1. Introduction
This Privacy Policy (the “Policy”) describes how Sferical AI AB, reg. no. 559520-4016 (“Sferical AI”, “we”, “us” or “our”), at the address Box 16066, 103 22 Stockholm, Sweden, processes your personal data.
We are establishing a sovereign AI compute platform in Sweden, to give our partner companies secure, large-scale access to world-class AI compute. Our goal is to help partners turn AI into measurable business impact. With state-of-the-art compute capacity and shared industrial expertise, Sferical AI will enable faster R&D, more efficient engineering workflows and support the development of new AI-driven capabilities and applications.
We are responsible for the processing of your personal data as described in this Policy in the capacity of data controller. If you would like to know more about our processing of your personal data, you are welcome to contact us.
It is important to us that you feel comfortable with how we process your personal data, and we therefore ask you to read through this Policy, which we may update from time to time. If we make changes to the Policy, the new version will apply from the time it is published on our website.
2. The scope of this Policy
The Policy covers our processing of personal data collected in relation to your interactions with us, if you are a job applicant or a representative of our business partners and customers.
3. How we collect your personal data
The personal data we process relating to you is collected directly from you or from third-party data sources. If you would like to know more about from which third parties we collect your personal data, you are welcome to contact us.
4. How we process your personal data
We only process your personal data to the extent permitted in accordance with applicable data protection legislation. This means that we need to have a legal basis for the purposes of our processing of your personal data, which in our context generally means one of the below legal bases. If you are acting on behalf of someone else, e.g., in the capacity of a representative of an entity, our processing is carried out with reference to our legitimate interest balanced against your interests or fundamental rights or freedoms, where our legitimate interest is to conclude and perform the contract with the entity you represent.
Performance of a contract: the processing is necessary in order for us to provide you with our services or otherwise perform a contract between us or the entity you represent, or to take steps at your request prior to entering into a contract.
Performance of legal obligations: the processing is necessary to fulfil our legal obligations according to law or other statutes that we are subject to, or if we are subject to orders or decisions by courts or authorities, which require us to process your personal data.
Legitimate interests: the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, if they are not overridden by your interests or fundamental rights or freedoms.
Consent: the processing is carried out with your prior consent, where we are responsible for clearly informing you of what processing you consent to and your right to withdraw your consent in relation to our continued processing.
Below, we explain more about the categories of personal data we process, for what purposes we process them and what legal bases we rely on when processing your personal data, including for how long we store your personal data.
4.1.1. Business relations
| What we do and why: | The personal data that we process: |
| To enter into or fulfil contracts between us or the entity you represent. | • Name • Contact details, such as email address, phone number, location, and address • Professional title as well as information about the entity you represent |
| Legal basis for the processing activity: | |
| We need to process your personal data in order to fulfil our obligations in relation to the contract. | |
| Retention period: | |
| We process and store your personal data until the contract terminates and up to ten (10) years thereafter or for a period of time to fulfil legal obligations, for example according to the Swedish Accounting Act, whichever is longer. | |
4.1.2. Contracts
| What we do and why: | The personal data that we process: |
| To enter into or fulfil contracts between us or the entity you represent. | • Name • Contact details, such as email address, phone number, location, and address • Professional title as well as information about the entity you represent |
| Legal basis for the processing activity: | |
| We need to process your personal data in order to fulfil our obligations in relation to the contract. | |
| Retention period: | |
| We process and store your personal data until the contract terminates and up to ten (10) years thereafter or for a period of time to fulfil legal obligations, for example according to the Swedish Accounting Act, whichever is longer. | |
4.1.3. To register as a user of the Sferical platform
| What we do and why: | The personal data that we process: |
| To enter into or fulfil contracts between us or the entity you represent concerning the Sferical platform. | • Name • Contact details, such as email address, phone number, location, and address • Professional title as well as information about the entity you represent |
| Legal basis for the processing activity: | |
| We need to process your personal data in order to fulfil our obligations in relation to the contract. | |
| Retention period: | |
| We process and store your personal data until the contract terminates or until the account is deleted. | |
4.1.4. Support
| What we do and why: | The personal data that we process: |
| To provide customer support, including addressing and resolving customer inquiries and issues. | • Name • Contact details, such as email address, phone number, location, and address • Professional title as well as information about the entity you represent • Information which you provide to us when communicating with you |
| Legal basis for the processing activity: | |
| Our legitimate interest in providing efficient customer support and maintaining customer relationships. | |
| Retention period: | |
| We process and store your personal data for two (2) years from the time we were last in contact because of the support matter. | |
4.1.5. Recruitment
| What we do and why: | The personal data that we process: |
| Recruitment and employment process. | • Name • Contact details, such as email address, phone number, location, and address • Personal data contained in CV, personal letter, letter of recommendations, diplomas, and information provided by references • Information provided by you during the recruitment process • Results of tests and checks carried out during the recruitment process |
| Legal basis for the processing activity: | |
| Our legitimate interest to make it possible for us to evaluate your qualifications and personal qualities in connection with decisions on recruitment. | |
| Retention period: | |
| We need to retain your personal data after you have participated in a recruitment process to protect our rights under the Swedish Discrimination Act. We therefore save the information from the recruitment process for two (2) years after the recruitment process is over. | |
4.1.6. Camera surveillance
| What we do and why: | The personal data that we process: |
| To ensure and manage workplace security and to protect our business, employees, visitors and property, we use camera surveillance. | • Footage from our camera surveillance |
| Legal basis for the processing activity: | |
| Our legitimate interest to prevent, detect and investigate crimes and accidents. We only use personal data concerning criminal offences in case we need this footage to establish, exercise or defend legal claims in an individual case. | |
| Retention period: | |
| We retain your personal data for three (3) days. | |
4.1.7. Website
| What we do and why: | The personal data that we process: |
| To maintain, facilitate and improve the functions and user experience of our website, create statistics, as well as support our work on detecting and counteracting flaws, breaches, and incidents. | • IP-address • Information about your use of our website • Other technical information which is generated upon visiting our website, such as what type of device is used and web browser |
| Legal basis for the processing activity: | |
| Our legitimate interest to gather information to maintain, facilitate and improve the functionality, user experience, and security on our portal and website. | |
| Retention period: | |
| We process and store information on how our users interact with our website for a period of maximum six (6) months. Cookies are deleted in accordance with our cookie information. In most cases, the collected personal data will be aggregated and anonymised at an earlier stage, in connection to us creating statistics. | |
5. Security measures
We have taken security measures to ensure that your personal data is handled in a safe way. For example, access to systems where personal data is stored is limited to our employees and service providers who require it in the course of their duties. Such parties are informed of the importance of maintaining security and confidentiality in relation to the personal data we process. We maintain appropriate safeguards and security standards to protect your personal data against unauthorized access, disclosure, or misuse. We also monitor our systems to discover vulnerabilities.
6. Sharing your personal data
To achieve the above purposes, we may give third parties access to your personal data based on a contractual relationship with us, this could be our affiliates, partners, IT suppliers, security companies, or other suppliers and subcontractors, that have a legitimate interest in receiving the personal data, process personal data on our behalf, or which are joint controllers with us. We may also share your personal data with government agencies and law enforcement authorities to fulfil our legal obligations or on the basis that we have a legitimate interest.
In the context of our development, the corporate structure may change, e.g., by the total or partial sale of the company. We may hand over your personal data to a potential buyer for purposes of such total or partial sale of the company based on our legitimate interest to perform such transactions. In the case of a partial transfer of assets containing personal data, the processing basis for the related transfer of personal data is, as a rule, based on our legitimate interest in transferring parts of our assets and making commercial/structural changes.
7. Where we process your personal data
We strive to process your personal data within the EU or EEA. However, we will transfer your personal data to service providers who, either themselves or by their sub-contractors, are located or have business activities in a country outside the EU or EEA. In such cases, we are responsible for ensuring that the transfer is made in accordance with applicable data protection legislation before it occurs, e.g. by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission, or by ensuring appropriate safeguards based on the use of standard contractual clauses that the European Commission has adopted and other appropriate measures to safeguard your rights and freedoms.
You may access a list of the countries that the European Commission has decided to provide an adequate level of data protection here.
You may access the European Commission’s standard contractual clauses here.
Please contact us for more information concerning which countries outside the EU/EEA to which we currently transfer personal data.
8. Additional retention period
We may use personal data to handle any customer complaints or to defend and/or establish legal claims. We will generally process such personal data for ten (10) years from creation or for the time necessary to fulfil the purpose in the relevant case. This processing of your personal data is based on our legitimate interest of establishing and/or defending legal claims.
9. Your rights
You have rights in relation to us and our processing of your personal data. Below, you will find information about your rights and how you can exercise them. Please note that your rights apply to the extent that follows from applicable data protection legislation and that there may be exceptions to the rights.
We also ask you to note that we may need more information from you to confirm your identity before proceeding with your request to exercise your rights.
To exercise your rights or request information about them, you are welcome to contact us.
9.1. Right of access
You have the right to obtain a confirmation as to whether we process your personal data. If that is the case, you also have the right to receive copies of the personal data concerning you that we process as well as additional information about the processing, such as for what purposes the processing occurs, relevant categories of personal data and the recipients of such personal data.
9.2. Right to rectification
You have the right to, without undue delay, have incorrect personal data about you rectified. You may also have the right to have incomplete personal data completed.
9.3. Right to erasure
You have the right to request that we erase your personal data without undue delay in the following circumstances:
- The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- Our processing is based on your consent, and you withdraw your consent to the relevant processing;
- You object to the processing that we carry out based on a legitimate interest, and your objection overrides our or another party’s legitimate interest of the processing;
- The processed personal data is unlawfully processed;
- The processed personal data must be erased for our compliance with one or more legal obligations.
9.4. Right to restriction
You have the right to request that we restrict the processing of your personal data in the following circumstances:
- You contest the accuracy of the personal data during a period enabling us to verify the accuracy of such data;
- The processing is unlawful, and you oppose erasure of the personal data and request restriction instead;
- The personal data is no longer needed for the purposes of the processing, but is necessary for you for the establishment, exercise or defence of legal claims;
- You have objected to the processing of the personal data which we carry out based on a legitimate interest, pending the verification whether your objection overrides our or another party’s legitimate interest to continue with the processing.
9.5. Right to object
You have a right to object to our processing of your personal data when it is based on our or another party’s legitimate interest. If you object, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms in order to be allowed to continue with our processing.
9.6. Right to data portability
If our processing of your personal data is based on the performance of a contract with you or your consent, you have the right to receive the personal data you have provided us relating to you in an electronic format. You also have the right to have the personal data transferred from us directly to another data controller, where technically feasible. We ask you to observe that this right to so called data portability does not cover personal data which we process manually.
9.7. Right to withdraw consent
If our processing of your personal data is based on your consent, you always have the right to withdraw your consent at any time. A withdrawal of your consent does not affect the lawfulness of the processing that took place based on the consent before your withdrawal.
10. Complaints with the supervisory authority
In Sweden, the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) is the authority responsible for supervising the application of current data protection legislation. If you believe that we process your personal data in a wrongful manner, we encourage you to contact us so that we can review your concerns. However, you may lodge a complaint with the Swedish Authority for Privacy Protection at any time.
11. Contact details
If you have any questions about the processing of your personal data or want to exercise any of your rights, please contact us at:
Email: