KLARNA PRIVACY POLICY

At Klarna we care about your privacy. We therefore collect and process personal information responsibly and with your privacy in mind. This Privacy Policy describes how Klarna Bank AB (publ) (“Klarna”) collects and uses your personal data when you use any Klarna service (the “Service” or collectively, the “Services”) and become a customer . Examples of our Services are when you make payments with one of our payment options, when you contact us, when you use the Klarna web portal and mobile application (the "Klarna Apps") or when your personal data is automatically entered into the moment of checkout . Furthermore, this Privacy Policy describes your rights regarding the processing of personal data and how to exercise them.

It is important that you read and understand the contents of this Privacy Policy which applies to all personal data that Klarna processes, except as provided in Section 1.

Some of our Services will provide you with access to content and functionality offered by 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 your personal data on 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) a company registered in the Swedish Company Register under number 556737-0431 and with its principal place of business at Sveavägen 46, 111 34 Stockholm (Sweden). For the purposes of European data protection law, we act as a data controller of personal data received from you, or otherwise relating to you and collected by us, and are responsible for our use of your data in accordance with applicable laws on data protection.

1. Learn more about Klarna privacy

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

If you are an employee of Klarna or have applied to work with us, or are employed at a store we co-operate with, Klarna's processing of your personal data is subject to other privacy notices and you will be provided with relevant information depending of the relationship that binds you to Klarna. Please contact us using the information in Section 13 below if you would like a copy of the relevant privacy notice that applies to you.

2. What data do we use?

2.1 The personal data you provide

You may provide us with information about you when you use a Klarna Service, such as when you choose a payment method from those offered by Klarna, when you contact us or use the Klarna App. Therefore, the user is invited to remember that for the correct provision of the Services it is necessary to provide their personal data .

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

Identification data and contact details – name, date of birth, tax code, educational qualification, billing and shipping address, e-mail address, mobile number, nationality, salary, audio recordings, photos and video recordings of you and your identity card etc. .
Payment details – data regarding credit or debit cards (card number, expiry date and CVV code), current account number, etc.
Special categories of data – the user may, at his/her complete discretion, provide us with information concerning him/her that constitutes "special categories" of personal data pursuant to EU Regulation 2016/679 (“GDPR”), which includes, for example, data regarding religious beliefs, political opinions or philosophical beliefs, trade union membership, data relating to health, biometric data or the person's sex 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 user's explicit consent. Please refer to paragraph 5 for information on how to revoke consent.

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

2.2. Personal data about you 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 reference agencies or fraud prevention agencies, credit rating agencies and databases). public consultation):

Identification data and contact details – name, date of birth, tax code, educational qualification, occupation, gender, billing and shipping address, e-mail address, mobile number, nationality, etc.
Information about goods and/or services – data regarding the goods or services purchased or ordered by the user, including, for example, the types of goods or shipment identification numbers.
Financial information – financial information collected by third parties regarding income, any loans, negative payment reports, a previous payment or acceptance of credit.
Information regarding the interaction between you and Klarna – how you use the Services, including data about your outstanding debts and debt history as well as your Klarna repayment history; technical data such as page response times, download errors, personal preferences; customer interaction with Klarna customer service etc.
Recorded telephone conversations – we record telephone conversations made by the user to customer service.
Information regarding the interaction between the user and the shops – the user's relationships with the store where he makes the purchases, such as information regarding the receipt of the goods and the type of store.
info about device – such as your 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 user.
Information from external lists relating to sanctions and politically exposed persons (PPEs) – we can analyze your data by comparing it with that on the lists of people 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 these lists.
Services-Specific Information : In order to provide you with some of our Services, we may collect and process additional personal data not covered by the categories above. 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.

Processing aimed at providing the Services

Purpose of the processing	Personal data	Legal basis of the processing
Manage the relationship with you/customer in a variety of ways, for example in relation to managing your payments or to fulfill our obligations under credit agreements with you.	Identity and contact details, payment details, information about goods and/or services, financial information, information relating to the interaction between you and Klarna, information relating to the interaction between you and stores, information about device , specific information about the Services.	Fulfill contractual obligations.
Create and send information in electronic format to you (not of a commercial nature).	Identity and contact details, payment details, information about goods and/or services, financial information, information relating to the interaction between you and Klarna, information relating to the interaction between you and stores, information about device , specific information about the Services.	Fulfill contractual obligations.
Evaluate the best channel to contact the user and inform him of outstanding debts.	Identifying and contact details, financial information (if available) and information regarding the interaction between you and Klarna.	Klarna has a legitimate interest in being able to contact you in the most efficient way. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Evaluate in which order the different payment methods should be presented to the user checkout of a shop. This processing and related presentation, however, do not affect the payment methods available to you. You can object to this at any time by contacting Klarna using the contact details provided below. This processing constitutes profiling. Please read Section 6 for more information on profiling.	Identifying and contact details, information about goods and services, information about the interaction between you and Klarna, and information about the interaction between you and the stores.	If you have accepted the Klarna Terms of Services set out in Section 4.4, the applicable legal basis is the performance of contractual obligations. However, if you have not accepted those terms, Klarna bases this processing on a legitimate interest, as Klarna (and you as a customer) have a legitimate interest in having your preferred payment method prominently checkout . We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Carry out fact-finding surveys with users/customers regarding their level of satisfaction with our Services (for example, after using Klarna's customer service) via email, text message, telephone or otherwise. 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 his email address or telephone number is used for this purpose.	Identification 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 stores.	Klarna has a legitimate interest in carrying out customer satisfaction surveys. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Conduct credit and fraud assessments to determine which payment methods we can offer to you based on Klarna's internal data.	Identity and contact data, information on goods/services and financial information (if already available internally), information regarding the interaction between the customer and Klarna and between the customer and the store, as well as device data.	Klarna has a legitimate interest in carrying out credit and fraud assessment activities to determine which payment method to offer you. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Carry out 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).	Identifying and contact details, financial information and information regarding the interaction between the customer and Klarna.	Comply with legal obligations if the provision of credit is regulated by legal provisions. In the absence of legal obligations to comply with, the processing takes place for the purpose of fulfilling contractual obligations.
Prevent cyber attacks (such as DDoS) directed at Klarna Services as part of our commitment to ensuring the continuity and security of our Services.	Identity and contact data, 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. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Ability to manage the client's vulnerability (if, due to personal circumstances, they are in a vulnerable position).	Identification data and contact details, information regarding the interaction between the user and Klarna, special categories of personal data.	Based on customer consent.
Improve our Services, to train our operators and guarantee the quality of services as well as document what has been agreed and decided between the user and Klarna customer service.	Recording of telephone conversations.	Klarna has a legitimate interest in improving its Services, and providing training and quality assurance. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Communicate your data to stores, suppliers and other parties. (Please refer to Section 7 for more information regarding how and why we share 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 purposes of providing the Services, has a legitimate interest in using suppliers and may be subject to a 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 user's identity and carrying out checks with fraud prevention agencies and similar). Please refer to paragraph 7 for a more specific description of the fraud prevention companies we cooperate with.	Identification 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 shops, special categories of personal data, info about device .	Klarna and other parties (in particular, its customers) have a legitimate interest in carrying out business risk management activities, for example addressing fraud risks. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed. Klarna also has legal obligations to establish the identity of its customers. Special categories of data are processed on the basis of your explicit consent.
Carry out activities related to debt collection (e.g. collection and assignment of debts).	Identity and contact details, information about 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 debt collection and assignment activities. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.

Product improvement and research

Anonymize your personal data for the purposes of analyzing customer behavior for product development.	Identity and contact details, payment details, information about goods and/or services, financial information, information relating to the interaction between you and Klarna, information relating to the interaction between you and stores, information about device , specific information about the Services.	Klarna has a legitimate interest in anonymizing your personal data for product development purposes for analyzing customer behavior. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Perform data analysis to improve and test products (for example, to improve models to prevent risk and fraud).	Identity and contact details, payment details, information about goods and/or services, financial information, information relating to the interaction between you and Klarna, information relating to the interaction between you and stores, information about device , information from external lists relating to sanctions and politically exposed persons (PPE), specific information on the Services.	Klarna has a legitimate interest in analyzing data for product development and testing. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Allow internal analyzes and the development of statistical models.	Identity and contact details, payment details, information about goods and/or services, financial information, information relating to the interaction between you and Klarna, information relating to the interaction between you and stores, information about device , specific information about the Services.	Klarna has a legitimate interest in enabling internal analyzes for the development of statistical models. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.
Allow external research, for example conducted by universities or other bodies.	Identity and contact details, payment details, information about goods and/or services, financial information, information relating to the interaction between you and Klarna, information relating to the interaction between you and stores, information about 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. We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.

Compliance and Mitigating Klarna's Exposure to Legal Action

Comply with applicable legislation, such as anti-money laundering and accounting regulations and related to compliance with capital adequacy requirements.

Identity and contact details, payment details, information about goods and/or services, financial information, information relating to the interaction between you and Klarna, information relating to the interaction between you and stores, information about device , information from external lists relating to sanctions and politically exposed persons (PPE), specific information on the Services.

Fulfillment of legal obligations.

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

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

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 enforcing its rights under the law.

We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.

Commercial offers

Provide customers with commercial proposals and offers regarding our services.

It is always possible for the user to opt-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 about the Services.

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

We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.

Select the commercial offers to provide to the user. This data processing ceases when the user opts out of receiving commercial offers.

Identity 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 the device , specific information about the Services.

Klarna has a legitimate interest in selecting the commercial offers to provide to you.

We ensure that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest overrides that of the user in not having their data processed.

Supply link sponsored to store products and services.

Information about products/services, information about the interaction between you and Klarna, information about the interaction between you and the stores, information about device and specific information about services.

Klarna has a legitimate interest in providing link sponsored 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 overrides your interest in not having your data processed.

4. Processing of specific personal data for certain Services

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

4.1 Klarna Credit Services

The following Services aim to provide credit to the user: Deferred payment (invoice), Immediate payment (in case of direct debit), Financing, the Klarna card and the disposable card (both available in 'App by Klarna). For the purposes of providing these Services we carry out a credit assessment of the user, 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 further information on our treatment of creditworthiness.

The Klarna card and disposable paper

When you apply 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 in relation to other Credit Services. credit. If the customer has the Klarna Card the customer's credit rating is constantly updated, and is based on the customer's interaction with Klarna.

We share data about you and your purchases when you use your Klarna Card with VISA and VISA members as necessary to process your card transactions, prevent fraud and follow applicable rules. If you renew your Klarna card or receive a new one, we transfer this information to VISA so that VISA informs third parties where you have stored your card details (for example in the case of recurring transactions).

Additionally, if you add your Klarna Card to your e-wallet, we may need to share your data with your e-wallet service provider as described in that provider's privacy policy.

4.2 You click 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 contact details about you that you provide 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 funds data. If you make transactions or payments to other accounts, Klarna will pass your name and account number to the recipient and the recipient's financial institution.

Additionally, if you have made payments to a Klarna account, Klarna will process data received from the bank you used for the transaction including your name and account number.

4.4 Klarna's user experience under the Terms of Services

In order to provide you with a smooth shopping experience before and after, Klarna offers the services described below, which are also described in more detail in the Klarna Terms of Services. The use of these Services involves the processing of the user's personal data as indicated below:

History of operations

We save information about the goods and services you purchase through our Services, or otherwise allow us to access, so we can display it to you.

Automatic filling of information

Auto-filling of users' contact information can be done in two ways: through user interaction and/or through cookies.

Autofill through user interactions

When you use the Services, we may ask for your identifying information and contact details, such as your name, address, telephone number, email, date of birth and/or identity card number. We will store this information in our systems and, upon your return, you will only need to provide some contact details such as telephone number, email, postcode or identity document (depending on the country) in order to allow us to fill in automatic the remaining fields with the additional data.

Autofill via cookie

An additional method of automatic data filling occurs through the installation of a Klarna cookie on the 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 Klarna platform. In this case we will use i cookies to import data already stored by Klarna when you use our services with them device . We will then automatically populate the data when you interact with Klarna.

Deactivating the autofill function

If you do not wish to use the autofill feature, you can contact us so that we can disable this setting. You can also change your settings directly through the Klarna App or during the purchase process in a store. Finally, the user can delete the cookies from your device, thus eliminating ours as well.

Pre-selected preferred payment methods

Klarna can determine your preferred payment method for purchases, and pre-select it for you. This procedure, however, does not affect the payment methods available to you. To this end, Klarna processes data from interactions between you and Klarna, such as data regarding your past payment methods, purchase, amounts and 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 benefits such as discounts, special events, product pre-sales, promotions, commercial offers, samples, freebies, etc., we take into consideration information relating to 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. Please refer to paragraph 6 for further information on profiling.

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

As part of the offers and benefits programme, Klarna, its suppliers and sub-contractors (on behalf of Klarna) may use this data to communicate offers and benefits to you by post, SMS, email , social media and other digital channels. Klarna and their respective suppliers and sub-suppliers will not use any channels of marketing directed for this purpose (e.g e-mail or text messages) if the user has expressed the opt-out to receive shares of marketing direct (i.e. if the user has not expressed the opt-in if the same is provided for by national legislation).

To express the opt-out to receive offers and benefits the user can unsubscribe via the link indicated in the emails sent by Klarna or by contacting Klarna (see paragraph 13).

The Klarna App

If you use the Klarna App, some additional personal data (for example, information uploaded by you based on your consent) will be processed in order to ensure the provision of the Services you decide to use within the Klarna App. App, as shown below. Additionally, when you choose to redeem rewards or participate in specific offers, the provider of those offers may deduct your use of Klarna's services. The personalization of content constitutes a profiling of user data, an integral part of the Klarna shopping assistance App online ; for more information see Section 6.

Personalized articles and adverts : you will be able to see personalized articles and adverts based on your previous purchases, contact details and identification data, data on goods or services, data relating to the interaction between you and Klarna, data relating to the interaction between the user and the stores, data relating to the device and specific data relating to the service.
Sponsored links : if the user clicks on a link sponsored that promotes a shop, product or service, you will be redirected to the shop's website via a third party, a so-called "affiliate network" (for further explanation see paragraph 7.14). The affiliate network may place tracking technology on the user's device containing data relating to the user's click on the 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.
Personalized Klarna overview : you can view the overview to consult 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 you have shared information, topics, products and services that you are generally interested in with Klarna, Klarna will use this information to provide you with personalized shopping collections, where you can find tailored products and services tailored to your interests.
Shipping and parcel tracking : the user can in some cases track the route of shipments.
Ability to "follow" stores : if the user decides to "follow" a store, he receives information on the offers linked to that store. Klarna will automatically assess whether those purchases qualify for access to discounts or other offers as part of the current offer.
Credit Services : We may offer credit to users based on previous purchases.
Shopping with a disposable card : Shopping through the Klarna App is one of the ways to use Klarna payment methods in almost any store through a disposable card. When you use your disposable card, Klarna collects information about your purchases and displays it to you on the App.
Customer support : When you contact support through or in connection with the Klarna App, we will have access to the information you provide.
Email Connect: if you have connected your email account to the Klarna Email Connect service, Klarna will regularly access your email account to extract other information relating to the goods and services and the interaction between you and the stores, in order to upload such information about the Klarna App. You can deactivate the service at any time by removing Klarna's access.
Find the shop: You can choose to share your location with Klarna, in which case you will allow us to use that information to show you nearby stores. You may revoke your consent by deactivating sharing on your device. Klarna will not retain your location after showing you stores.
The web browser in-app : The Klarna App contains a web browser where you can access store websites and online stores and then make purchases with Klarna payment methods even with stores that do not yet use our payment methods. Klarna collects information about your browser usage in order to provide you with relevant offers. Additionally, websites you visit may set their own cookies and other tracking technologies on your device.
Visual search : The user can choose to upload product photos, either by taking a photo of the product or choosing a photo from their phone's library, and Klarna will try to find products similar to those uploaded to display to the user.
Wishlist : You can choose to add products and services in the Klarna App to your Wishlist so you can find them later or track their prices. He can also share his Wishlist 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 in to a store's website, the link to a product or service you choose to add to your Wishlist may include personal information such as your email address.
Connected bank accounts (the Personal Finance Service): Using this service will allow the user to get an overview of their finances, including not only their transactions with Klarna, but also with connected bank accounts. When you choose to use this Service, Klarna will process information regarding your external account and other accounts (such as card accounts) that you choose to connect, and will collect personal data such as account number, bank, account transaction history, funds and available goods. Based on this data, Klarna will display and provide you with tools to control your finances through offers designed for your specific situation (based on profiling, as explained in paragraph 6). This is done by comparing your charges 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: You may choose to upload a profile photo to the Klarna App, in which case you are providing your consent for the image to be displayed in various Klarna interfaces (such as checkout of Klarna in a store, or in the Klarna App). Klarna interfaces can also be installed in store apps. The photo may also be shown to others if the user shares their device with others (using autofill through cookies ), or if you choose to share the content of your Klarna App with others. You may withdraw your consent at any time in accordance with paragraph 5, and Klarna will then delete the image.

5. Withdrawal of consent

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

Klarna makes the following decisions that have no legal or similar effect on you:

predict commercial content 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 benefits" for further information;
decide the most appropriate way to inform the user about his current 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 checkout in the store.

In addition, 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 to you relevant financial information or a range of offers, in accordance with the terms of the Service.

Decisions having legal effect or 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 result in a significant impact on you as a consumer. Through automated decisions, objectivity and transparency in decisions when offering those Services are increased.

We use this type of automated decision making when:

we decide to approve your request to use a Credit Service;
we decide not to approve your request to use a Credit Service;
we decide whether you are engaging in behavior that poses a risk of fraud or money laundering, if our processing operations reveal that your behavior is attributable to money laundering or fraudulent behaviour, or that your behavior the user is inconsistent with previous uses of the Service or in case of suspected and deliberate misrepresentation regarding his/her identity. Where appropriate, Klarna also checks whether or not a particular customer is on a so-called anti-money laundering list.

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

You always have the right to contest an automated decision that has legal or similar effect (together with related profiling) by contacting us via the email address set out in paragraph 13. A Klarna employee will then deal with the case .

7. Disclosure of User Information

We may need to share your 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 your personal data is treated with an adequate level of protection and in compliance with applicable law.

7.1 Suppliers and sub-suppliers

Klarna may share your personal data with the suppliers and sub-contractors it uses to provide the Services. Suppliers and sub-suppliers are companies authorized to process data received from Klarna or on behalf of Klarna. For example, software and data storage providers, payment processing providers and business consultants fall into this category.

7.2 Stores

Klarna shares personal data with the stores you visit or shop at (which may include the store's group companies if you have been informed about this by the store). This is to enable the store to execute and manage the purchase and administer the relationship with the store or its group, for example by verifying the identity of the customer, sending the goods, managing queries and disputes, sending relevant offers and preventing fraud. Personal data shared with a store will be subject to their privacy policies.

7.3 Payment Service Providers (“FSPs”) and Financial Institutions

FSPs provide stores and Klarna with services for accepting and processing electronic payments across a variety of payment methods, including credit cards, and payments by direct bank debit, bank transfers etc. Some stores use FSPs with which they share user data for payment processing. Sharing is carried out in compliance with the stores' privacy policies. Stores may also, for payment processing and administration, require us to share user information with FSPs. Some FSPs collect and use your data independently, in accordance with their respective privacy policies. This occurs for example if you use an electronic wallet.

Additionally, for the purpose of carrying out transactions, Klarna may share your data with other financial institutions when you make transactions with your account.

7.4 Credit rating agencies

If you apply to use a Credit Service (please refer to paragraph 4.1 for the specification of the relevant Credit Services), your personal data may be shared with credit reference agencies ("ARCs"). evaluate your credit score in relation to your credit application, to confirm your identity and contact details and to protect you and other customers from fraud. This sharing constitutes a credit check.

In Italy, Klarna sends your address, date of birth and tax code to credit agencies in order to receive a verification of your profile.

Our checks impact the creditworthiness agencies' assessment of your credit profile. Additionally, Klarna shares information about your repayments (including late repayments and undisputed missed payments) with credit bureaus, and this data may be included in credit default files, which may also influence the rating. carried out by credit rating agencies, and be consulted by third parties. The credit rating agencies process your data in accordance with their own privacy policies; Below you can find a list of the credit rating agencies with which we cooperate.

Your attention is drawn to the fact that Klarna only stores the credit assessment received from an ARC in data script format. It is therefore advisable to request a copy of the evaluation directly from the ARC if you wish to read it legibly.

7.5 Fraud prevention and identity verification agencies

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

7.6 Klarna Group Companies

Your data may be shared with other Klarna group companies based on Klarna's legitimate interests in conducting its business.

7.7 Social media companies

If you contact us via social media such as Facebook or Twitter, your data will be recorded and processed by these companies in parallel with us, in accordance with their applicable privacy policies.

7.8 Person holding power of attorney provided by the user

Klarna will share your data on the basis of your consent if Klarna has received a power of attorney from you in favor of a third party. This sharing will be done based on your consent.

7.9 Google

When you use Google Maps in checkout (for example, by searching for your address in the search section) or the Klarna App, Google will process your information subject to its terms of service and privacy policy. privacy of Google Maps/Google Earth. Additionally, when you use the Klarna App via a browser, Google collects information about your browser device through the reCAPTCHA service implemented therein, sometimes in combination with any information you enter into the reCAPTCHA service. Google will treat 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, as the reCAPTCHA service prevents the abuse of its Services.

7.10 Authority

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

7.11 Logistics and transport companies

Klarna may share your personal data with logistics and transport companies for the delivery of goods or if you have chosen to track/track your shipment. By way of example, we may share your contact information, identification data and tracking number. Please note that logistics and transport companies will process data in accordance with their own privacy policies.

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

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

7.13 Debt collection agencies and other purchasers of outstanding debts

Klarna may share your data if we assign your outstanding debts to third parties or assign them for collection of such debts, 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 credit collection and assignment activity. Debt collection agencies or any other acquirer may process your personal data in accordance with their own privacy policies or on behalf of Klarna.

Debt collection agencies or any other buyer may also report your unpaid debt to credit reference agencies, which may affect your credit score and ability to obtain credit in the future.

7.14 Affiliate Networks

Klarna may share information that you have clicked on link sponsored (i.e. links promoting 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 via the "affiliate network". The affiliate network may place tracking technology on your device that contains information that you have clicked on a sponsored link in one of Klarna's interfaces, in order to track your visit to a store to calculate potential commissions at Klarna. Affiliate networks may process your personal data in line with their own privacy policies.

7.15 Assignment

If Klarna buys or sells any credit, business or well, may share your personal data to the prospective buyer or seller of the credit, business or good .
If Klarna itself or substantially its entire business is acquired by a third party, personal data of Klarna customers may be shared.

8. Klarna's storage of your personal data

We are committed to ensuring that personal data is processed within the EU/EEA area. In certain circumstances, for example where we share your personal data with a Klarna Group company, supplier or sub-contractor based outside the EU/EEA, your personal data may also be transferred to and processed in a location outside the EU/EEA area. If the store where you make your purchase is located outside the EU/EEA area, sharing your personal data with the store will also result in the data being transferred outside the EU/EEA area.

We ensure that an adequate level of protection of your personal data is maintained and that appropriate protective 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 of ensuring that the third country or 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 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 Policy. Therefore, the user's personal data will be retained even if a purpose no longer exists if it is required for different purposes, and exclusively for the same ones. In particular:

if the user has accepted i Terms of Services Klarna and for the duration of these Terms (by asking or instructing us to delete data for example under the right to erasure/to be forgotten), we will process personal data necessary to provide the Services to you, including without limitation data relating to previous purchases;
we process the user's personal data relating to the credits in stock, for the purposes of new creditworthiness assessments for a period of 90 days from the date of carrying out the search;
we process personal data relating to debts for the purposes of reassessing creditworthiness for a period of 3 years from the date of settlement of the debt through settlement, write-off or assignment carried out by Klarna;
we keep telephone records for a period of 90 to ensure quality assurance;
we process your personal data in compliance with applicable laws, such as consumer protection, banking, anti-money laundering and accounting regulations. Depending on the applicable law, the user's personal data may be retained for a maximum period of 10 years from the conclusion of the relationship with the customer.

10. Your rights with respect to your personal data

Right to access information. The user has the right to obtain information on how their data is processed. We comply with this obligation with this Privacy Policy, through the information available on the website and with our responses to requests sent to us by you.
Right of access to data. The user can request a copy of their data if they want to know what data concerns them. We may provide a copy of this data in electronic format (ie, “data portability”).
Right of rectification. The user has the right to obtain rectification of inaccurate or incomplete data concerning him.
Right to erasure (to be forgotten). The user has the right to request the deletion of their personal data, for example when they are no longer necessary in relation to the purposes for which they were collected or when consent has been revoked. However, as set out in paragraphs 3 and 9 above, Klarna has certain legal obligations that prevent us from immediately deleting some of your personal data.
Right to limit data processing or object to data processing. If the user believes that the data is incorrect or is being processed unlawfully , these you have the right to ask us to stop processing. The user can also object to the processing when he believes that there are circumstances that would make such processing unlawful. Furthermore, you can always object to our use of your data for direct marketing.
Right to contest an automated decision. You have 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 set out in Section 5, where Klarna processes your data on the basis of your consent (whether express or otherwise), you may withdraw your consent at any time.
Rights to apply instructions post-mortem . You have the right to give (or designate the person authorized to do so) instructions on the storage, deletion and communication of personal data after death).
Right to lodge a complaint. You have 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/ .
Checking service settings. In the Klarna App, Klarna allows the user to customize preferences for certain Services, for example in relation to the possibility of receiving notifications or personalized commercial proposals. We will always respect your choices.

11. Cookies and other tracking technologies

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

12. Update of the Privacy Policy

We are constantly working to improve our offering of the Services, in order to provide you 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 that you read this Privacy Policy each time you use a Klarna Service, as our processing of your personal data may be different to the last time you used the Services.

13. How to contact us

Klarna Bank AB (publ) is a company registered in the Swedish Company 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 service specialists for data protection related matters. Further information can be requested by writing to privacy@klarna.co.uk.

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

The controller of your 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/ .