Klarna privacy policy

 Klarna Privacy Policy

At Klarna, we care about yours privacy. We therefore collect and process personal information responsibly and with your consideration in mind privacy. This Privacy Notice describes how Klarna Bank AB (publ) ("Klarna") collects and uses your personal data if you use any of Klarna's services (the "Service" or collectively, the "Services") and become a customer. - for example by making payments with any of our payment options, using Klarna's web and mobile applications (the "Klarna Apps") or if you have given your authorization to pre-fill personal data at the time of checkout. Furthermore, this Privacy Notice describes your rights regarding the processing of personal data and how to exercise these rights.

 

It is important that, before starting to use any of our Services, you read the content of this Privacy Notice in which we describe the processing of personal data in all our Services.

 

Some of our Services will provide you with access to content and functionality offered by other companies or organizations other than Klarna ("Third Party Services"). This happens, for example, when you link to third party sites from our websites, when you access third party sites while using the web browser in the Klarna App. This Privacy Policy does not apply to the collection and use of the user's personal data in third party services, and Klarna is not responsible for the processing of your personal data by such third parties. 

 

"We", "our" or any other reference "to us" means Klarna Bank AB (publ) company registered in the Swedish Commercial Register under number 556737-0431, with head office at Sveavägen 46, 111 34 Stockholm (Sweden). For the purposes of the European law on the protection of personal data, we act as trustee of the processing of personal data received from users, or otherwise concerning users and collected by us and we are responsible for the use of user data in accordance with applicable laws regarding data protection.

 

1. More information about Klarna's privacy

The processing of your personal data by Klarna Ident and Klarna Open Banking in the execution of the Services takes place in compliance with the provisions of the privacy policies relating to those services, which are presented to you when you use them. Those separate disclosures apply in lieu of the information given here. Other specific privacy notices may be provided for selected campaigns or offers available for a limited time, and will in these cases be presented together with them. 

If you are a Klarna employee or have applied to work with us, or are employed at a store we cooperate with, Klarna's processing of your personal data is subject to other privacy notices and you will be provided with relevant information depending on of the relationship that binds you to Klarna. Contact us using the information in Section 13 below if you would like a copy of the relevant privacy statement about you.

 

2. What data do we use?

2.1 The personal data you provide

You can provide us with information about you when using a Klarna Service, such as when choosing a payment method from those offered by Klarna, when contacting us or using the Klarna App. Therefore, the user is invited to remember that in order to provide the Services correctly, it is necessary to provide their personal data.

Depending on the Services chosen, the following personal data may be processed: 

  • Identification and contact details - name, date of birth, social security number, educational qualification, billing and shipping address, e-mail address, mobile number, nationality, salary, etc.

  • Payment details - data regarding credit or debit cards (card number, expiration date and CVV code), current account number, etc.

  • Special categories of data - the user can, at his complete discretion, provide us with information concerning him constituting "particular categories" of personal data pursuant to EU Regulation 2016/679 ("GDPR"), of which, for example, data concerning the religious beliefs, political views or philosophical beliefs, trade union membership, data relating to the person's health or sexual life or sexual orientation. The user will never be asked to communicate this type of personal data in order to access our Services. This category of personal data may only be provided to us on a strictly voluntary basis and with the explicit consent of the user. Please refer to paragraph 5 for information on how to withdraw consent.

The user can change their profile information as well as contact details and other editable settings at any time, using the Klarna App or by contacting us.

 

2.2. Personal user data collected by Klarna 

Depending on the Service you choose to use, Klarna may collect the following information about you, either directly or through third parties (such as credit rating or fraud prevention agencies, agencies and databases of public consultation):

  • Identification data and contact details - name, date of birth, social security number, educational qualification, occupation, gender, billing and shipping address, e-mail address, mobile number, nationality etc.

  • Information on goods and / or services - data concerning the goods or services purchased or ordered by the user, including, for example, the types of goods or the identification numbers of the shipment.

  • Financial information - financial information collected from third parties regarding income, any loans, negative payment reports, a previous payment or credit acceptance, account number, name of the account holder and other bank details.

  • Information regarding the interaction between you and Klarna - the way in which the user uses the Services, including data regarding outstanding debts and the history of debts as well as the history of Klarna's repayments; technical data such as page response times, download errors, personal preferences; customer interaction with Klarna's customer care service etc.

  • Recorded telephone conversations - we record the telephone conversations made by the user to customer service.

  • Information regarding the interaction between the user and the shops - the user's relationship with the shop where he purchases, such as information regarding the receipt of the goods and the type of shop.

  • info about device - such as the IP address, language settings, browser, time zone, operating system and platform and screen resolution. Please refer to paragraph 11 below for more information regarding the ways in which we collect data from device of the user or we store them on the same.

  • Information from external lists relating to sanctions and politically exposed persons (PEP) - we can analyze the user's data by comparing them with those in the lists of persons subject to sanctions and the so-called "Politically Exposed Persons" (PPE). These lists contain data such as name, date of birth, place of birth, occupation or position and reason for inclusion in those lists. 

  • Service Specific Information: to provide the user with some of our Services, we may collect and process additional personal data not covered by the above categories. Please refer to Section 4 for additional personal data processed for the relevant Service.  

 

3. Type, purpose and legitimacy of the processing of Personal Data

Depending on the Services used, Klarna may process personal data for the purposes listed below, on the legal basis indicated for each purpose. Please refer to Section 4 below for more information on how we process user data in our Services.

 

Treatment aimed at providing the Services

Purpose of the processing

Personal data

Legal basis of the processing

Manage the relationship with the user / customer in various ways, for example in relation to the management of the user's payments or to fulfill our obligations arising from the credit agreements entered into with the user.

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device, specific information about the Services.

Fulfill contractual obligations.

Create and send information in electronic format to the user (not of a commercial nature).

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device, specific information about the Services.

Fulfill contractual obligations.

Evaluate the best channel to contact the user and inform him of the outstanding debts.

Identification data and contact details, financial information (if available) and information regarding the interaction between the user and Klarna.

Klarna has a legitimate interest in being able to contact the user in the most efficient way.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Evaluate in which order the different payment methods should be presented to the user checkout of a shop. However, this processing and its presentation do not affect the payment methods available to you.

The user can object to this at any time by contacting Klarna using the details provided below.

This treatment constitutes a profiling. Please read Section 6 for more information on profiling.

Identification data and contact details, information on goods and services, information on the interaction between the user and Klarna, and information on the interaction between the user and the shops.

If the user has accepted the Klarna Terms of Services indicated in Section 4.4, the applicable legal basis is that of the fulfillment of contractual obligations.

However, if the user has not accepted those terms, Klarna bases this treatment on a legitimate interest, since Klarna (and the user as a customer) have a legitimate interest in having the preferred payment method in a prominent position at the checkout.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Carry out cognitive surveys of users / customers regarding their degree of satisfaction with our Services (for example, after using Klarna's customer service) via email, sms, telephone or other.

It is always possible to object to this data processing. The user will also be informed of his right to object (opt-out) from such communications whenever your email address or telephone number is used for this purpose.

Identification data and contact details, information on goods / services and information regarding the interaction between the user / customer and Klarna and between the user / customer and the shops.

Klarna has a legitimate interest in conducting customer satisfaction surveys.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Perform credit assessments before granting credit (Please refer to Section 4.1 for information on our Credit Services and Section 7 for information on how we cooperate with credit rating agencies).

Identification data and contact details, financial information and information regarding the interaction between the customer and Klarna.

Fulfill legal obligations if the provision of credit is governed by legal provisions. In the absence of legal obligations to be respected, the processing takes place for the purpose of fulfilling contractual obligations.

Prevent cyber attacks (such as DDoS type) directed at Klarna Services as part of our commitment to ensure the continuity and security of our Services.

Identification data and contact details, information regarding the interaction between the customer and Klarna and between the customer and the stores, as well as data relating to device used.

Pursue Klarna's legitimate interest in ensuring the security of its Services.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Ability to manage the client's vulnerability (if, due to personal circumstances, he is in a vulnerable position).

Identification data and contact details, information regarding the interaction between the user and Klarna, particular categories of personal data.

Based on the customer's consent.

Improve our Services, to train our operators and ensure the quality of services as well as document what has been agreed and decided between the user and Klarna's customer service.

Recording of telephone conversations.

Klarna has a legitimate interest in improving its Services, and in providing quality training and guarantees.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Communicate user data to shops, suppliers and other parties. (Please refer to Section 7 for more information regarding our methods and purposes for sharing user data).

All categories of personal data referred to in paragraph 2.

Depending on the recipients, please refer to Section 7. For example, Klarna, for the purpose of providing the Services, has a legitimate interest in using suppliers and may be subject to the legal obligation to communicate data with the authorities. The communication of data to payment service providers is required for the execution of the payment contract stipulated with the user.

Carry out risk analysis, prevent fraud and manage risks (for example by ascertaining the identity of the user and carrying out checks with agencies responsible for fraud prevention and the like).

Please refer to paragraph 7 for a more specific description of the fraud prevention companies we cooperate with.

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device.

Klarna and other parties (in particular, its customers) have a legitimate interest in conducting business risk management activities, for example by addressing the risks of fraud.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Klarna also has legal obligations to establish the identity of its customers.

Carry out activities related to credit recovery (e.g. collection and assignment of credits).

Identification data and contact details, information on goods / services, financial information and information regarding the interaction between the customer and Klarna and between the customer and the stores.

Klarna has a legitimate interest in carrying out credit collection and assignment activities.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

 

Product improvement and research

Anonymize the user's personal data for the purpose of analyzing customer behavior for product development.

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device, specific information about the Services.

Klarna has a legitimate interest in anonymizing your personal data for product development for the purpose of analyzing customer behavior.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Perform data analysis to improve and test products (for example, to improve models aimed at preventing risks and fraud).

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device, information from external lists relating to sanctions and politically exposed persons (PEP), specific information on the Services.

Klarna has a legitimate interest in analyzing data for product development and testing.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Allow internal analysis and development of statistical models.

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device, specific information about the Services.

Klarna has a legitimate interest in allowing internal analyzes for the development of statistical models.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Allow external research, for example conducted by universities or other entities.

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device, specific information about the Services.

Klarna has a legitimate interest in enabling external research and contributing to the general interest of society in supporting research.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

 

Compliance and mitigation of Klarna's exposure to legal action

 

To comply with applicable legislation, such as anti-money laundering and accounting legislation and relating to compliance with capital adequacy requirements.

Identification data and contact details, payment data, information on goods and / or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and the shops, information on device, information from external lists relating to sanctions and politically exposed persons (PEP), specific information on the Services.

Fulfillment of legal obligations.

Analysis of the lists relating to sanctions and politically exposed persons (PEE).

Identification data and contact details, information contained in the lists relating to sanctions and politically exposed persons (PEE).

Fulfillment of legal obligations.

Protect Klarna from legal action and enforce its rights under the law.

All categories of personal data referred to in paragraph 2.

Klarna has a legitimate interest in protecting itself from legal action, and in applying its rights deriving from the law.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

 

Commercial offers

Provide customers with commercial proposals and offers regarding our services.

It is always possible for the user to use theopt-out by contacting us: see paragraph 13.

Identification data and contact details, information regarding the interaction between the customer and Klarna and between the customer and the stores, specific information on the Services.

Klarna has a legitimate interest in providing customers with marketing activities and commercial offers.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Select the commercial offers to be provided to the user. This data processing ceases when the user renounces receiving commercial offers.

Identification data and contact details, information on goods / services, information regarding the interaction between the customer and Klarna and between the customer and the store, information on device, specific information about the Services.

Klarna has a legitimate interest in selecting the commercial offers to be provided to the user.

It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest exceeds that of the user in that their data is not processed.

Provide "sponsored links" to store products and services.

Information on products / services, information on the interaction between the user and Klarna, information on the interaction between the customer and the stores, information on device and specific information on services.

Klarna has a legitimate interest in providing "sponsored links" to promote our stores in the Klarna App and on our website.

 

We guarantee that the processing carried out for this purpose is necessary to satisfy our legitimate interest, and that our interest exceeds that of the user that their data is not processed.

 

4. Processing of specific personal data for certain Services

This paragraph indicates the processing operations of the user's personal data carried out for certain Services. Please refer to the terms and conditions of the relevant Service for further information regarding the Services and their characteristics.

 

4.1 Klarna's Credit Services

The following Services have as their object the provision of credit in favor of the user: Deferred payment (invoice), Immediate payment (in case of direct debit), Financing, the Klarna card and the disposable card (both available in the 'Klarna app). For the purpose of providing these Services, we carry out an assessment of the user's creditworthiness, based on the identification data and contact details provided by the user, information regarding the interaction between the user / customer and Klarna and financial information. Financial information includes information obtained externally from credit rating agencies, such as income and payment reports. Please refer to paragraph 7 for more information on our creditworthiness treatment.

 

Klarna paper and disposable paper

When the user applies for the Klarna card and the disposable card (available in the Klarna App), Klarna conducts a credit assessment of the user / customer in the same way as it does with respect to other credit. If the customer owns the Klarna Card, the customer's creditworthiness assessment is constantly updated, and is based on the customer's interaction with Klarna.

We share data regarding the user and his purchases when the user uses the Klarna Card with VISA and with the members of the VISA circuit, as necessary to carry out transactions with the card, prevent fraud and follow the applicable rules. If the user renews the Klarna card or receives a new one, we transfer this information to VISA so that VISA informs third parties where the user has stored his card data (for example in the case of recurring transactions).

In addition, in the event that the user adds the Klarna Card to the electronic wallet, we may need to share the user's data with the provider of the electronic wallet services as described in the privacy policy of that provider.

 

4.2 The user clicks on one of our promotions or event announcements published by third parties on social media

If you click on one of our promotions or event announcements posted by third parties on social media, we may receive the contact details about you provided in relation to your profile used on that social media (such as name, email address and telephone number and any other relevant commercial information such as company name, address and business sector).

 

4.3 Klarna accounts (savings and payment accounts)

If you have an account with Klarna, Klarna will also process your transaction and fund data. If the user transacts or makes payments to other accounts, Klarna will pass the user's name and account number to the recipient and to the recipient's financial institution.

In addition, if the user has made payments to a Klarna account, Klarna will process the data received from the bank that the user used for the transaction including the user's name and account number.

 

4.4 The user experience offered by Klarna under the Terms of Services

In order to offer the user an easy shopping experience, before and after it, Klarna offers the services described below, which are also described in greater detail in the Klarna Terms of Services. The use of these Services involves the processing of the user's personal data as indicated below: 

 

Operations history

We save information relating to goods and services purchased by the user through our Services, or those which we have been allowed to access otherwise, in order to show them to the user.

 

Automatic filling of information 

The automatic filling of user contact information can be done in two ways: through user interaction and / or through cookies.

 

Automatic filling through user interactions

When the user uses the Services, we may ask for the user's personal and identification data, such as name, address, telephone number, e-mail, date of birth and / or identity card number. We will keep this information in our systems and, on his return, the user will only have to provide some contact details such as telephone number, e-mail, zip code or identity document (depending on the country) in order to allow us to fill in automatic the remaining fields with the additional data.

 

Automatic filling through cookies

Another method of automatic data filling takes place through the installation of a Klarna cookie on device of the user (computer, tablet, mobile phone) which allows the user to decide to save their data such as name, address, telephone number, e-mail, date of birth, identity card number and card data on the Klarna platform. In that case we will use i cookies to import Klarna's already stored data when the user uses our services with him device. Later, we will automatically fill in the data when the user interacts with Klarna. 

 

Disabling the automatic fill function

If the user does not want to use the automatic filling function, he can contact us in order to disable this setting. The user can also change their settings directly through the Klarna App or in the purchase process at a store. Finally, the user can delete the cookies from your device thereby deleting ours as well.

 

Pre-selected preferred payment methods

Klarna can establish the user's preferred payment method for purchases, and pre-select it for him. This procedure, however, does not affect the payment methods available to the user. To this end, Klarna processes the data of the interactions between the user and Klarna, such as data regarding the payment methods chosen in the past, the purchase, the amounts and the shop. This data processing constitutes a profiling activity. Please refer to paragraph 6 for further information on profiling. 

 

Offers and benefits

In order to offer users offers and advantages such as discounts, special events, product pre-sales, promotions, commercial offers, samples, gifts, etc., we take into consideration information relating to the interactions between the user and Klarna (such as the number of purchases in a certain period of time) and the data to contact and identify the user. These are activities that may involve profiling activity. Please refer to paragraph 6 for further information on profiling.

This data will form the basis for Klarna's marketing and customer analysis, for the development of business and business processes, as well as for statistical purposes.

As part of the offers and benefits program, Klarna, its suppliers and subcontractors (on behalf of Klarna) may use this data for the communication of offers and benefits to the user by ordinary mail, SMS e-mail, social media and other digital channels. Klarna and their respective suppliers and subcontractors will not use any channels of marketing directed for this purpose (eg e-mail or text messages) if the user has expressed theopt-out to receive shares of marketing direct (or if the user has not expressed theopt-in if the same is required by national legislation).

To express theopt-out to receive offers and benefits, the user can cancel through the link indicated in the e-mails sent by Klarna or by contacting Klarna (see paragraph 13).

 

The Klarna App

If the user uses the Klarna App, some additional data will be processed in order to ensure the provision of the Services that he decides to use within the App, as indicated below. In addition, when the user chooses to redeem the rewards or participate in specific offers, the provider of these offers can deduce the use of Klarna services by the user.

  • Articles and personalized ads: the user will be able to see articles and personalized advertisements based on the purchases made previously, the contact details and identification data, the data on goods or services, the data relating to the interaction between the user and Klarna, the data relating to the interaction between the user and the stores, to data concerning the device and to specific data relating to the service.

  • Link sponsored: if the user clicks on a link sponsored that promotes a shop, a product or a service, the user will be redirected to the website of the shop through a third party, a so-called "affiliate network" (for further explanation see paragraph 7.14). The affiliate network could place a tracking technology on the user's device containing the data relating to the user's click link sponsored in the Klarna App and which is then used to track the user's visit to a store in order to calculate a potential commission to Klarna.

  • Klarna custom overview: you can view the overview for consulting the status of purchases made with Klarna and the related history, access any refunds and pay or extend the payment terms.

  • Personalized shopping collections: if the user has shared with Klarna information, topics, products and services that interest him in general, Klarna will use this information to provide him with personalized shopping collections, where he can find tailor-made products and services tailored to his interests.

  • Package shipping and tracking: the user can in some cases trace the path of shipments.

  • Possibility to "follow" the shops: if the user decides to "follow" a shop, he receives information on offers related to that shop. Klarna will automatically evaluate whether those purchases guarantee access to discounts or other offers under the current offer.

  • Credit servicesWe may offer credit to users based on previous purchases.

  • Shopping with the disposable card: Shopping through the Klarna App is one of the ways to use Klarna's payment methods in almost all stores through a single-use card. When the user uses the disposable card, Klarna collects information regarding purchases and shows them to the user on the App.

  • Customer service: when the support service is contacted through the Klarna App, we will have access to the information provided by the user.

  • Email Connect: if you have connected your email account to the Klarna Email Connect service, Klarna will regularly log into your email account to extract other information related to the goods and services and the interaction between you and the stores, in order to upload such information about the Klarna App. The user can deactivate the service at any time by removing Klarna's access.

  • Find the store: the user can decide to share his location with Klarna, in which case he will allow the use of this information to show nearby shops. The user can revoke their consent by deactivating sharing on their device. Klarna will not keep the user's location after showing them the shops. 

  • The web browser in-app: The Klarna App contains a web browser where you can access the websites of the stores and online stores and then shop with the Klarna payment methods even with stores that do not yet use our payment methods. Klarna collects information on the use of the browser by the user in order to provide relevant offers. In addition, the websites visited by the user can set their own cookies and other tracking technologies on their device.

  • Wishlist: the user can choose to add products and services in the Klarna App to their Wish List, to be able to find them later, or keep track of their prices. He can also share his Wish List with other people, such as friends and family, who will then be able to see his profile photo and username. In some cases, if you are logged into a store's website, the link to a product or service that you have chosen to add to your Wish List may include personal information such as your e-mail address.

  • Connected bank accounts (the Personal Finance Service): The use of this service will allow the user to obtain an overview of their finances, including not only their transactions with Klarna, but also with the connected bank accounts. When you choose to use this Service, Klarna will process information regarding the external account and other accounts (such as card accounts) that you choose to connect, and will collect personal data such as account number, bank, transaction history, account, funds and available goods. Based on this data, Klarna will display and provide the user with the tools to control his finances through offers designed on his specific situation (based on profiling, as explained in paragraph 6). This is achieved by comparing the expenses with those of other users of the Service. Based on this comparison, Klarna, together with its partners, can offer ways to minimize fixed and non-fixed costs.

  • Profile picture: the user can choose to upload a profile photo to the Klarna App, in which case the image could be shown in various Klarna interfaces (as in checkout of a store using Klarna, or in the Klarna App). Klarna interfaces can also be installed in store apps. The photo could also be shown to others if the user shares his device with others (with the use of automatic filling through cookies), or if you choose to share the content of your Klarna App with others. The user can at any time delete his image through the App or by contacting us.

 

5. Withdrawal of consent

In cases where Klarna processes the user's personal data on the basis of consent, even explicit (for example if a power of attorney is presented that allows another person to access your data, or in the case of a declaration of vulnerability of the customer or in case of uploading of particular data in our Services), the user can revoke the consent at any time by contacting us or deleting their data uploaded in the Klarna App. The withdrawal of consent will not harm the user as such data is not required for the purpose of providing the Services.

 

6. Profiling and automated decision making

"Profiling" consists of the automated processing of personal data aimed at examining certain personal characteristics of the user, such as aspects of his financial situation or his preferences, such as purchase preferences. We use the profiling of users' personal data that we have in order to make individual or automated decisions regarding the user for the purposes indicated below.

 

Decisions without legal effect or of similar significance

Klarna makes the following decisions without legal effects or of similar significance for the user:

  • foresee commercial contents potentially of interest. The user can always oppose this type of commercial proposal and unsubscribe from marketing or profiling by contacting us. Please refer to paragraph 3 for further information on the processing of personal data for marketing purposes;

  • decide which loyalty rewards best suit the user. Please refer to paragraph 4.4 "Offers and advantages" for further information;

  • decide the most suitable way to inform the user about his outstanding debt position. Please refer to paragraph 3 for further information;

  • select the content to be displayed to users in the Klarna App. Please refer to paragraph 4.4 "The Klarna App" for further information;

  • select the order in which the different payment methods should be presented to the user at checkout in the store.

Additionally, some of our Services (such as connecting bank accounts and other similar accounts with the Klarna App) use profiling in order to provide the applicable Service to you, such as communicating relevant financial information to you or a range of offers, in accordance with the terms of the Service.

 

Decisions having legal effect or of similar significance

Automated decision-making having legal effect or automated decisions with similar relevance means that some decisions in our Services are based solely on automatic means, without any interaction from our employees and have a significant impact on the user as a consumer. Through automated decisions, objectivity and transparency in the decisions in the offer of those Services are increased.

We use this type of automated decision-making when:

  • we decide to approve the user's request to use a credit service;

  • we decide to not approve the user's request to use a credit service;

  • we decide if the user is engaging in behavior involving a risk of fraud or money laundering, if our processing operations reveal that the user's behavior is attributable to money laundering or fraudulent behavior, or that the behavior of the 'user is inconsistent with previous uses of the Service or in case of suspected and deliberate false declaration about his identity. If applicable, Klarna also checks whether a particular customer is on a so-called anti-money laundering list or not.

Please refer to paragraph 3 for further information on the type of data processed for these purposes.

The user always has the right to contest an automated decision that has legal or similar effects (together with the related profiling) by contacting us through the e-mail address referred to in paragraph 13. A Klarna employee will then deal with the case .

 

7. Disclosure of User Information

We may need to share users' personal data with the categories of recipients listed below for the purposes listed below. The recipients and the purposes for which the data are communicated depend on the Services used by the users. When we share your personal data, we take all reasonable contractual, legal, technical and organizational measures to ensure that the user's personal data are treated with an adequate level of protection and in compliance with applicable law. 

 

7.1 Suppliers and subcontractors. 

Klarna may share your personal data with the suppliers and subcontractors it uses to provide the Services. Suppliers and subcontractors are companies authorized to process data received from Klarna or on behalf of Klarna. By way of example, this category includes software and data retention service providers, payment processing service providers and business consultants.

 

7.2 Shops

Klarna shares personal data with the stores visited by the user or from which the user makes purchases (which could include companies in the store group, if the user has been informed by the store). This is done to allow the shop to execute and manage the purchase and administer the relationship with the shop or its group, for example by verifying the identity of the customer, sending the goods, managing queries and disputes, sending relevant offers and fraud prevention. Personal data shared with a store will be subject to the privacy policies.

 

7.3 Payment Service Providers, Account Information Services and Financial Institutions 

 

7.3.1 Payment Service Providers ("FSP") and Financial Institutions 

FSPs provide stores and Klarna with services for accepting electronic payments through a variety of payment methods, including credit cards, and payments by direct bank debit, wire transfer etc. Some stores use FSPs with which they share user data for payment processing. Sharing is carried out in compliance with the privacy policies of the shops. The stores may also, for the processing and administration of payments, require us to share user information with the FSPs. Some FSPs collect and use user data independently, in accordance with their respective privacy policies. This is the case, for example, when using an electronic wallet.

Additionally, in order to carry out transactions, Klarna may share your data with other financial institutions when you transact with your account.

 

7.3.2 Account Information Services (Account Information Services or AIS) and financial institutions

When the user uses Klarna's payment methods, the latter can activate fraud prevention tools to verify their identity. For example, he can check bank login credentials online on which Klarna is using theAIS in order to collect and evaluate user information. For the user's bank and for the latter, Klarna is the supplier of theAIS. When the user logs into their bank account online using theAIS, Klarna collects the data necessary to carry out the verification. When the user uses the bank access service, Klarna never stores the actual credentials of the same (for example, bank credentials, PIN and TAN). These data will instead be provided directly to the user's bank when the latter accesses it, using an encrypted connection compliant with standard relevant banks for public and private keys.

 

7.4 Credit rating agencies. 

If you request to use a credit service (refer to paragraph 4.1 for the specification of the relevant credit services), the user's personal data may be shared with credit rating agencies ("ARC"). evaluate your credit score in relation to the credit request, to confirm the identity and contact details of the user and to protect the user and other customers from fraud. Such sharing constitutes a credit check.

The user's attention is drawn to the fact that Klarna only keeps the creditworthiness assessment received from an ARC in the data script format. It is therefore advisable to request a copy of the evaluation directly from the ARC if you wish to view it legibly.

 

7.5 Fraud Prevention and Identity Verification Agencies

The user's personal data may be shared with fraud prevention agencies and for identity verification for the purpose of verifying the user's identity, the accuracy of the data provided and the prevention of criminal activities. The agencies we cooperate with in Italy are listed here. The user's attention is drawn to the fact that these companies process the data in accordance with their own privacy policies.

 

7.6 Klarna Group Companies

User data may be shared with other Klarna group companies, based on Klarna's legitimate interest in conducting its business.

Klarna may specifically transfer your personal data to BillPay GmbH, based in Germany, which is a company of the Klarna Group, in order to obtain full contractual obligations with you. The privacy policy of BillPay GmbH is available here.

 

7.7 Social Media Companies

If the user contacts us through social media such as Facebook or Twitter, his data will be recorded and processed by these companies in parallel with us, in accordance with the respective applicable privacy policies.

 

7.8 Subject holding power of attorney provided by the user

Klarna will share the user's data on the basis of the consent given, if it has received a power of attorney from the user in favor of a third party. This sharing will be carried out on the basis of the user's consent.

 

7.9 Google

When the user uses the Klarna App through a browser, Google collects information on his device through the reCAPTCHA service implemented therein, sometimes in combination with any information entered in the reCAPTCHA service. Google will process this information in accordance with its own privacy policy. Klarna processes this data on the basis of its legitimate interest in carrying out its business, since the reCAPTCHA service prevents the abuse of its Services.

 

7.10 Authority

Klarna may communicate the necessary data to the police, tax or other authorities if required by law or by the user in certain circumstances. By way of example, communications required by law are those relating to anti-money laundering or terrorist financing prevention obligations.

 

7.11 Logistics and transport company

Klarna may share the user's personal data with logistics and transport companies for the delivery of goods or if the user has expressed the choice to track / monitor the shipment. By way of example, we may share contact details and identification data and the shipping number. Please note that logistics and transport companies will process the data in accordance with their own privacy policies.

 

7.12 Partners in the Personal Finance Service and in the Offers and Benefits program

If the user chooses to participate in offers and benefits (benefit) that Klarna provides in the Personal Finance Service or through the Offers and Benefits Program, Klarna may share personal data necessary to allow the user to access offers made in cooperation with our partners (this includes the fact that the user is a customer of Klarna). Information on what data is shared is provided with each offer. 

 

7.13 Debt collection agencies

Klarna will be able to share user data in the event of the transfer of outstanding credits to third parties or of assignment for the collection of such credits, for example to debt collection agencies. This sharing of personal data is carried out on the basis of our legitimate interest in carrying out the collection and assignment of credit. Debt collection agencies may process the user's personal data in accordance with their own privacy policies or on behalf of Klarna.

Debt collection agencies can also report the user's unpaid debt to credit reference agencies, which can affect his credit score and ability to obtain credit in the future.

 

7.14 Affiliate Networks

Klarna may share the information that the user has clicked on "sponsored links" (ie links that promote shops, products or services) with so-called "affiliate networks". This sharing occurs when you click on a sponsored link, as you are redirected to the store's website through the "affiliate network". The affiliate network may put a tracking technology on the user's device that contains the information that he clicked on a sponsored link in one of Klarna's interfaces, in order to track his visit to a store to calculate potential commissions. in Klarna. Affiliate networks may process your personal data in line with their own privacy policies.

 

7.15 Transfer 

  • If Klarna buys or sells a business unit or assets, it can share the user's personal data to the possible buyer or seller of the business unit or assets.

  • If Klarna itself or substantially its entire company is acquired by a third party, personal data of Klarna's customers may be shared.

 

8. Klarna stores your personal data

We are committed to the processing of personal data within the EU / EEA area. In certain circumstances, for example when we share your personal data with a Klarna Group company, supplier or subcontractor based outside the EU / EEA, your personal data may also be transferred and processed. in a location outside the EU / EEA area. If the shop where the user makes the purchase is located outside the EU / EEA area, the sharing of personal data with the shop will also involve the transfer of data outside the EU / EEA area.

We ensure that an adequate level of protection of personal data is maintained and that adequate protection measures are taken in accordance with applicable data protection legislation such as the GDPR, when your personal data is transferred outside the EU / EEA area. These safeguards consist in ensuring that the third country or the State in question is subject to an adequacy decision by the European Commission, or implements standard contractual clauses of the European Commission.

 

9. Duration of the processing of personal data

We process your data for the period of time necessary to achieve the purposes of the processing. These purposes are described in this Privacy Notice. Therefore, the user's personal data will be kept even if a purpose is no longer valid if so required for different purposes, and exclusively for the same. In particular:

  • if the user has accepted i Terms of Services Klarna and for the duration of validity of these Terms (by asking us or giving us instructions for deleting data for example by virtue of the right to erasure / to be forgotten), we will process the personal data necessary for the provision of the Services to you, including without limitation data relating to previous purchases; 

  • we process the user's personal data relating to credits in stock, for the purpose of new assessments of creditworthiness for a period of 90 days from the date of the search;

  • we process personal data relating to debts for the purposes of the new assessment of creditworthiness for a period of 3 years from the date of extinction of the debt by means of settlement, cancellation or assignment made by Klarna;

  • we keep telephone records for a period of 90 to ensure quality assurance;

  • we process the user's personal data in compliance with applicable laws, such as the legislation on consumer protection, banking, anti-money laundering and accounting. Depending on the applicable law, the user's personal data may be kept for a maximum period of 10 years from the conclusion of the relationship with the customer.

 

10. User rights with respect to their personal data

  • Right of access to information. The user has the right to obtain information on how their data is processed. We fulfill this obligation with this Privacy Policy, through the information available on the website and with our responses to requests sent to us by the user.

  • Right of access to data. The user can request a copy of their data if they want to know what data concerning them is. We can provide a copy of these data in electronic format (ie "data portability").

  • Right of rectification. The user has the right to obtain the correction of inaccurate or incomplete data concerning him.

  • Right to cancellation (to be forgotten). The user has the right to request the deletion of their personal data, for example when they are no longer necessary for the purposes for which they were collected or when consent has been revoked. As specified in paragraphs 3 and 9 above, Klarna must nevertheless comply with some legal obligations that prevent us from immediately deleting some of the user's personal data. 

  • Right to limit data processing or to object to data processing. If the user believes that the data is incorrect or that it is being processed illegally, these has the right to ask us to stop processing. The user can also oppose the treatment when he believes that there are circumstances that would make this treatment unlawful. Furthermore, the user can always oppose our use of his data for direct marketing.

  • Right to challenge an automated decision. The user has the right to contest an automated decision made by Klarna. See Section 6 for more information on how Klarna uses automated decisions.

  • Right to withdraw consent. As required by Section 5, in cases where Klarna processes the related data on the basis of your consent (explicit or not), the user can withdraw his consent at any time.

  • Rights to apply the instructions post-mortem. The user has the right to give (or designate the person authorized to do so) instructions on the retention, deletion and communication of personal data after death.

  • Right to lodge a complaint. The user has the right to lodge a complaint with a National Supervisory Authority or the Swedish Data Protection Authority. The complaint to the Swedish authority can be forwarded through the site https://www.datainspektionen.se/other-lang/in-english/.

  • Check the service settings. In the Klarna App, Klarna allows the user to customize preferences for certain Services, for example in reference to the ability to receive notifications or personalized commercial proposals. We will always respect the user's choices.

 

11. Cookies and other tracking technologies

We use cookies and similar tracking technologies to offer a pleasant and personalized experience in our interfaces online, as on our website, the Klarna App and the checkout of stores that cooperate with Klarna. The user can find information regarding the tracking methods used by Klarna, and accept or reject the tracking technologies in the related interface. 

 

12. Update of the Privacy Policy

We are constantly working to improve our offer of Services, in order to provide the user with an increasingly pleasant experience. This includes both changes to existing Services and the offering of new Services over time. For this reason, it is important to read this Privacy Policy every time you use a Klarna Service, as the processing of the user's personal data may be different from the last time the Services were used.

 

13. How to contact us

Klarna Bank AB (publ) is a company registered in the Swedish Commercial Register under number 556737-0431. Klarna's head office is at Sveavägen 46, 111 34 Stockholm (Sweden).

Klarna has a data protection officer and a team of data protection specialists exclusively dedicated to data protection and privacy. Klarna also has a dedicated team of customer support specialists for data protection matters. Further information can be requested by writing to datenschutz.ch@klarna.com

Klarna Bank AB (publ) is subject to Swedish data protection law. More information about Klarna is available on the website www.klarna.com.

The owner of the user's personal data is Klarna Bank AB (publ), a company subject to Swedish data protection law. For more information on Klarna visit the website https://www.klarna.com/international/.

 

Last updated: October 25, 2020