w18-118 Privacy Policy – Combain CPS (Rev. A 2018-04-25)

Your personal information and how we handle them

With your personal information, we mean the data we collect and save about you and how you use our services that directly or indirectly identify you. We use this information to provide services, provide you with a better experience, improve services, and provide offers that suit your needs.

The following information is a summary of how we collect and manage your personal data in accordance with the General Data Protection Regulation (GDPR).

  • Type of personal information we collect
  • Here’s how we collect personal data
  • This is how we use personal data
  • How long do we save personal data
  • To whom do we provide personal data
  • How do we protect your personal data
  • You decide about your personal data
  • How we process your personal data when you are no longer a customer

Type of personal data we collect


When you become a customer of Combain, we collect your contact information:
Name, address, e-mail address and telephone number.

Information about your services

We also save data about which of our services you order and use, and the way you use them.

Support cases

When you contact our support, we collect the information you provide us to help us with your case.

Here’s how we collect personal data

We collect and process data as …

  • … you specify yourself when you become a customer with us.
  • … you indicate when you contact us in the form of notes, chat conversations, emails and recorded conversations.
  • … is created when you use our services – for example, when you visit our website or log in to the service.
  • … we get from other sources – such as Billmate AB.
  • … is collected through cookies that collect information on and from your browser.

Exactly what information we collect about you depends on which of our services you use.

This is how we use personal data

In order for us to process your data, one of the following legal bases must be met:

  • Requirements to complete the agreement with you.
  • Requirements to fulfill a legal obligation.
  • The treatment lies in both your and Combain interest.
  • Consent of you for that particular treatment.

In order for us to provide our services to you, we need to process your personal information. Below you will find information about what we use your data for, and the legal basis for which the treatment is supported.

Provision of Services

We treat personal data to identify you as a customer and to handle and deliver the services you ordered and subscribe to. As well as personal information required to handle billing and payment of the services you use.

Legal basis: Completion of agreements.

Communications & Support

We may use personal information from previous contact with us in order to provide you with better assistance.

We use your contact information and information about which services you use as the basis for invoices, newsletters, important information about your services, offers and tips on how to use our services.

Legal basis: Importance, Consent and Compliance.

Development of our services and products

We process personal information about how you use our services, and from contacting us as a basis for improving your experience specifically and our services in general.

Legal basis: Importance and Consent.


In order to market relevant products and services to you according to your needs, we process personal information about what services you use and how to use them.

Legal basis: Importance and Consent.

Security and Prevention of Addiction

We process personal data in order to detect and prevent the following for our services and our network:

  • abuse
  • intrusion
  • attacks such as viruses, DDOS
  • offenses
  • use of our services that violate our terms

Legal basis: Compliance and legal commitment.

Statutory obligations

We process personal data in order to comply with the requirements of the law.
Legal basis: Legal commitment.

How long do we save personal data

We save personal information as long as there is a documented purpose for the treatment.

To whom do we provide personal data

Partners, subcontractors and other companies in Combain

We have agreements with all partners and subcontractors in the EU, and EU standard contractual clauses for all outside the EU. The agreements govern, among other things, the personal data being processed, why treatment is done, how personal data are to be protected and how long they are being treated. The agreement also contains instructions from personal data protection to Personal Data Counselor how to process personal data.

We strive to never share more personal information than absolutely necessary with each partner.

We take appropriate safeguards to ensure that your personal information is handled in accordance with applicable laws regarding safety and privacy. The same requirements apply to our subcontractors.

For the following purposes, we may share certain data with the following partners and subcontractors.

In order to charge for our services

PartnerPersonal data shared and why
Billmate ABData required to make a card payment and to verify the authenticity of the personal data specified on order.


Upon request, we may, by law and authority decision, be required to provide certain personal data to, for example, the Police.

How do we protect your personal data

We use industry standards to safely store, treat and communicate sensitive information such as personal information and passwords. For example, SSL / TLS, PGP, and one-way hash algorithms.

The protection is implemented with systematic, organizational and technical measures to ensure integrity, confidentiality and accessibility.

Combain’s staff are bound by confidentiality agreements and treat only the information their mission requires.

You decide about your personal data

You decide about your own personal data. That is, you decide which tasks you want to leave and what processing of your personal information you approve and you can revoke your consent as you wish.

However, note that we need some personal information to provide our services to you. If you choose to revoke your consent, this may mean that we can not provide all our services to you.

How we process your personal data when you are no longer a customer

When you notify us to close your account, we will remove all your personal information where there is no longer any purpose for further processing. We also notify any potential partners and subcontractors who processed your data to be deleted from them.

What is removed is yours …

  • … any email addresses with associated emails.
  • … personal data in our CRM system.
  • … backups of the above are removed in accordance with our backup schedule.

Among the things that are not removed are:

  • Data required by legal obligations for example invoice data.