Privacy Policy

This policy ("Privacy Policy") is an integral part of Tessin Nordic AB's (556965–9187) ("Tessin") Terms of Use and relates to the processing of personal data within the company’s business activities. The privacy policy defines how Tessin collects, processes, and protects the Investor’s personal data and this applies from the time said data is published on tessin.com. All updates in the Privacy Policy will be published on tessin.com and the Investor will receive information by e-mail in the case there any major changes occur in the Privacy Policy.

The term "personal data" refers to information that can directly or indirectly identify a natural person but does not refer to information that has been anonymised or aggregated in such a way that it (even with the help of other information) can identify a specific natural person.

The definitions provided in the Privacy Policy shall have the same meaning as in the Terms of Use, unless otherwise stated in another context. A list of the Privacy Policy content is provided below:

(Personal Data) Controller
How Tessin manages user data
Use of personal data
Discontinued use of personal data
Disclosure of personal data
Cookies, etc.
Access, review, and change of personal data
Transfer of personal data to third countries
Closing an account and preserving personal data
Rights of the Investor
Contact details

1. (Personal Data) Controller

Tessin is the (Personal Data) Controller and is therefore responsible for the processing of personal data that occurs on the Bulletin Board and within the framework of the services provided according to the Terms of Use. Tessin is also responsible for ensuring that the processing is conducted in accordance with the principles stated in the Privacy Policy.

2. How Tessin manages user data

When the Investor registers an account on tessin.com and agrees to the Terms of Use, they agree to share certain personal information with Tessin and thereby agree that the information will be transferred and stored on our servers in Sweden or in other countries in or outside the EU/EEA.

2.1 Information submitted by the Investor

Be advised that Tessin collects and saves provided information when an Investor registers and uses the Bulletin Board, such as when an Investor completes an investment and uses other services or tools that Tessin provides or may come to provide. Information refers to and includes the following:

Information submitted to Tessin upon registering as a member on the Bulletin Board; this information consists of an e-mail address and in some cases a telephone or mobile phone number, as well as a first and last name.
In cases where an Investment is carried out via the Bulletin Board and information is provided about an Investor’s social security number, financial information (in the form of bank account numbers), and possibly the Investor’s registered address.
Information about an Investor’s usage of the Bulletin Board, including information about completed or canceled reservations, completion of investments and other activities related to the Investor’s account.
Information regarding whether or not a payment for Investments has been paid and what compensation the Investor has received in the form of dividends, amortization, interest, or repayment of an investment.
Information and/or correspondence sent to Tessin in the form of feedback or information provided to Tessin's customer service.
Documentation requested by Tessin to fulfill its legal obligations regarding measures against money laundering and terrorist financing. For example, an Investor may need to confirm their registered address, verify their identity, and answer questions through Tessin's customer knowledge form.
Additional documentation requested by Tessin due to concerns about compliance with the Terms of Use.

2.2 Information Automatically Collected by Tessin

Information is automatically collected from an Investor’s computer, mobile phone or other device when they use the Bulletin Board or additional services provided by Tessin, or click on links in newsletter from Tessin or on the Bulletin Board. The information is only attributable to the individual investor if the Bulletin Board is used by a registered investor and consists of internet connection information, page views statistics, IP address, traffic to and from the Bulletin Board, ad data, URL reference, and standard information from web logs.

2.3 Information from Third Parties

Tessin may obtain additional information about an Investor from a third party- e.g., sales companies or data providers, and add the material to the Investor’s existing information shared with Tessin. This information may include credit data, information from courts of law, and/or authorities. However, Tessin only collects information permitted by applicable legislation.

3. Use of Personal Data

3.1 Purpose of Personal Data Usage

Tessin uses an Investor’s personal data for the following purposes: providing access to the Bulletin Board and offering new investments, managing daily business needs, monitoring and analysis, helping investors utilize Tessin's services and tools, providing relevant customer support, and for general marketing purposes. Furthermore, Tessin uses an Investor’s personal data because the company is legitimately interested, and also in order to fulfill the agreement stipulated by Tessin’s Terms of Use with the Investor; in case an Investment is completed, the agreement under which Tessin acts as an administrative agent, in order to fulfill agreements with the Real Estate Companies that offer Investments and to meet legal obligations.

By not only accepting Tessin's Terms of Use but also the company’s Privacy Policy, an Investor agrees that Tessin can use personal data for the following purposes:

Provide an Investor access to the Bulletin Board, provide customer service with information about an Investor's account, administer an Investor's membership status in an Investor’s network, enable the implementation of investments, and additionally provide access to the tools and services that Tessin may offer at any time.
Send information about the Investments that are promoted on the Bulletin Board, share relevant information about previous Investments, inform an Investor about updates on the Notice Board, Terms of Use, and the Privacy Policy, or Tessin's services.
Administer, provide, develop, and secure the Bulletin Board's technical functionality in order that an Investor is ensured a safe and efficient experience with the Bulletin Board and its associated services.

Monitor the Bulletin Board to ensure that the tool is not used in violation of the Terms of Use and to exercise Tessin's or another entity's right under the Terms of Use, e.g. to prevent, detect and investigate security incidents, potentially prohibited and/or additional illegal activities.
Use cookies or other tracking technology to provide services and/or work with other third parties, such as advertising or analytics companies to provide general services. Further information about Tessin's use of cookies can be found in the Terms of Use.
Promote Tessin's products and services or products from Tessin's selected real estate business partners, and provide information about Tessin's potential group companies' websites and/or services, via e-mail or in another way.
Gather statistics, conduct market and customer analysis as well as perform general business and method development.
Enable financing or transfer of all or part of Tessin or its business.
Implement controls related to EU sanctions lists, UN sanctions lists, and PEP lists, etc., and fulfill all other laws, regulations and internal regulation obligations.

4. Discontinued use of personal data

If an Investor does not wish to receive promotions or investment offers from Tessin, they can contact Tessin at [info@tessin.com](mailto: info@tessin.com) to unsubscribe to these kind of mailings. The Investor should note that if they withdraw their approval of the handling of personal data, and/or the disclosure of the data for the purposes specified in the Privacy Policy, this may result in Tessin denying access to the Bulletin Board, the services, and/or customer service provided by Tessin in accordance with the company’s Privacy Policy and the User Terms.

5. Disclosure of personal data

Tessin does not resell or disclose an Investor’s personal data to third parties for marketing purposes (beyond what is stated in point 3: Use of Personal Data) without their explicit consent. Tessin only discloses an Investor’s personal information in order to fulfill its legal obligations and maintain adopted policies. An Investor’s personal data will only be disclosed in accordance with applicable laws and regulations.

In order to fulfill obligations under the Terms of Use and for the purposes stated in Use of Personal Data, Tessin may share an Investor’s personal information with the following:

Any future Tessin Group companies for the provision of common content and common services, to detect and prevent the infringement of Tessin's policies, and provide guidance for group products, websites, tools or services, all in accordance with applicable law;
Subcontractors (employed by Tessin for operational purposes), including but not limited to, IT vendors, cloud service providers, any loan agent representing the Investor of an Investment, payment institutions or other entities required for the management of deposits and payments connected with investments, updates on ongoing investments, or other mailings that are made to the Investor, and for the operation of the Bulletin Board.
Supervisory authorities, law enforcement, and other authorities or competent third parties, for inquiries related to criminal investigations or other activities that may entail a responsibility for either Tessin or the Investor. To the extent permitted by an applicable law, Tessin will disclose information that is relevant and necessary for any investigation - e.g., the name, personal identification number, e-mail address, and IP address of the Investor.
Information about Investors to other Investors or potential companies - i.e., if Tessin were to be divested or merged with another company.

Tessin will inform the Investor if their personal data is to be used or disclosed for purposes other than those stated in the Privacy Policy.

6. Cookies, etc.

When an Investor visits or uses the Bulletin Board and or other tools or services, such as e-mail, Tessin and its suppliers can use cookies, web beacons and similar technology to store information in order to create a faster and safer experience for the Investor. For more information about which cookies Tessin uses, see the Terms of Use.

7 .Access, review, and change of personal data

The password is an Investor’s key to their account and should consist of unique numbers, letters and symbols. An Investor may not reveal their password to any third party and is responsible for all activity that takes place through the Investor’s account. If an Investor's password has for some reason come into the wrong hands the Investor must immediately inform Tessin.

A Investor can review and change some of their personal information in the account settings on the Bulletin Board and must immediately update or alternatively notify Tessin's customer service if their personal information is changed or incorrect. Tessin will oblige an Investor’s legal rights regarding the possibility of requesting correction or deletion of an Investor’s personal data.

8. Transfer of personal data to third countries

Tessin saves and processes an Investor’s personal information on Tessin's servers in Sweden, in addition to other countries in or outside the EEA. Tessin provides appropriate protection for an Investor’s personal data when the information is transferred to a location outside the EEA. An Investor agrees that their personal data may be processed and transferred to a country outside the EEA.

Tessin uses physical, technical, and organisational security measures, based on the amount and sensitivity of the personal data being processed, and does so in order to prevent unauthorized processing, including but not limited to unauthorized access, appropriation and use, or loss, deletion or other damage to an Investor’s personal information. An example of some of the security measures that Tessin uses are: encryption and anonymisation of data, firewalls, and access controls for the use of personal data.

9. Closing an account and preserving personal data

At an Investor’s request, Tessin will close the Investor’s account and delete their personal information in an expedient manner. The deletion of data will be done in accordance with applicable laws. Tessin reserves the right to close accounts that are used in violation of the Terms of Use.

Personal information related to closed accounts is normally deleted or anonymized shortly after the account is closed. Tessin may retain personal data related to closed or inactive accounts in the following situations:

Tessin has a legitimate business interest and the retainment of information is not prohibited by law.
In cases where the Investor has invested in a real estate investment that is not repaid and the information is needed to complete repayment to the Investor.
To handle a dispute and/or ensure that Tessin's Terms of Use are upheld.
When Tessin is obliged by law to keep personal data, such as for compliance with money laundering legislation.
To take further measures that are permitted by law.

All data will be handled safely and only for the amount of time that is necessary to fulfill any of the purposes set out in the Privacy Policy, regardless of the circumstances related to an Investor’s personal data

10. Rights of the Investor

An Investor has the right to obtain more detailed information about which personal data Tessin processes about the Investor by requesting a registry extract. The request must be made in writing and compensation is not accepted by Tessin. An Investor also has the right to request the correcting or blocking of personal data that is incorrect and even can request the removal/deletion of personal data as well. An Investor also has the right to request that their personal data is structured in a machine-readable format in order to be able to transfer the information to another controller who is responsible for personal data. An Investor has the right to deny that personal information is used for direct marketing and they can withdraw their approval by contacting Tessin at info@tessin.com.

If an Investor wishes to exercise any of these rights, they should contact Tessin at info@tessin.com and enter their full name and the email address used for registration. Once the data is changed or deleted, they will be informed within one month that this action is completed. Be advised that data, which cannot be deleted, will be pseudonymized.

11. Contact details

If you have any questions or want to know more about what kind of personal data we process from your account, please contact us at: info@tessin.com or Tessin Nordic AB, Box 3627, 103 59 Stockholm. If you believe that Tessin is not processing your personal data in a correct manner, you can also contact the supervisory authority for data protection in your country. In Sweden, this the Swedish Data Protection Authority (DPA) and you can contact them by e-mail: datainspektionen@datainspektionen.se.