1. Introduction
Besedo Global Services AB. (the ‘Controller’), a company registered under the laws of Sweden with company number 556673-5824, with registered address at Sveavägen 34, iOffice, 111 51 Stockholm, Sweden, is committed to protecting each visitor’s (‘Your’) personal data and information and comply with the General Data Protection Regulation and any applicable supplementary data protection legislation (‘Applicable Law’). The Controller strives for its services to be safe and enjoyable for everyone, and this Policy aims to help You understand what information the Controller might collect about You and how the Controller makes use of such information when You visit www.besedo.com including any of its sub-domains (Excluding Implio which is hosted on implio.com) and links hereon (the ‘Website’) and when accessing or using any service offered by the Controller through the Website, or which is available for download through third-party applications (‘Services’).
Any personal data that is provided to or gathered by the Controller through the use of the Website is controlled by the Controller, thereby acting as the data controller in terms of Applicable Law. The Controller is thus responsible for the collection and processing of personal data from the Website and ensures that Your personal data is processed fairly, lawfully, in accordance with good practice and collected only for specific purposes which are known and accepted by You when You make use of the Website and Services. The Controller seeks to adopt the best practices when it comes to the principles of personal data processing and email communication with You. This is in place in order to assure You that Your personal data is, at all times:
(i) processed in accordance with Your rights, in a fair and lawful manner;
(ii) obtained only for specific and lawful purposes;
(iii) adequate, relevant, and not excessive to its purpose;
(iv) kept in an accurate and updated form;
(v) stored securely; and
(vi) not kept longer than is necessary for the purpose.
2. When and what personal data is gathered
The Controller gathers and processes Your personal data in several situations, such as when You (i) visit the Webpage, (ii) request support or have questions, and/or (iii) participate in a survey. In the table provided below, the purposes for which the Controller processes personal data in connection to the Webpage is listed. The information gathered normally consists of contact information such as names, telephone numbers, addresses and/or e-mail addresses. It may also be technical information such as IP addresses, geolocation data, the type of browser You use.
Where personal data is gathered directly from You, the Controller will provide information on which personal data that is mandatory in order for the Controller to be able to fulfill its part of the agreement, e.g. to respond to queries.
3. Why and for how long personal data is processed and the legal basis therefor
The processing of personal data is permissible only where there is a specific purpose for the processing and an applicable so-called “legal basis”. Furthermore, the processing of personal data is permissible only for a limited period of time. The Controller will only process Your personal data for the purposes set forth below and at no time for any purpose that is incompatible with those purposes. Furthermore, the Controller will only process Your personal data for the period of time set forth in the column to the right in the table below. Please note that the Controller may be compelled to deviate from the time limits in the table in cases in which the Controller must process Your personal data in order to comply with applicable legislation. In such cases, however, the Controller will only process Your personal data to the extent such laws so require or make it necessary for the Controller to do so.
| Processing | Legal Basis | Storage Time |
| Customer service correspondence | ||
| If You forward any queries to the Controller, personal data may be retained by the Controller for customer service purposes, to keep records of the Controller’s relationship with You, to measure and improve customer service, and to investigate potential fraud and violations of the Controller’s terms and conditions. | Fulfillment of the Controller’s obligations towards You or, to the extent no agreement exists, the Controller’s legitimate interest to improve its business and investigate frauds and term violations. | The Controller stores its records of customer service correspondence for up to 1 year. |
| Direct marketing | ||
| The Controller may obtain contact details for electronic mail in relation to the sale of its products or its Services and therefore may use such details for direct marketing of its own similar products or services. In all correspondence, You will have the opportunity to unsubscribe from receiving direct marketing free of charge. | The Operator’s legitimate interest to conduct direct marketing to potential and existing customers. | If You have subscribed to the Operator’s e-mail send-outs, the Operator will keep your personal data until you unsubscribe. In all other cases records will be kept until legitimate interest has been disproven. |
| Surveys and questionnaires | ||
| The Controller may, from time to time, offer optional questionnaires and surveys for such purposes as market research, collection of demographic information or assessing Your interests and needs. The use of the information collected in such surveys will be explained in detail in the survey itself. If personal data is collected from You, and if the survey or questionnaire is not anonymous, You will be given notice of how the information will be used prior to Your participation in the survey or questionnaire. | The Controller’s legitimate interest to improve its business processes and to provide the customer with the most relevant Services. | To the extent survey or questionnaire results include personal data, such personal data is erased after 1 year. |
| Personalization, website traffic information and security. | ||
| The information gathered by the Controller helps the Controller personalize and continually improve the experience on the Website and the Services provided to You, understand the Website’s users and to manage the load on servers. The Controller uses the information to improve the Website infrastructure and Services that are offered, and to prevent or detect fraud or abuses. This may include information on the pages of the Controller’s Website that You visit, including, but not limited to, IP addresses, geolocation data, the type of browser You use, details of any links which direct You to the Website and the times You access the Controller’s Website. | The Controller’s legitimate interest to improve Your browsing experience. To the extent cookies are used for this purpose, Your consent is gathered in accordance with applicable cookie legislation. | Most settings will apply until You change or disable them. With regard to cookies, please see the more detailed information below. |
4. Personal Data Security
Your personal data which is stored at the Controller may only be accessed by the Controller’s employees as well as the affiliates of the Controller in possession of the required clearance. All persons who have access to such personal data are required to comply with the terms of this Policy and are contractually obliged to keep such information strictly confidential even after appointment within the Controller has been terminated.
The Controller is committed to implementing adequate organizational and technical security measures to protect Your personal data from illegal or accidental access, destruction, alteration, blocking, copying, distribution, as well as other illegal actions from third parties.
5. Shared Information
Information about You and other users is an important part of the Controller’s business and the Controller is not in the business of selling it to third parties. The Controller may however be required to release personal information when it is believed by the Controller that the release is appropriate or necessary to comply with the law or an enforcement order, to enforce or apply the Controller’s agreements or to protect the rights, property or safety of the Controller, the Controller’s users or third-parties, including for fraud protection and credit risk. This excludes selling, renting, sharing or otherwise disclosing Your personal data for commercial purposes in a way that is contrary to the commitments made in this Policy.
To ensure proper provision of Services, the Controller may transfer Your personal data to third parties that provide hosting services, services related to the sending of emails and similar service providers. These third parties have the right to use the received personal data for the sole purpose of providing the Services to You and are bound by the terms of this Policy and by other agreements that ensure the proper use of Your personal data which is furnished.
The Controller may further transfer Your personal data to any affiliates of the Controller for the purpose of appropriate and high-quality provision and improvement of the Website and the Services and for the performance of the Services and this Policy.
Other than as set out above, You will receive notice when information about You might be transferred to third parties, and You will have an opportunity to choose not to share such information. The Controller will only transfer personal data to a country outside the EU/EEA (a so-called “third country”) if such third country has an adequate level of personal data protection, or if such transfer is required for conclusion or performance of any Service requested by You, in accordance with the Applicable Law. Where none of the aforementioned applies, such transfer will normally be based on the EU Commission’s standard model clauses for such transfers. You may find them here.
6. Links to Third-Party Web Sites
The Website and Services may include third-party advertising and links to other websites and/ or services. The Controller does not provide any personally identifiable customer information to these advertisers or third-party linked websites who work on their own behalf. The Controller does not have access to or control over cookies or other features that they may make use of, and their information practices are not covered by this Policy.
7. Cookies
We use cookies to improve your experience on our website and to comply with privacy regulations like the GDPR and the Privacy Directive.
What Are Cookies?
Cookies are small text files placed on your device when you visit a website. They help us remember your preferences, understand how our site is used, and show the correct cookie banner based on your location.
Types of Cookies We Use
Strictly Necessary Cookies: These are essential for the website to work properly. They include cookies that store your consent preferences. These cookies do not collect any personal information.
Performance Cookies: These help us understand how visitors use our site. The data collected is anonymous and used only to improve the website.
How We Manage Consent
We use OneTrust to manage your cookie preferences. When you visit our site, a cookie is set to remember your choices. This cookie is anonymous and does not contain any personal data.
To show the correct cookie banner, OneTrust uses a geolocation service provided by Cloudflare. This service estimates your location (e.g., city level) using your IP address. This location data is not stored and is only used to apply the correct regional settings.
Your Choices
You can manage or disable cookies at any time through your browser settings. Please note that disabling cookies may affect how the website functions.
You can also change your cookie preferences or withdraw your consent at any time by clicking the “Cookie Settings” link at the bottom of the page.
For more details, please visit OneTrust.
8. Your Rights
Under Applicable Law, You are entitled to the following rights. Please note that all the rights are not unconditional. Therefore, an attempt to invoke one of the following rights might not lead to an action from the Controller. In addition to these rights, You may also lodge a complaint with the data protection supervisory authority.
- The right to access. You may request access to your personal data at any time. Upon request, the Controller will provide a copy of Your personal data in a commonly used electronic form.
- The right to rectification. You are entitled to obtain rectification of inaccurate personal data and to have incomplete personal data completed.
- The right to erasure (“right to be forgotten”). Under certain circumstances, You may request the Controller to delete Your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from the Controller.
- The right to object. You are entitled to object to certain processing activities conducted by the Controller in relation to Your personal data, such as the Controller’s processing of the personal data based on the Controller’s legitimate interest. The right to object also applies to the processing of Your personal data for direct marketing purposes.
- The right to restriction of processing. You may, under certain circumstances, request that the Controller restrict the processing of Your personal data.
- The right to data portability. You are entitled to receive the personal data (or have the personal data directly transmitted to another data controller) in a structured, commonly used, and machine-readable format.
Most of the personal data processing carried out on the Website is entirely voluntary and so is allowing cookies. You are, therefore, not obliged to provide personal data or enable cookies. Please note, however, that some functionality on the Website or in the Services may require or function more smoothly if You provide Your personal data or allow cookies.
9. Notices and Revisions
If You have any concerns about Your privacy, You are kindly requested to forward an e-mail to the Controller at privacy@besedo.com containing a detailed description of Your concerns. The Controller will do its best to resolve such issues within a reasonable time.
The Controller’s business changes constantly, and the Policy will thereby also change to take account of the new changes in the Website and Services. The Controller will provide notice by e-mail containing reminders of notices and updates unless You have instructed it not to.
Last updated: August 14, 2025
Related: Besedo publishing policy and Security FAQ