Privacy Policy

Vinter cares about privacy and protecting the Personal Data handled by us. All Personal Data is Processed in accordance with Applicable Law. In this Policy, we describe how and the purposes for which we use your personal information as well as what lawful basis we use and what measures we take to protect Personal data. We also provide information on how you exercise the rights you have linked to our Processing of Personal data.

Why and who?

Invierno AB Reg. No. (559207-4172) ("Vinter", "we", "us", "our") is the Controller of all Personal Data listed in this Privacy Policy (the "Policy"). In order to be fully transparent regarding where your Personal Data is stored and Processed, we will also provide a list of all our data Processors. This Policy provides information on how we handle Personal Data when you communicate with us, use the Services or visit our website (together the "Functions").


  • Users of the Services
  • Visitors of our website


"Applicable Law" refers to the legislation applicable to the processing of Personal Data, including the GDPR, supplementary national legislation, as well as practices, guidelines, and recommendations issued by a national or EU supervisory authority.
"Controller" is the company/organization that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
"Data Subject" is the living, natural person whose Personal Data is being processed.
"Personal Data" is all information relating, directly or indirectly, to an identifiable natural person.
"Processing" means any operation or set of operations that is performed on Personal data, e.g. storage, modification, reading, handover, and similar.
"Processor" is the company/organization that processes personal data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
"The Services" is data, calculation, administration, and publication of indexes or related to indexes.
The definitions above shall apply in the Policy regardless if they are capitalized or not.

Vinter's role as a Controller

The information in this Policy covers Personal Data Processing for which Vinter is the Controller. As a Controller, we are responsible for the Processing for which we decide the purpose of ("the why") and the means for the Processing (what methods, what personal data, and for how long it is stored). The Policy does not describe how we Process Personal Data in the role of a Controller - i.e. when we process Personal Data on behalf of our customers.
Vinter may process Personal Data in order to fulfill its legal obligations as a benchmark administrator under the Benchmarks Regulation and to fulfill its legal obligations under agreements with partners and clients.

Vinter's processing of personal data

We have a responsibility to describe and demonstrate how we fulfill the requirements that are imposed on us when we Process your Personal Data. This section aims to describe:
  • That Processing of Personal Data is necessary is for the purpose
  • That we have identified the lawful basis for the Processing


Consent - Vinter may process your personal data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.
Performance of a contract - The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.
Legitimate interest - Vinter may process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject and if the processing is necessary for the purpose in question.
Legal obligation - We are required by laws and regulations to process Personal Data as a result of our business.


We will keep your personal data as long as it is necessary for the purpose for which it was collected. Depending on the lawful basis on which we support the Processing, this may a) be regulated in a contract, b) be dependent on valid consent, c) be stated in legislation or d) follow by an internal assessment based on a legitimate interest assessment (LIA). In the list below, we indicate, where possible, the period during which the Personal Data will be stored and the criteria used to determine the storage period.


Processing and purpose of Processing: Registering user account to enable customer log in, verify user credentials to increase security and prevent abuse, identify through a third party, for example if login takes place via Google or LinkedIn, controls to ensure that we process accurate and relevant personal data, analyze how the Service is used as a basis for improvement and development, record user sessions to ensure a high quality of technical features to enhance the user experience, send requested information and answer client's and stakeholder's questions, invite people to relevant events to network and build business relationships, control that the Service is used in accordance with the applicable terms and conditions to mitigate the risk of abuse, communicate to be able to effectively and quickly help customers with any issues, market the business and inform potential clients, log user behavior to be able to customize the content of ads in order for it to be as relevant as possible to the recipient. Personal Data: Names, email addresses, personal identification numbers, Internet Protocol addresses, cookie ID, user data, location data, and authentication data.
Source: Directly from the registered, cookies, social networks, security systems, internally generated, or public sources.
Lawful basis: The legitimate interest of producing accurate and reliable indexes to be used as benchmarks in financial products, marketing, and provision of market data to customers. Storage period: Five years if required under the BMR. One year after termination of a client agreement if there is no such obligation under the BMR.

Your rights

You are the one in control of your Personal Data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access - You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification - If you find that the Personal Data we process about you is incorrect, let us know and we will fix it!
Erasure - Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections - Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry - in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction - You can also ask us to restrict our Processing of your Personal Data
  • Whilst we are Processing a request from you for any of your other rights;
  • If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or
  • In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.
Data portability - We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent - If you have given consent to one or several specific processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future processing of Personal Data and not for Processing that has already taken place.


You can request data portability through your Vinter rep. In any case, you can email us at [email protected]

Transfer of personal data

In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside the EU/EEA, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by controlling that either of the following requirements are fulfilled:
  • the EU Commission has determined that the level of protection is adequate in the third country where the data is processed;
  • the Processor has signed up to the EU Commission's standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
  • the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.
We have entered into Data Processing Agreements (DPA) with all our Processors. The DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.


Processor: Google Ireland Limited Personal data being processed: Names, email addresses, personal identification numbers, Internet Protocol-addresses, cookie ID, user data, location data, and authentication data.
Instructions: Vinter instructs Google to process Personal Data only in accordance with applicable law: (a) to provide the Services and TSS; (b) as further specified via Vinter's and End Users’ use of the Services (including the Admin Console and other functionality of the Services) and TSS; (c) as documented in the form of the applicable Agreement, including the Data Processing Amendment; and (d) as further documented in any other written instructions given by Vinter and acknowledged by Google as constituting instructions for purposes of the Data Processing Amendment. Google will comply with the instructions (including with regard to data transfers) unless European or National Law to which Google is subject requires other processing of Personal Data by Google, in which case Google will notify Vinter (unless that law prohibits Google from doing so on important grounds of public interest) before such other processing. For clarity, Google will not process Personal Data for Advertising purposes or serve Advertising in the Services. If Google at its option makes any Additional Products available to Vinter in accordance with the Additional Product Terms, and if Vinter opts to install or use those Additional Products, the Services may allow those Additional Products to access Personal Data as required for the interoperation of the Additional Products with the Services.

Security measures

Vinter has taken technical and organizational measures to ensure that your Personal Data is processed securely and protected from loss, abuse, and unauthorized access.


Organizational security measures are measures that are implemented in work methods and routines within the organization.
  • Internal governance documents (policies/instructions)
  • Login and password management
  • Information security policy
  • Physical security (premises etc.)
Technical security measures are measures implemented through technical solutions.
  • Encryption
  • Pseudonymization
  • Access control level
  • Access log
  • Secure network
  • VPC
  • VPN
  • Firewall
  • Back-up
  • Regular security inspection
  • Two-step verification


Vinter uses cookies and similar tracking techniques to analyze the use of the Functions so that we can give you the best user experience. For more information on how we use cookies, see our Cookie Policy.

If we don’t keep our promise

If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Swedish Data Protection Authority.
More information about our obligations and your rights can be found at

Changes to this policy

We reserve the right to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.


We have appointed a Data Protection Officer who can answer questions about your rights and other questions about how we process your personal information.
Contact information for Vinter data protection representative: Håkan Holmberg, [email protected]