Privacy notice
How we handle personal data, why we hold it, and what you can ask us to do with it.
1. Who is responsible for your data
Ascendance AB, registration number 559584-9364, of Ringvägen 153 B, 116 31 Stockholm, Sweden, is the controller of the personal data described in this notice. PPWR Sweden is a business name of Ascendance AB. Contact us at info@ppwrsweden.com.
2. What we collect
When you contact us. Your name, email address, telephone number, the company you represent, and whatever you tell us in your message.
When you become a client. Contact and role details for the individuals we deal with, and the information needed to carry out the engagement. Packaging and volume data is generally commercial rather than personal data, but the correspondence around it is not.
Client due diligence. Identity documents, date of birth, nationality, ownership and control information, beneficial ownership details, sanctions and politically exposed person screening results, and information about the purpose of the engagement and the source of funds. We are required by law to collect this and cannot act for you without it.
When we act as your representative. Correspondence from Naturvårdsverket, producer responsibility organisations and other authorities addressed to you, which we receive, act on within our mandate, and forward.
Billing records. Invoices, payment details and related correspondence.
We do not buy personal data from third parties and we do not build marketing profiles.
3. Why we use it, and on what legal basis
- Answering enquiries
- Our legitimate interest in responding to someone who has contacted us about our services (Article 6(1)(f)).
- Providing our services
- Performance of our contract with you, or steps at your request before entering into it (Article 6(1)(b)). Where our client is a company, our legitimate interest in dealing with its representatives (Article 6(1)(f)).
- Acting as your representative
- Performance of the mandate, and compliance with obligations under Regulation (EU) 2025/40 and Swedish packaging legislation (Articles 6(1)(b) and 6(1)(c)).
- Client due diligence
- Compliance with legal obligations under anti-money-laundering legislation (Article 6(1)(c)).
- Accounting and tax
- Compliance with the Swedish Accounting Act and tax legislation (Article 6(1)(c)).
- Establishing or defending claims
- Our legitimate interest in protecting our legal position (Article 6(1)(f)).
4. Who we share it with
- Naturvårdsverket, where registration or reporting requires it
- Producer responsibility organisations, where affiliation requires it
- Supervisory authorities and the Swedish Police, where anti-money-laundering legislation requires a report
- Our IT, hosting and email providers, acting as processors under written agreements
- Our accountant and auditor
- Other companies in the Ascendance group, where your matter involves them
We do not sell personal data or share it for anyone else's marketing.
5. Where your data is held
Our website and email are hosted within the EU. Where a provider processes personal data outside the EU or EEA, we rely on an adequacy decision or on the European Commission's standard contractual clauses, with supplementary safeguards where required.
6. How long we keep it
- Enquiries that do not become engagements
- 12 months from our last exchange.
- Client due diligence records
- 5 years from the end of the engagement, as anti-money-laundering legislation requires.
- Accounting records
- 7 years, as the Swedish Accounting Act requires.
- Representation and reporting files
- 5 years after the end of the appointment, reflecting the retention periods in the regulation.
7. Your rights
You may ask us for a copy of the personal data we hold about you, to correct it, delete it, restrict how we use it, or provide it in a portable format. You may object to processing based on legitimate interest and withdraw consent where we rely on it.
Some rights are limited. Where we hold data because the law requires it, in particular client due diligence records and reporting files, we cannot delete it on request. We will tell you if that is the position.
To exercise a right, email us. We respond within one month and will say if we need longer.
8. Complaints
Tell us first and we will look into it. You also have the right to complain to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), Box 8114, 104 20 Stockholm, imy@imy.se.
9. Cookies and tracking
This website sets no cookies. We use no analytics, no advertising technology and no third-party tracking, and we embed no content that loads from other sites. Nothing here identifies you and there is nothing for you to consent to.
Our web host keeps standard server logs, including IP addresses, for security and operation. If we add analytics in future we will update this notice and ask for consent before any non-essential cookie is set.
10. Changes to this notice
We update this notice when our processing changes. The version and date at the top tell you which version you are reading.