This Investor Privacy Notice explains how Klarna UK II plc (“Klarna”) uses personal data of its current and potential shareholders and investors.
1. Who is responsible for your private data?
Klarna UK II plc, a public limited company incorporated under the laws of England and Wales (registered number 14467769) and with registered office at 10 York Road, London (“Klarna”, “we”, “our” and “us”), is the data controller in accordance with the UK General Data Protection Regulation (the “UK GDPR”).
2. Your data protection rights as a data subject
You have several rights under the UK GDPR related to you having control of your personal data and to receive information directly from us on how we process personal data about you.
Please note that:
we may ask you for proof of identity when making a request to exercise your rights. We do this to ensure we only disclose information where we know we are dealing with the right individual; and
We may not always be able to do what you ask for, for example if it would be in contravention with applicable law, or it would impact the confidentiality we owe others.
We will assess your request reasonably promptly, before deciding what action to take. To exercise any of the above rights, or if you have questions relating to your rights, you can always reach us by sending your request to the address set out in Section 9.
Your rights
Subject to applicable law, you may have the following rights regarding the processing of your relevant personal data:
the right not to provide your personal data to us;
the right to request access to, or copies of, your relevant personal data, together with information regarding the nature, processing and disclosure of those relevant personal data;
the right to request rectification of any inaccuracies in your relevant personal data;
the right to request, on legitimate grounds:
erasure of your relevant personal data; or
restriction of processing of your relevant personal data;
where we process your relevant personal data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal data in reliance upon any other available legal bases); and
the right to lodge complaints regarding the processing of your relevant personal data with a competent data protection authority.
Subject to applicable law, you may also have the following additional rights regarding the processing of your relevant personal data: - the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the UK GDPR; and - the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes. |
3. What kind of personal data do we collect?
In this section, we describe the types of personal data that we collect or create about you as a shareholder or investor of Klarna. In section 4, we describe for what purposes we use these types of personal data.
Contact data – name, date of birth, address, email, phone number, contact details.
Verification of identity – personal ID number, national insurance number, or similar.
Role data – company, job title, role, and function.
Ownership data – details of your shareholdings and ownership interests in Klarna.
Investor status data - details on what type of investor you are.
4. What personal data are used for what purposes and with which legal basis?
In the context of investor relations, Klarna processes personal data for the purposes set out in the table below.
# | Purpose of the processing - what we do and why. | Type of personal data used for the purpose, and where they come from (the source). See section 3 to read more about the different types of personal data. | Legal basis for processing according to the UK GDPR. | When the purpose of using the personal data ends. See section 7 for when Klarna deletes the data. |
---|---|---|---|---|
I. | Investor relations, shareholder operations, and identity verification. | All categories of personal data mentioned in section 3. | The processing is based on a balancing of interests (Article 6(1)(f) UK GDPR). When balancing interests, Klarna has determined that we have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that our interest outweighs your right not to have your data processed for this purpose. You may contact us for more information about how the determination was made. See section 9 for our contact information. | See section 7 for more information on our obligations and right to retain information according to law. |
II. | To disclose personal data to the categories of recipients described in section 5. | All categories of personal data mentioned in section 3. | Varies depending on the recipient (see section 5). | See section 7 for more information on our obligations and right to retain information according to law. |
III. | To protect Klarna from legal claims and safeguard Klarna’s legal rights. | All categories of personal data mentioned in section 3. | The processing is based on a balancing of interests (Article 6(1)(f) UK GDPR). When balancing interests, Klarna has determined that we have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that our interest outweighs your right not to have your data processed for this purpose. You may contact us for more information about how the determination was made. See section 9 for our contact information. | See section 7 for more information on our obligations and right to retain information according to law. |
5. Who do we share your personal data with?
When we share your personal data, we ensure that the recipient processes it in accordance with this notice, such as by entering into data transfer agreements or data processor agreements with the recipients, in accordance with applicable law.
In the context of Klarna’s investor relations, we may share your personal data with:
your appointed representatives;
legal and regulatory authorities, upon such authorities requests, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
accountants, auditors, consultants, lawyers, and other outside professional advisors to Klarna, subject to binding contractual obligations of confidentiality, as well as third parties engaged by Klarna in connection with a contemplated IPO process, including regulatory authorities, or entities providing services necessary to safeguard the interests of the shareholders.
third party processors (including providers of services relating to the creation and maintenance of shareholder registers as well as investor services);
any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a re-organization, dissolution or liquidation); and
other companies in the Klarna group.
6. When can we transfer your personal data outside of the EU or the UK, and how do we protect it then?
We always strive to process your personal data within the EU/EEA area or the UK. But in certain situations, such as when we share your information within the Klarna group or with a service provider that operates outside the EU/EEA or the UK, your personal data may be transferred outside the EU/EEA or the UK, respectively. Klarna always takes reasonable steps to ensure that the same high level of protection applies to your personal data according to the UK GDPR, even when the data is transferred outside of the EU/EEA or the UK. Your rights in respect to your personal data (described in detail in section 2), are not affected when data is transferred outside of the EU/EEA or the UK. You can read more about the recipients with whom Klarna may share your personal data in section 5.
7. How long we store your personal data
Klarna retains personal data of its current and potential investors and shareholders for:
the duration of the relevant investment or shareholding;
plus any applicable periods required by additional periods necessary in connection with the purposes set out in this Investor Privacy Notice (including compliance with applicable legal requirements);
plus any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against Klarna in connection with your personal data, or to which your personal data are relevant);
plus an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, Klarna is afforded a reasonable amount of time in which to identify any personal data that is relevant to that claim).
Please note that even where we have a legal obligation to store your personal data, this does not necessarily mean that we are also permitted to use this data for any other purpose. Klarna will make an assessment for each specific purpose of how long we may use your personal data. You can read more about the purposes for which Klarna processes personal data in section 4.
8. Updates to this Investor Privacy Notice
We are constantly working to improve our services so that you have a smooth user experience. This may involve modifications of existing and future services. If that improvement requires a notice or consent in accordance with applicable law, you will be notified or given the opportunity to give your consent. It is also important that you read this Investor Privacy Notice every time you use any of our investor services, as the processing of your personal data may differ from your previous use of the service in question.
9. Klarna contact information
Klarna UK II plc (registered number 14467769) is located at 10 York Road, London, SE1 7ND, United Kingdom.
Klarna has a data protection officer and a number of data protection specialists. We also have a customer service team that handles data protection issues. You can reach all of these via
. If you want to reach Klarna's data protection officer, please state this in the subject field.Klarna UK II plc complies with UK data protection laws. Please visit
for more information about Klarna.