data processors, we will process personal data in accordance with the instructions we have received under the personal data processing agreement we have entered into with you or your employer. That processing is not included in this privacy policy since this policy describes the processing we do as a data controller. Therefore, “you” hereinafter refers to you who use the Prime Penguin platform (“Platform”), the website or other services we provide to you (collectively the “Services”) or is in contact with us on behalf of a legal entity who, for example, might be your employer. The “Company” refers to the legal entity which you are representing as an employee, consultant or similar.


Contact information. We will process contact information such as your name, phone number, email-address and postal address.

Company-related data. This means information regarding the Company, such as your work e-mail address and if necessary, information regarding your right to represent the Company. This is applicable when you contact us in the role of representative of a company.

Personal identification number. If you are a sole trader, we will process your personal identification number as it is the same as your company registration number.

Communications data. We will collect and store your communication with us and any information provided to us in such communication, for example when e-mailing us.

Technical data. We will collect technical data from the computer (or other device) you use in connection with your use of the Services such as IP address, browser type and version, screen resolution, preferred language, geographic location, operating system and computer platform. Even though we do not normally use technical data to identify individuals, sometimes individuals can be recognized from it.

Sensitive data. We will process sensitive data about you if you provide us with such information and only to the extent necessary and justified.

Additional information regarding users of the platform:

User account data. Your username and e-mail address will be processed to provide you access to the Platform.

User activity logs. We save information about your activity in the Platform in order to analyze users’ use of the Platform for improving the Platform, but also to enable customer support.

Customer support-related information. To be able to provide customer support we will process the information necessary to handle the matter, such as contact details, communications data and technical data.

Survey data. If you are a customer to us, we may contact you to participate in online customer satisfaction surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Billing data. We will process payment history and to receive payment for the services we provide; If sending you an invoice, process your personal information if necessary, to provide a reference on the invoice, or if credit card-payment is used, process the four last digits of your credit card number.

How we gather your personal DATA

Information you give to us. Most of the information we process about you is received from you. You may directly or indirectly give us information about yourself in different ways, for example when you register for the Platform. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to provide you with our Services. Not providing such personal data may prevent us from providing our Services to you or, if applicable, the Company.

Information we collect about you. We may also, responsibly and with your privacy in mind, obtain personal data about you from your employer or the website of your employer.

How your PERSONAL DATA will be used And the Legal grounds for it

To communicate with you. Your contact details and the content of our communications with you will be used to communicate with you. This processing can either be necessary for us under our contract with you or your employer or for our legitimate interest in effective communication with our current and potential customers and business partners.

To market our services. Your contact information will be used to send newsletters, information and marketing regarding our services. This processing is based on our legitimate interest of being able to market us and our current and future services, in a manner that is relevant for you. Feel free to follow the unsubscribe instructions contained in the e-mail received from us or contact us directly.

If you are a sole trader, to identify you and the Company. We process your personal identification number as a part of the information we keep about the Company and to identify you as the representative of the Company. This is necessary for the identification process and for our legitimate interest of being able to identify our customers, suppliers and business partners.

To fulfil our legal obligations. Prime Penguin is obliged to follow Swedish law. This means that your personal data will be processed to the extent necessary for us to fulfil our legal obligations, for example the Swedish Accounting Act.

To protect our legitimate business interests and legal rights. We will use your personal data where we believe it is necessary to protect and enforce our legal rights, interests and the interests of others, for example in connection with legal claims, compliance, regulatory and audit functions. The legal ground for this processing is our legitimate interest to protect us, you and others and for us to defend against or enforce legal claims.

In connection with a merger or acquisition. In connection with, due to strategical or business-oriented reasons, a potential merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, the personal data we retain about you may be processed, shared or transferred, to parties involved in the process. This processing is based on our legitimate interest of being able to develop our business.

With your consent. Your personal data may be used for other purposes than stated above if you ask us to or you give us your consent. For example, if you are one of our customers, we might contact you asking for your consent to publish a customer review by you for the purpose of marketing our Services.

To administer our agreements. If you are our customer or supplier, personal data will be processed when we enter into and during the agreements with you or the Company. This is necessary for us to be able to enter into and fulfil agreements with you or the Company and for our legitimate interest in being able to enter into and fulfil different types of agreements and to have a contact person in connection with the agreement.

To conduct customer surveys. Based on our legitimate interests, such as our interest in developing and improving our Services your contact information may be used to contact you regarding customer surveys. By continuously collecting qualitative feedback from you and other users, we can gain a deeper understanding of problems with our Services and needs of our customers.

Participation in customer surveys is however optional and processing of any answers to surveys is based on your consent. To the extent possible we avoid collecting personal data in connection with customer surveys, but if it is necessary for the purpose of the survey we may collect personal information.

Additional processing regarding users of the Platform

To provide the Platform to you. We will continue to process your personal data (contact information such as username, e-mail address) to provide the Platform to you (or to the Company). This is necessary to fulfill our contractual obligations to you or the Company with respect to the Platform.

For billing purposes. Your personal data will be used for billing purposes. This includes having you as an invoice-reference. This processing is necessary and is based on our legitimate interest of being able to ensure payments for the services that we provide.

To provide customer support. Your personal data (e.g. user account data, technical data) will, when necessary, be used to investigate, respond to and resolve potential complaints and problems associated with the Platform (e.g. bugs). This processing is necessary to provide you with the Platform and uphold our obligations under our contract with you or your employer and for our legitimate interest in the functionality of the Platform.

To develop and improve our business and Services. We use technical data, such as user activity logs, survey data, and other aggregated and non-personal information to develop and improve the Platform including troubleshooting, data analysis, research, statistical purposes and testing (such as evaluation of new features, in line with the fundamental nature of the Platform). For example, we may collect and evaluate technical data about your use of the Platform for analytical purposes, to understand how users use the Platform in order to make it more intuitive. This processing is partly necessary to provide the Platform to you but mainly to pursue legitimate interests, such as our interest in developing and improving the Platform.

Regarding visitors of the website

When you visit our website, we will collect information using cookies and similar techniques. If the information we collect contain personal data, we will process the personal data in order to let us:

To provide a website with basic functionalities. The processing is necessary for the purpose of our legitimate interest of having a website and services that are working optimally.

To retrieve statistics, such as information about how long a visit lasts, which parts of the Website you have read and other information about behavior on the Website. The processing is based on your consent.

To market Prime Penguin and our products and services, by showing you relevant product recommendations and offerings. The processing is based on your consent.

On the Website, you can get in contact with us, by filling out a form. We will process your email address in order to be able to communicate with you and respond to your request. Email address and any other data you give us can be saved and processed for marketing purposes. The processing is based on your consent.


Sometimes, we need to share your personal information with other trusted individuals and companies. Your personal information is shared with:

Other users of the Platform. As the purpose of our Platform is to enable e-commerce and logistic providers to connect and to ensure a smooth cooperation between the parties, the necessary data for enabling such connection and cooperation will be shared.

Yur employees and consultants. Your personal data will, when appropriate, be shared with some of our employees and consultants. However, we will restrict access to those of our employees and consultants who need it to perform their jobs, for example to provide you with customer support. Our employees and consultants are of course subject to strict confidentiality.

Our service providers. We transfer to or share your personal data with our subcontractors who help us provide the Service to you which requires the processing of personal data. We provide personal data to third parties solely for the purpose of delivering the Service and to manage our daily operations including marketing of our services. Our subcontractors are not authorized by us to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal requirements. The services include:

  • Managing customer support-matters regarding the Platform,
  • Credit card processing,
  • IT-service for the performance of our Services and services that handle necessary, technical support and maintenance of our IT-solutions. This includes storage of your information by our web host,
  • Analysis of how our Services are used.

Authorities and other public actors. Sometimes legal obligations may require us to share information about you, for example to respond to lawful requests from law enforcement agencies, regulatory agencies, and other public and government authorities. We may also disclose information if needed to detect and prevent fraud or in connection with a legal process, for example to enforce our agreements or to protect our rights, you or others.

Where we PROCESS your personal data

Prime Penguin always strives to process and store your data within the EU/EEA. However, your data may for particular purposes be transferred to, and stored at, a destination outside of the EU/EEA territory where the privacy laws may not be the same as in the EU/EEA, and in some cases may be less protective than, privacy laws in the EU/EEA. However, in case of a transfer, for example to a supplier in a third country, the transfer is made according to applicable legislation. We will transfer your personal data to a destination outside EU/EEA only if adequate safeguards are in place in accordance with GDPR.

Please contact us for more information about the applicable safeguard in a specific case.

How long we keep your PERSONAL DATA

Prime Penguin keeps your personal data only for as long as necessary to fulfil the purposes for which it was collected. How long the data is kept depends on the type of information and why we process it.

If you or the Company use the Platform, we generally save your personal data for as long as you are a user of the Platform and as needed for tax and book-keeping purposes etc. Upon termination of the account your data might be stored up until one (1) month after termination due to technical reasons.

Personal data processed on the basis of your consent will be deleted when your consent is withdrawn or upon expiry of the purpose for which your consent was given. Moreover, we store data to the extent we believe it is necessary to protect our legal rights, legitimate interests and the interests of others. Your data may also be stored for a longer period if required by applicable statutory retention periods.

We regularly review our need to keep data, taking into account applicable legislation.

Your rights

Right to object. You have the right to object to processing based on legitimate interest. This means that we may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You can always contact us for more information on the balance test that has been made. Upon an objection we might have to investigate the situation further prior to a decision.

You however have an unconditional right to object to personal data being processed for direct marketing purposes.

Right to access your data. You have the right to request a transcript of personal data processed by us, and additional information on how the data have been collected, processed, shared, etc. The first transcript may be requested free of charge, however if you make repeated and unreasonable requests for copies we might charge you with an administrative fee.

Right to transfer your data. You have the right to transfer your personal data to another controller under certain conditions.

Right to rectification. You have the right to correct inaccurate or incomplete information about yourself.

Right to erasure (‘right to be forgotten’). You have the right to request that we delete personal data about you, for example if the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or if there is no legal basis for processing the data. Please note that we might have to decline your request if we are legally obliged to keep the information or if the information is necessary to defend legal claims.

Right to restriction. You are entitled to request that the processing of your personal data should be limited until inaccurate or incomplete information about you has been corrected, or until an objection from you has been handled.
Right to withdraw your consent. You may at any time withdraw any consent you have given us. However, please note that it will not affect any processing that has already taken place.

Right to complain. You have the right to lodge a complaint to the Supervisory Authority in the country you live or work in, if you believe that we have not complied with our obligations regarding your personal data. In Sweden the Supervisory Authority is Datainspektionen, which also is our lead supervisory authority, and you can find more information at their website:

Please note that if you request restriction or erasure it might affect our abilities to provide our services to you. Moreover, legal rights or obligations (such as confidentiality, accounting and tax legislation) may prevent us from disclosing or transferring all or part of your information, or from immediately deleting your information.

Changes in this Privacy Policy

This privacy policy may be updated periodically to reflect changes in our collection and use of your personal data. The latest updated version is always found on the Website. We encourage you to visit the Website on a regular basis to keep updated on our processing of personal data.