1. Introduction

assetly (“Assetly,” “we,” “us,” or “our”) is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with:

• Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR)
• The Swedish Data Protection Act (Dataskyddslagen 2018:218)

This policy applies to personal data collected through our website and related communications.

‍

2. Data Controller

Assetly is the Data Controller responsible for the processing of personal data described in this policy.

Company details:
assetly
legal@assetly.se

‍

3. Personal Data We Collect

We may collect the following categories of personal data:

‍

3.1 Information You Provide

• First and last name
• Email address
• Company or organization
• Role or professional title
• Message content submitted via forms
• Budget ranges (if voluntarily provided)
• ‍

3.2 Technical Data

When you visit our website, we may collect:

• IP address
• Browser type and version
• Device information
• Pages visited
• Date and time of access

(Where required, such processing is subject to cookie consent.)

‍

4. Legal Basis for Processing (Article 6 GDPR)

We process personal data on the following legal bases:

‍

4.1 Legitimate Interest — Article 6(1)(f)

‍

To:

Respond to professional inquiries

• Evaluate potential business relationships
• Protect our business from misuse or fraud

We conduct balancing assessments where required.

‍

4.2 Pre-Contractual Measures — Article 6(1)(b)

Where processing is necessary to take steps prior to entering into a brokerage or advisory agreement.

‍

4.3 Legal Obligation — Article 6(1)(c)

Where required to comply with Swedish or EU law.

‍

4.4 Consent — Article 6(1)(a)

Where required (e.g., certain cookies or optional communications).

‍

5. Purpose of Processing

We process personal data for the following purposes:

• Handling inquiries
• Assessing domain acquisition or brokerage opportunities
• Conducting due diligence
• Communicating regarding potential engagements
• Maintaining business records
• Ensuring website security

We do not sell personal data.

‍

6. Data Sharing and Transfers

We may share personal data with:

• IT and hosting providers
• CRM and secure communication platforms
• Professional advisers (legal, accounting)
• Authorities where legally required

Where data is transferred outside the EU/EEA, we ensure appropriate safeguards such as:

• EU Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• ‍

7. Data Retention

We retain personal data only for as long as necessary to:

• Respond to inquiries
• Evaluate or manage business relationships
• Comply with legal obligations

Inquiry-related data that does not lead to engagement is typically retained for a limited period, unless further communication occurs.

Retention periods may vary depending on legal and contractual requirements.

‍

8. Security Measures

We implement appropriate technical and organizational measures to protect personal data, including:

• Access controls
• Encrypted communications (where applicable)
• Secure hosting environments
• Restricted internal access

However, no system can guarantee absolute security.

‍

9. Your Rights Under GDPR

Under GDPR, you have the right to:

• Request access to your personal data (Article 15)
• Request rectification (Article 16)
• Request erasure (Article 17)
• Request restriction of processing (Article 18)
• Object to processing based on legitimate interest (Article 21)
• Data portability where applicable (Article 20)
• Withdraw consent at any time (where processing is based on consent)

To exercise your rights, contact us using the details provided below.

You also have the right to lodge a complaint with:

Integritetsskyddsmyndigheten (IMY)
Sweden’s Authority for Privacy Protection
www.imy.se

‍

10. Automated Decision-Making

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects.

‍

11. Cookies

Our website may use cookies or similar technologies for:

• Website functionality
• Analytics
• Security

Where legally required, cookie processing is based on user consent.

Further details are provided in our Cookie Policy (if applicable).

‍

12. Confidentiality of Business Communications

Due to the nature of domain brokerage and advisory services:

• Communications may involve commercially sensitive information
• We handle inquiries with discretion
• Confidentiality obligations arise formally only where agreed in writing
• ‍

13. Updates to This Policy

We may update this Privacy Policy periodically to reflect legal, operational, or technical changes.

The latest version will always be available on this page.

‍

Effective Date: 07.05.2026

‍

Contact for Data Protection Matters:
legal@assetly.se
assetly

‍