Klarna Privacy Policy

KLARNA

To offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

KLARNA’S PRIVACY NOTICE

We at Klarna care about your privacy. Therefore, we always collect and process your personal data responsibly and with your privacy in mind. This Privacy Notice describes how Klarna Bank AB (publ) (“Klarna”) collects and uses your personal data when you use any of Klarna’s services (the “Services”) and become a customer of ours. Examples of use of our Services are when you pay with any of our payment methods, when you contact us, when you use the Klarna web portal and mobile application (the “Klarna App”), or when your information is autofilled in the checkout of a store that uses Klarna. This Privacy Notice also describes your rights in relation to our use of your personal data, and how to exercise those rights.

This Privacy Notice applies, except for what is stated in Section 1 below, to all personal data that Klarna processes. It is therefore important that you read and understand this Privacy Notice.

Some of our Services will provide you access to content and functionality offered by other companies or organizations than Klarna (“Third Party Services”). This is for example the case when we link to third party sites from our websites, and when you access third party sites while using the web browser in the Klarna App. This Privacy Notice does not apply to the collection and use of your personal data in Third Party Services, and Klarna is not responsible for such third parties’ processing of your personal data.

"We", "our" or "us" means Klarna Bank AB (publ) registered with the Swedish companies register under the registration number 556737-0431 and with our main office located at Sveavägen 46, 111 34 Stockholm, Sweden. For the purposes of EU data protection law, we are a data controller in respect of the personal data we receive from you, or otherwise collect about you, and we are responsible for ensuring that we use your personal data in compliance with applicable data protection laws.

1. OTHER KLARNA PRIVACY NOTICES

The services Klarna Ident and Klarna Open Banking use your personal data in accordance with what is stated in those Services’ separate privacy notices, which are presented to you when you use those services. Those separate notices apply instead of the information given here. Separate privacy notices may also apply for specific campaigns or offers which are temporarily available. If so, such separate privacy notices are presented in connection with the campaign or offer.

If you are employed by Klarna, a candidate applying for a job at Klarna, or an employee of a store that cooperates with Klarna, other privacy notices apply to Klarna’s processing of your personal data for these purposes, and you will be provided the relevant information in connection to your contact with Klarna. Contact us using the information in Section 13 below if you want a copy of the relevant privacy notice.

2. WHAT INFORMATION DO WE USE?

2.1 INFORMATION YOU GIVE US

You may give us information about yourself when you use one of Klarna’s Services, for example when you choose to pay with one of Klarna’s payment methods, contact us, or use the Klarna App. Please note that you are only allowed to provide your own personal data when using the Services, for the Services to be provided correctly.

Depending on which Service you choose to use, this personal data will be:

Contact- and identification information – name, date of birth, national ID number, title, billing and shipping address, email address, mobile phone number, nationality, salary, employment and employment history, audio recordings, photos and video recordings of you and your ID card etc.

Payment information – credit and debit card data (card number, validity date, and CVV code), bank account number, etc.

Special categories of data – you may, at your sole discretion, choose to provide us information about you which constitutes “special categories” of personal data according to EU Regulation 2016/679 (the “GDPR”), including e.g. data revealing religious, political or philosophical beliefs, trade union membership, or data concerning health, biometric data, sex life or sexual orientation. We will never require this type of data from you in order to provide you with our Services. Providing us with this information will be strictly voluntary and based on your explicit consent. Please see Section 5 for information about how you can revoke your consent.

You can at any time change your profile information such as your contact information and other editable settings. This can be done either in the Klarna App or by contacting us.

2.2 INFORMATION WE COLLECT ABOUT YOU

Depending on which Services you choose to use, we may collect the following information about you, either ourselves or via third parties (for example credit and fraud prevention agencies, stores, or public databases):

Contact- and identification information – name, date of birth, national ID number, title, occupation, gender, billing and shipping address, email address, mobile phone number, nationality, audio recordings, photos and video recordings of you and your ID card etc.

Information on goods/services – details about the goods/services you purchase or order, including for example type of goods or shipment tracking number.

Financial information – financial information collected from third parties such as your income, potential credit commitments, negative payment remarks, previous payment- and credit acceptances.

Information about the interaction between you and Klarna – how you use the Services, including information on outstanding and historical debts and your repayment history with Klarna; technical data such as page response times, download errors, personal preferences; your interactions with the Klarna customer service, etc.

Recorded telephone conversations – we record telephone conversations if you call our customer service, and sometimes when we call you, if we inform you about this at the start of the call.

Information about the interaction between you and stores - your dealings with stores you visit or shop with, such as information about whether you have received the goods, and type of store.

Device information – e.g. IP address, language settings, browser settings, time zone settings, operating system and platform and screen resolution. To learn more about how we may collect information from your device, or store information on your device, please see Section 11 below.

Information from external sanction lists and PEP lists – we may screen your information against lists of persons subject to sanctions, and lists of persons who are so called Politically Exposed Persons. These lists include information such as name, date of birth, place of birth, occupation or position and reason for being listed.

Service-specific information – in order to provide you with some of our Services we may collect and process additional personal data that is not covered by the above categories. Please see Section 4 below in order to find out which additional personal data is processed for the respective Service.

3. WHAT PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSE, AND WHY IS IT LAWFUL FOR US TO DO SO?

Depending on which Services you use, Klarna may process your personal data for the purposes listed below, based on the legal bases stated for each respective purpose. You can find more specific information about how we process your data in some of our Services in Section 4 below.

Processing in order to provide the Services

Purpose of the processing

Personal data

Legal basis for the processing

Administer the customer relationship with you in different ways, for example to process your payment or carry out our obligations arising from credit contracts entered into between you and us.

Contact- and identification information, payment information, information on goods/services, financial information, information about the interaction between you and Klarna, information about the interaction between you and stores, device information, and service-specific information.

Fulfil contractual obligations.

Create and send information to you in electronic format (non-marketing).

Fulfil contractual obligations.

Assess which is the most suitable way to contact you to inform you about outstanding debts.

Contact- and identification information, financial information (if we have this available) and information about the interaction between you and Klarna.

Klarna has a legitimate interest in being able to contact you in the most effective way.

We ensure that the processing performed for this purpose is necessary for fulfilling our legitimate interest, and that our interest outweighs your interest in not having your personal data processed for this purpose.

Assess in which order different payment methods should be presented to you in the checkout of a store that uses Klarna. This processing and presentation do not, however, affect which payment methods are available to you.

You can opt out from this at any time by contacting us using the contact details below.

This processing constitutes profiling. Please see Section 6 for more information on profiling.

Contact- and identification information, information on goods/services, information about the interaction between you and Klarna, and information about the interaction between you and stores.

If you have accepted the Klarna Services Terms outlined in Section 4.4, the applicable legal basis is to fulfil contractual obligations.

However, if you have not accepted those terms, Klarna base this processing on legitimate interest, as Klarna (and you as a customer) have a legitimate interest in having your preferred way of paying presented in a prominent position in the checkout.

Conduct customer satisfaction surveys regarding our Services (for example after you have contacted Klarna’s customer service) via email, sms, phone, or through other means.

You can object to this at any time. You will also be informed about your right to opt-out from these communications every time your email or phone number is used for this purpose.

Contact- and identification information, information on goods/services, information about the interaction between you and Klarna, and information about the interaction between you and stores.

Klarna has a legitimate interest in conducting customer satisfaction surveys.

Carry out credit- and fraud assessments for the purpose of assessing which payment methods to offer you, based on a limited lookup from an external credit reference agency (Please see in Section 7.4 how we cooperate with credit reference agencies).

Contact- and identification information, information on goods/services, financial information (if already internally available), information about the interaction between you and Klarna, and information about the interaction between you and stores, as well as device information.

Klarna has a legitimate interest in carrying out credit- and fraud assessments for the purpose of assessing which payment methods to offer you.

Carry out credit assessment before granting credit (Please see Section 4.1 on Klarna’s credit Services and Section 7.4 regarding how we cooperate with credit reference agencies).

Contact- and identification information, financial information and information about the interaction between you and Klarna.

Comply with laws, when the credit we provide is regulated by law. In cases when the credit is not regulated by law, the processing is done to fulfil contractual obligations.

Prevent IT attacks (for example DDoS attacks) toward Klarna’s Services, as part of our efforts to keep our Services safe and secure.

Contact- and identification information, information about the interaction between you and Klarna, information about the interaction between you and stores, as well as device information.

Klarna has a legitimate interest in keeping our Services safe and secure.

To be able to treat you as a vulnerable customer (if you due to personal circumstances are in a vulnerable position).

Contact- and identification information, information about the interaction between you and Klarna, and special categories of personal data.

Based on your consent.

Improve our Services, training and quality assurance, as well as documenting what has been discussed and decided between you and Klarna’s customer service.

Recorded telephone conversations.

Klarna has a legitimate interest in improving our Services, and in conducting training and quality assurance.

Transfer your data to stores, suppliers and other recipients. (Please see Section 7 for more information on how we share your data and why).

All of the personal data categories under Section 2.

Varies depending on recipients, see more in Section 7. For example, Klarna has a legitimate interest to use suppliers to provide its Services, and we may have legal obligations to share data with authorities. Data sharing with payment service providers is necessary to carry out the payment contract with you.

Carry out risk analysis, fraud prevention and risk management (for example through verifying your identity, and carry out checks with fraud prevention agencies and similar agencies).

Please see Section 7 for a more detailed description of the fraud prevention companies we cooperate with.

Contact- and identification information, payment information, information on goods/services, financial information, information about the interaction between you and Klarna, information about the interaction between you and stores, special categories of personal data and device information.

Klarna and other parties (foremost our customers) have a legitimate interest in risk management of Klarna’s business, for example handling fraud risks.

Klarna also has legal obligations to establish its customers’ identities.

Special categories of data are processed based on your explicit consent.

Perform debt collection services, i.e. to collect and sell debt.

Contact- and identification information, information on goods/services, financial information, information about the interaction between you and Klarna and information about the interaction between you and the stores.

Klarna has a legitimate interest in collecting and selling debt.

Product improvement and research

Anonymise your personal data for product development in order to analyse customer behaviour.

Klarna has a legitimate interest in anonymising your personal data for product development in order to analyse customer behaviour.

Perform data analysis for product improvement and product testing (for example to improve risk- and fraud models).

Klarna has a legitimate interest in performing data analysis for product improvement and product testing.

Enable internal research and creation of statistical models.

Klarna has a legitimate interest in enabling internal research and to create statistical models.

Enable external research, for example by universities or other bodies.

Klarna has a legitimate interest in enabling external research, and contributing to the general interest of society to support research.

Compliance and to protect Klarna from legal claims

Comply with applicable laws, such as anti-money laundering and bookkeeping laws, and regulatory capital adequacy requirements.

Comply with laws.

Perform screening against lists of persons subject to sanctions, and lists of persons who are so called Politically Exposed Persons.

Contact- and identification information, information from external sanction lists and PEP lists.

Comply with laws.

Protect Klarna from legal claims, and enforce Klarna’s legal rights.

All of the personal data categories under Section 2.

Klarna has a legitimate interest in protecting itself from legal claims, and in enforcing its legal rights.

To provide marketing

To provide marketing and offers regarding our Services to you.

You may always opt out by contacting us, see Section 13.

Contact- and identification information, information about the interaction between you and Klarna, information about the interaction between you and stores, and service-specific information.

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

To decide which marketing to provide you. This processing also ceases when you opt out from receiving marketing.

Contact- and identification information, information on goods/services, information about the interaction between you and Klarna, information about the interaction between you and stores, device information, and service-specific information.

Klarna has a legitimate interest in deciding which marketing to provide you.

To provide links that are sponsored to products and services of stores.

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

Klarna has a legitimate interest in providing links that are sponsored to promote stores in the Klarna App and on our website.

4. SERVICE-SPECIFIC PROCESSING OF PERSONAL DATA IN SOME OF KLARNA’S SERVICES

This Section sets out certain processing of your personal data which is specific for certain Services. To learn more about our Services, and their included features, please consult the terms and conditions of the respective Service.

4.1 KLARNA’S CREDIT SERVICES

The following Services involve us giving you a credit: Pay later (invoice), Pay now (if it involves direct debit), Financing, as well as Klarna Card and the one time card (both available in the Klarna App). To provide these Services, we do a credit assessment of you. The credit assessment is based on contact- and identification information you have provided, information about the interaction between you and Klarna, and financial information. The financial information includes externally obtained information from credit reference agencies, such as income and payment remarks. You can read more about our use of credit reference agencies in Section 7.4 below.

THE KLARNA CARD AND ONE TIME CARD

When you apply for the Klarna Card and the one time card (available in the Klarna App), Klarna conducts a credit assessment of you, as we do for our other credit Services. If you have the Klarna Card, Klarna then continuously updates our credit assessment of you based on your interactions with Klarna.

We share information about you and the purchases you make when using the Klarna card with VISA and members of the VISA card network, as far as this is necessary to carry out the card transactions, prevent fraud, and follow applicable rules. If you renew your Klarna Card or receive a new one, we will transfer this information to VISA in order for VISA to inform third parties with whom you have stored your card details (for example for recurring transactions).

If you add your Klarna Card to a digital wallet, we may need to share your data with the digital wallet provider, in line with that provider’s privacy notice.

4.2 OFFERS AND EVENT INVITATIONS POSTED ON SOCIAL MEDIA

If you have clicked on one of our offers or event invitations posted on social media, we may get access to contact information which forms part of your profile (for example your name, email address, telephone number and other relevant business information such as the name of your employer, its address, and type of business). We use this information to supply you with the requested Service, and to supply you with marketing and offers about our Services. You can always opt out from this by contacting us, see Section 13.

**4.3 The Klarna accounts (savings and payment accounts) **

If you have a Klarna account, Klarna will also process information about your transactions and information about your funds. If you make transactions or payments to other accounts, Klarna will forward your name and account number to the recipient and the financial institution of the recipient.

Furthermore, if you have made payments into a Klarna account, Klarna will process information received from the bank you used for the transaction, such as your name and account number.

4.4 THE KLARNA USER EXPERIENCE DELIVERED UNDER THE KLARNA SERVICES TERMS

To be able to deliver a smoooth user experience, both before and after you have done a purchase, Klarna offers the Services described below, and which are also described in more detail in the Klarna Services Terms. The use of these Services involves the following processing of your personal data:

Historical transactions

We save information about the goods/services you purchase using our Services, or otherwise choose to give us access to, in order to display this information to you.

Autofill of your information.

Autofill of your information can be done in two ways – through your interaction and / or through a cookie:

Autofill through your interaction

When you use the Services, we may ask for your contact- and identification information, such as name, address, telephone number, email, birth date and/or national ID number, as well as other information as applicable. We will keep this information in our systems, and when you return to us or use our Services you will only need to provide some information such as phone number, email, zip-code, or national ID number (dependent on the country) in order for us to autofill the remaining fields with your other details.

Autofill through cookie

An additional method we may use to autofill your information is by placing cookies on your device (computer, tablet, mobile phone, etc.), which enable you to choose to save your information such as name, address, telephone number, email, date of birth, national ID number, and card details with Klarna. If you do so, we then use the cookie to fetch those details from Klarna when you use our Services with the same device. We will then autofill your details when you interact with Klarna.

Deactivation of Autofill

If you don’t want to use the autofill functionalities you can contact us to adjust your settings. You can also adjust your settings in the Klarna App directly or in the purchase process at a store. You can at any given time delete cookies on your device, which will delete our cookies as well.

Preselected preferred payment methods

Klarna can assess which payment method is your preferred way of paying when shopping, and preselect this payment method for you. This processing and presentation does not, however, affect which payment methods are available to you. For this assessment, Klarna processes information about the interaction between you and Klarna, such as information about your previously selected payment methods, purchase amount(s) and store. This processing constitutes profiling. Please see Section 6 for more information on profiling.

Offers and benefits

To be able to offer you benefits such as discounts, special events, pre-access to products, sales promotions, store offerings, sampling, giveaways, etc, we look at information about the interactions between you and Klarna (such as the number of purchases under a certain time period), your contact- and identification information, information on goods/services, and information about the interaction between you and stores. This may involve profiling. Please see Section 6 for more information on profiling.

The information will form the basis for Klarna’s marketing and customer analytics, business- and method development, as well as statistics.

Within the offers and benefits program, Klarna and Klarna’s suppliers and subcontractors (on Klarna’s behalf), may use this information to communicate with you and deliver offers and benefits, via physical mail, text messages, email, social media and other digital channels. Klarna and its suppliers and subcontractors will not use any direct marketing channel for this purpose (e.g. email or text-messages) if you have opted out from direct marketing (respectively if you have not opted in, if that is legally required in your country of residence).

You can opt out from offers and benefits either by deregistering using the link provided in each email from us, or by contacting us, see Section 13 below.

THE KLARNA APP

If you use the Klarna App, additional personal data will be processed to provide the Services you choose to use within the Klarna App, as set out below. Furthermore, when you choose to redeem rewards or take part in specific deals, the provider of such offers may be able to deduce your use of Klarna’s services.

Personalized articles and ads: you will be able to see personalized articles and ads based on your previous purchases, contact and identification information, information on goods or services, information about the interaction between you and Klarna, and information about the interaction between you and stores, device information and service-specific information.

Links that are sponsored: if you click on a link that is sponsored and that promotes a store, product or service, you will be redirected to the store’s website through a third party, a so-called “affiliate network” (further explained in Section 7.14). The affiliate network might place a tracking technology on your device that contains the information that you clicked on such a link in the Klarna App which is then used to track your visit to a store in order to calculate a potential commission to Klarna.

Personalized Klarna overview: an overview is displayed, where you can view the status of your Klarna purchases and view your purchase history, access potential refunds, settle payments and extend your payment terms.

Curated shopping collections: If you have shared with us information about what topics, products and services you are generally interested in, we will use this information to provide you with personalized shopping collections, where you may find products and services tailored to your interests.

Delivery and parcel tracking: you may in some cases be able to track the route of your parcel.

Possibility to “follow” stores: if you choose to “follow” a store, you receive information about campaigns connected to that store. Klarna will then automatically assess whether your purchases entitles you to discounts or other offers within that store’s ongoing campaign.

Credit Services: we may offer you credit based on previous purchases.

Shopping with the one-time card: shopping through the Klarna App is a way of using Klarna’s payment methods in almost any store, through a one time card. When you use the one-time card, Klarna will collect information about your purchases and show them in the app.

Customer service: when you contact the Klarna customer service through the Klarna App we will have access to the information you provide.

Email Connect: If you have connected your email account to Klarna’s Email Connect service, Klarna will regularly access your email account and extract purchase related information such as tracking ID’s and other information about goods and services and the interaction between you and stores, in order to populate this information into the Klarna App. You may at any time turn this service off, thereby removing Klarna’s access.

Store locator: You can choose to share your location with us, in which case we will use this information to show stores close to you. You may at any time turn off this sharing in your device. Klarna will not keep your location after we have shown the stores to you.

The in-app web browser: The Klarna App contains a web browser in which you may access stores’ websites and online shops in order to then shop using Klarna’s payment methods also with stores that do not yet use our payment methods. Klarna collects information about how you use the browser in order to provide you with relevant deals and offers. Furthermore, websites you visit may set their own cookies and other tracking technologies on your device.

Wishlist: You can choose to add products and services in the Klarna App to your Wishlist, in order to find them later, or track their prices. You may also share your Wishlist with other people such as friends and family, and they will then be able to see your profile picture and profile name. 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 about you from that website, such as your email address.

Your connected bank accounts (the Personal Finance Service): Using this Service will allow you to get an overview of your finances, including not only your transactions with Klarna, but also your connected bank accounts. When you choose to use this Service, Klarna will process information about the external bank accounts and other accounts (such as card accounts) which you choose to connect, and collect personal data such as account number, bank, historical transactions on the account and funds and assets available. Based on this data, Klarna will visualise and provide you tools to control your finances by way of offers tailored to your specific situation (based on profiling, as explained in Section 6). This is done by comparing your expenses with the expenses of other users of the Service. Based on this comparison, we, together with our partners, can offer ways of minimising your fixed and non-fixed costs.

Profile picture: You can choose to upload a profile picture in the Klarna App, in which case this picture may be shown in various Klarna interfaces (for example in the checkout of a store that uses Klarna, or in the Klarna App). Klarna’s interfaces may also be embedded in stores’ apps. The picture may also be shown to others if you share your device with others (while using autofill through cookies), or if you choose to share content from your Klarna App with others. You may at any time erase your picture in the App or by contacting us.

5. REVOKING CONSENT

In cases where Klarna processes your personal data based on your consent or explicit consent (for example if you submit a Power of Attorney, allowing another individual to access your data, in case you provide us information indicating that you are a vulnerable customer, or in case you upload special categories of personal data into our Services), you can at any time revoke this consent, either by contacting us or by deleting your uploaded data in the Klarna App. Revoking consent will not lead to any detriment for you, as we do not require this type of information to provide our Services.

6. KLARNA’S PROFILING AND AUTOMATED DECISION MAKING

“Profiling” means automated processing of personal data to evaluate certain personal aspects relating to you, for example in order to analyse or predict aspects of your financial situation or your preferences, such as purchase interests. We use profiling based on the personal data we have about you in order to take individual or automated decisions about you, for the following purposes:

Decisions without legal or similarly significant effect

Klarna makes the following decisions without legal or similarly significant effects for you;

Predicting what marketing content would be of interest to you. You can always object to this and deregister from the marketing and this profiling, by contacting us. For further information about our processing of personal data for marketing purposes, see Section 3 above);

Deciding what loyalty bonuses would suit you (See Section 4.4 Offers and benefits above for further information);

Deciding on the most suitable way to contact you concerning outstanding debt (see Section 3 for further information);

Deciding which content to display to you in the Klarna App. See Section 4.4 The Klarna App for further information.

Deciding in which order different payment methods should be presented to you in the checkout of a store that uses Klarna.

In addition, some of our Services (such as when you connect bank accounts and similar accounts in our Klarna App), use profiling in order to deliver the applicable Service to you, for example delivering relevant financial insights to you, or to select which offers to give you, in accordance with the terms of the relevant Service.

Decisions with legal or similarly significant effect

Automated decision making with legal effects, or automated decisions with similarly significant effect, means that some decisions in our Services are solely based on automatic means, without any interaction from any of our employees, and carry a significant impact on you as a consumer with them. By making such decisions in an automated fashion, Klarna increases objectivity and transparency in the decisions when offering those Services.

We use this type of automated decision making when we:

Decide to offer you our credit Services, and subsequently grant you a credit;

Decide not to offer you our credit Services;

Decide whether you pose a fraud- or money laundering risk, if our processing reveals that you display behaviour consistent with money laundering or fraudulent conduct, that your behaviour is inconsistent with your previous use of our Services, or that you appear to have deliberately hidden your true identity. In relevant cases, Klarna also checks whether or not a specific customer is listed on a so called sanction list.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details in Section 13 below.

See Section 3 for further information on the types of personal data processed for these purposes.

You always have the right to challenge an automated decision which carries a legal or similarly significant effect (together with the profiling connected to it), by contacting us using the email address referred to in Section 13 below. A Klarna employee will then look at your case.

7. WHO MIGHT WE SHARE YOUR PERSONAL DATA WITH?

We may share your personal data with the categories of recipients listed below, for the purposes listed below. Exactly which recipients we share your personal data with, and for which purposes, will depend on which Service you use. When we share your personal data, we take all reasonable contractual, legal, technical, and organisational measures to ensure that your personal data is treated with an adequate level of protection and in accordance with applicable law.

7.1 SUPPLIERS AND SUBCONTRACTORS

Klarna may share personal data with the suppliers and subcontractors we use in order to provide our Services to you. Suppliers and subcontractors are companies who are only entitled to process the personal data they receive from Klarna on Klarna’s behalf. Examples of such suppliers and subcontractors are software- and data storage providers, payment processing services, and business consultants.

7.2 STORES

Klarna shares personal data with the stores you visit or purchase from (which may include the stores’ group companies if you have been informed about this by the store). This is done in order to allow the store to execute and administer your purchase, and administer your relationship with the store or its company group, for example by verifying your identity, send you the goods, manage questions and disputes, send relevant marketing and prevent fraud. The personal data shared with a store will be subject to the store’s privacy notices and practices.

7.3 PAYMENT SERVICE PROVIDERS (“PSPS”) AND FINANCIAL INSTITUTIONS

PSPs provide stores and Klarna with services for accepting electronic payments through a variety of payment methods including credit card, and bank-based payments such as direct debit, bank transfers, etc. Some stores use PSPs with which they share your information for the processing of payments. This sharing is done in accordance with the stores’ own privacy notices. The stores may also, for the processing and administration of payments, require us to share your information with the PSPs. Some PSPs also collect and use your information independently in accordance with their own privacy notices. This is for example the case if you use a digital wallet.

In addition, Klarna may share your information with other financial institutions when you conduct transactions with your account, in order to perform the transactions.

7.4 CREDIT REFERENCE AGENCIES

A limited lookup (i.e. a “soft lookup”) may be conducted at a Credit Reference Agency (“CRA”) before you apply for one of Klarna’s payment methods in the checkout, to assess your creditworthiness for the purpose of tailoring the payment methods offered to you. This will happen either as you enter your name, address, phone number, and date of birth in the checkout and continue, or directly when the checkout is loaded if the store transfers this information to Klarna. This limited lookup will not affect your creditworthiness.

If you apply to use a credit Service (see Section 4.1 above for a specification of our credit Services), your personal data may also be shared with CRAs to assess your creditworthiness in connection with your application, to confirm your identity and your contact information, and to protect you and other customers from fraud. This sharing also constitutes further soft credit lookups which does not affect your creditworthiness.

Furthermore, a hard credit search (or “a hard credit lookup”) is performed when you apply for Financing, as well as a soft lookup to assess affordability. In order to perform the hard credit search, Klarna will send the CRAs your name, address, date of birth, phone number, as well as bank account number and sort code if relevant, in order to receive the lookup on you.

This hard credit search will affect your credit rating as follows:

The CRA will keep a record of our enquiry against your name and which may be linked to your representatives (“associated records”). For the purposes of any application for Services from us, you may be assessed with reference to “associated records”. Where any search or application is completed, or agreement entered into, involving joint parties, we may record details about this at the CRAs. As a result an “association” will be created that will link your financial records. Details of which CRA we have used for a specific search are available on request. We may also add to your (or, if applicable, your business’) record with the CRAs information in the form of; details of your agreement with us, any payments you make under it, and any default or failure to keep to its terms. These records will remain on the CRAs’ files for 6 years after our agreement with you is settled or terminated, whether settled by you or, if applicable, your business or by way of default. This and other information about you (or, if applicable, your business and those with whom you are linked financially) may be used to make credit decisions about you or your business in the future.

The identities of the CRAs, and the ways in which they use and share personal data, are explained in more detail at https://www.transunion.co.uk/crain and https://www.experian.co.uk/crain. The CRAs will process your information in accordance with their own privacy notices and you can find out which ones we cooperate with here.

Please note that Klarna only holds the credit assessment we receive from a CRA in a script data format. This means that you are recommended to request a copy of the assessment directly from the CRA if you would like to see a readable version.

7.5 FRAUD PREVENTION AGENCIES AND COMPANIES THAT SUPPLY IDENTITY LOOKUPS

Your personal data may be shared with fraud prevention agencies and companies that supply identity lookups in order to verify your identity, the accuracy of the data you have provided us with, and to prevent criminal activities. The companies we cooperate with in the United Kingdom are listed here. Please note that these companies process your data in line with their own privacy notices.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

7.6 KLARNA GROUP

Your information may be shared with companies within the Klarna group, based on Klarna’s legitimate interest to conduct its business.

7.7 SOCIAL MEDIA COMPANIES

If you contact us through social media such as Facebook or Twitter, your data will be recorded and processed by those companies, in accordance with their privacy notices.

7.8 A PERSON HOLDING A POWER OF ATTORNEY OF YOUR AFFAIRS

Klarna will share your data with a person holding a power of attorney from you, allowing the person holding the power of attorney to receive such data. This sharing will be done based on your consent.

7.9 GOOGLE

When you use the Klarna App through a web browser, Google will collect your device information through its reCAPTCHA service implemented there, sometimes combined with any information you enter into the reCAPTCHA service. Google will process this information in line with its own privacy policy. Klarna processes this data based on its legitimate interest to conduct its business, as the reCAPTCHA service prevents misuse of our Services.

7.10 AUTHORITIES

Klarna may disclose necessary information to authorities such as the police, tax agencies or other authorities if we are required to do so by law, or under some circumstances if you have requested us to do so. One example of such legally required disclosures is disclosure for purposes of anti-money laundering and counter terrorist financing

There is also a requirement under UK law to withhold tax due on the payments. You will not need to do so, or take any action based on the agreement we have with the UK tax office (the HMRC), as we will disclose the necessary information to the UK tax office to support this agreement. If you have any questions regarding these arrangements, please contact the tax office.

7.11 LOGISTICS AND TRANSPORTATION COMPANIES

Klarna may share your information with logistics and transportation companies that deliver the goods you have ordered, if you have opted in to parcel tracking. Examples of data we share are contact- and identification information and tracking number. Please note that the logistics and transportation companies process your data in accordance with their own privacy notices.

7.12 PARTNERS WITHIN THE PERSONAL FINANCE SERVICE AND THE OFFERS AND BENEFITS PROGRAM

If you choose to take part of offers and benefits which Klarna provides within the Personal Finance Service or through the Offers and benefits program, Klarna may share the personal data that is necessary to enable you to access offers made in cooperation with our partners (this includes the fact that you are a customer of Klarna). Which personal data is shared is presented in connection with every offer.

7.13 DEBT COLLECTION AGENCIES

Klarna may share your information when selling, or assigns to collect, unpaid debts to third parties, e.g. to debt collection agencies. This sharing of personal data is based on our legitimate interest in collecting and selling debts. The debt collection agencies may process your personal data in line with their own privacy notices, or on Klarna’s behalf. For our Financing service, the debt collection agencies may also report your unpaid debt to credit reference agencies which may affect your credit rating and your ability to obtain future credit.

7.14 AFFILIATE NETWORKS

Klarna may share the information that you have clicked on a link that is sponsored (i.e. la links that promote stores, products or services) with so-called “affiliate networks”. This sharing takes place when you click on a link that is sponsored as you will then be redirected to the store’s website through the “affiliate network”. The affiliate network might place a tracking technology on your device that contains the information that you clicked on such a link in one of Klarna’s interfaces, in order to track your visit to a store in order to calculate potential commission to Klarna. The affiliate networks may process your personal data in line with their own privacy notices.

7.15 DIVESTMENT

In the event that Klarna sells or buys any business or assets, Klarna may disclose your personal data to the prospective seller or buyer of such business or assets.

If Klarna or substantially all of its assets are acquired by a third party, personal data about Klarna’s customers may be disclosed and shared.

8. WHERE DO WE PROCESS YOUR PERSONAL DATA?

We always strive to process your personal data within the EU/EEA. In certain situations, such as when we share your personal data with a Klarna group company or a supplier or subcontractor located outside the EU/EEA, your personal data may however be transferred to, and processed in, a destination outside of the EU/EEA. If the store where you shop is located outside the EU/EEA, our sharing of your personal data with the store will also mean that your data is transferred outside the EU/EEA.

We ensure that an adequate level of protection is maintained, and that suitable safeguards are adopted in line with applicable data protection legislation requirements, such as the GDPR, when we transfer your data outside the EU/EEA. These safeguards consist of ensuring that the third country or state at hand is subject to an adequacy decision by the European Commission or implementing the European Commission’s standard contractual clauses.

9. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

We will process your personal data for the time period needed to fulfil the respective purpose of our processing. These purposes are described in this Privacy Notice. This means that even though we stop processing your personal data for one purpose, we may still need to keep your personal data, if the data is needed for another purpose, using it only for that other purpose. In particular:

For as long as you have accepted our Klarna Services Terms, and until you terminate those terms (by contacting us or by instructing us to delete data, for example by way of a right to erasure request), we will process the personal data we need to be able to deliver the Services to you, including but not limited to data relating to your previous purchases.

We process the personal data included in credit lookups for the purpose of new credit assessments for a time period of 90 days, following the date that the lookup was done.

We process debt-related personal data for the purpose of new credit assessments for a time period of three (3) years following conclusion of the debt - by payment of the debt, the debt being written off by Klarna or sale of the debt by Klarna.

We process the recordings of telephone conversations for a time period of 90 days for quality assurance purposes, but may keep the recordings for up to two years for fraud investigation purposes. We may also retain recordings of outbound calls for up to two years, in order to document what has been decided on the call.

We process personal data for the purpose of complying with applicable laws, such as consumer rights legislation, banking- and anti-money laundering legislation and bookkeeping rules. Depending on the applicable legislation, your personal data may be processed up to ten years after the end of the customer relationship.

10. YOUR RIGHTS IN REGARDS TO THE PERSONAL DATA

Right to be informed. You have the right to be informed about how we process your information. We do this through this Privacy Notice, other information on our website, and by answering questions sent to us.

Right to access your data. You may request a copy of your data if you would like to know what personal data we process about you. This copy of your personal data can also be transmitted in a machine readable format (i.e. “data portability”).

Right to rectification. You have the right to correct inaccurate or incomplete information about yourself.

Right to erasure. You have the right to request deletion of your personal data, for example when it is no longer necessary for us to process the data for the purpose it was collected, or when you have withdrawn your consent. As described in more detail in Sections 3 and 9 above, Klarna however needs to adhere to certain legal obligations preventing us from immediately deleting some of your personal data.

Right to restrict processing of your data or object to our processing. If you believe your information is incorrect or you believe we use your data unlawfully, you have the right to ask us to stop the processing. You may also object to our processing where you believe there are circumstances that would make such processing unlawful. Furthermore, you can always object to us using your data for direct marketing.

Right to challenge an automated decision. You have the right to challenge an automated decision made by Klarna if this decision carries with it legal or similarly significant effects. See Section 6 for more information on how Klarna uses automated decisions.

Right to withdraw consent. As set out in Section 5, where we process your data based on consent or explicit consent, you may withdraw this consent at any time.

Right to lodge a complaint. You have the right to lodge a complaint with your national supervisory data protection authority, or the Swedish Data Protection Authority (“DPA”). Complaints to the Swedish DPA can be made using this link: https://www.datainspektionen.se/other-lang/in-english/.

Complaints to the UK supervisory authority (the Information Commissioner) can be made using this link: https://ico.org.uk/.

Controlling service settings in the Klarna app. In the Klarna app, Klarna provides possibilities for you to customize your preferences for certain Services, for example when it comes to whether you want to receive notifications or personalized marketing. We will always respect your choices.

11. WHAT ABOUT COOKIES AND OTHER TRACKING TECHNOLOGIES?

To deliver a tailored and smoooth experience, we use cookies and similar tracking technologies in our online interfaces, such as our website, the Klarna App and the checkout of stores that cooperate with Klarna. You can find information about the tracking technologies we use, and accept respectively reject relevant tracking technologies in the respective interface.

12. UPDATES TO THIS PRIVACY NOTICE

We constantly work to improve our Service offerings, in order for you to get an even smooother user experience. This includes both changes in existing Services and new Services over time. It’s therefore important that you read this Privacy Notice each time you use a Klarna Service, since the processing of your personal data can differ since you last used one of our Services.

13. CONTACT DETAILS.

Klarna Bank AB (publ) is registered in the Swedish companies register under the registration number 556737-0431 with our main office located at Sveavägen 46, 111 34 Stockholm, Sweden.

Klarna has a Data Protection Officer and a team of data protection specialists working solely with data protection and privacy. We also have a special team of customer service specialists for data protection matters. You can always reach them at [email protected].

Klarna Bank AB (publ) is subject to Swedish data protection legislation. Visit www.klarna.com for further information on Klarna.

14. ACQUISITION OF CLOSE BROTHERS RETAIL FINANCE

In January 2019, Klarna acquired the Retail Finance division of Close Brothers Limited. In relation to this acquisition, Klarna acquired the personal data of customers who use or have used the services of the Retail Finance division. Klarna will process this personal data in order to fulfill contractual obligations, comply with applicable laws, and in line with Klarna’s legitimate interest to conduct its business.

The personal data acquired will be processed in line with the privacy notice, in force at the time of the acquisition, and in line with applicable data protection laws. Please note that you have the rights stipulated in this Privacy Notice also for this data, for example the right to access (See Section 13). The privacy notice, in force at the time of the acquisition may be found here.

Last updated 22 Feb 2022.