Klarna Privacy Policy

At Klarna, we care about your privacy. Therefore, we collect and process personal information 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 "Service" or collectively, the "Services") and become a customer. Examples of our Services are when you make payments with one of our payment options, when you contact us, when you use Klarna's web portal and mobile application (the "Klarna Apps") or when your personal data is automatically entered when you checkout . Furthermore, this Privacy Policy describes your rights regarding the processing of personal data and how to exercise them.

It is important that you read and understand the content of this Privacy Notice which applies to all personal data that Klarna processes, except as provided in Section 1.

Some of our Services will provide you with access to content and functionality offered by companies or organizations other than Klarna (“Third Party Services”). This occurs, for example, when you link to third party sites from our websites, when you access third party sites while using your 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 the processing of your personal data by such third parties.

"We", "our" or any other reference to "us" means Klarna Bank AB (publ) registered in the Swedish Companies House under number 556737-0431 and having its principal place of business at Sveavägen 46, 111 34 Stockholm, Sweden. For the purposes of European data protection law, we act as a controller of the personal data received from, or otherwise about, you and collected by us and are responsible for using your data in accordance with applicable data protection laws.

1. Further information on Klarna privacy

The processing of your personal data by Klarna Ident and Klarna Open Banking in the performance of the Services is in accordance with the privacy notices for those services, which are presented to you when you use them. Those separate notices apply in place of the information given here. Specific privacy notices may be provided for selected campaigns or offers that are available for a limited time, and will in those cases be presented together with them.

If you are a Klarna employee or have applied to work with us, or are employed in a store with which we cooperate, Klarna’s processing of your personal data is subject to other privacy notices and you will be provided with the relevant information depending on your relationship with Klarna. Please contact us using the details in Section 13 below if you would like a copy of the relevant privacy notice that applies to you.

2. What data do we use?

2.1 The personal data provided by you

You may provide us with information about yourself when you use a Klarna Service, such as when you choose a payment method from those offered by Klarna, when you contact us or when you use the Klarna App. Therefore, the user is invited to remember that in order to correctly provide the Services it is necessary to provide their personal data .

Depending on the Services chosen, the following personal data may be processed:

• Identification data and contact details – name, date of birth, tax code, education, billing and shipping address, email address, mobile number, nationality, salary, audio recordings, photos and video recordings of you and your identity card etc.

• Payment details – data relating to credit or debit cards (card number, expiry date and CVV code), current account number, etc.

• Special categories of data – you may, at your sole discretion, provide us with information about you that constitutes "special categories" of personal data pursuant to EU Regulation 2016/679 ("GDPR"), which includes, for example, data concerning religious beliefs, political opinions or philosophical beliefs, trade union membership, data relating to health, biometric data or data relating to a person's sexual life or sexual orientation. You will never be asked to communicate this type of personal data in order to access our Services. This category of personal data may be provided to us only on a strictly voluntary basis and with the explicit consent of the user. Please refer to paragraph 5 for information on how to withdraw your consent.

You can change your profile information, contact details and other editable settings at any time by using the Klarna App or by contacting us.

2.2. Personal data of the user collected by Klarna

Depending on the Service you choose to use, Klarna may collect the following information about you, either directly or through third parties (such as credit reference or fraud prevention agencies, agencies and publicly available databases):

• Identification data and contact details – name, date of birth, tax code, education, occupation, gender, billing and shipping address, email address, mobile number, nationality, etc.

• Information about goods and/or services – data relating to the goods or services purchased or ordered by the user, including, for example, the types of goods or shipping identification numbers.

• Financial information – financial information collected from third parties regarding income, any loans, negative payment reports, a previous payment or acceptance of credit.

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

• Recorded telephone conversations – we record telephone conversations made by the user to customer service.

• Information about the interaction between the user and the stores – your relationship with the store where you make purchases, such as information about whether you received the goods and the type of store.

• Information about the device – such as your IP address, language settings, browser settings, time zone, operating system and platform, and screen resolution. Please refer to paragraph 11 below for more information on how we collect data from you. device of the user or we store them on the same.

• Information from external lists of sanctions and politically exposed persons (PEPs) – we can analyse your data against those on lists of persons subject to sanctions and so-called “Politically Exposed Persons” (PEPs). These lists contain data such as your name, date of birth, place of birth, occupation or position and the reason for your inclusion in these lists.

• Service-specific information : To provide you with some of our Services, we may collect and process additional personal data not covered by the categories above. Please refer to Section 4 for additional personal data processed for the relevant Service.

3. Type, purpose and legitimacy of the processing of personal data

Depending on the Services you use, Klarna may process personal data for the purposes listed below, on the legal basis indicated for each purpose. Please see Section 4 below for more information on how we process your data in our Services.

Processing aimed at providing the Services

Purpose of the processing	Personal data	Legal basis for processing
Manage our relationship with you/customer in a variety of ways, for example in relation to managing your payments or to fulfil our obligations under credit agreements with you.	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, information on the device , specific information about the Services.	Fulfill contractual obligations.
Create and send information in electronic format to you (non-commercial in nature).	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, information on the device , specific information about the Services.	Fulfill contractual obligations.
Evaluate the best channel to contact the user and inform them of the outstanding debts.	Identifying and contact information, financial information (if available) and information regarding your interaction with Klarna.	Klarna has a legitimate interest in being able to contact you in the most efficient way. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Evaluate in what order the different payment methods should be presented to the user at checkout of a store. Such processing and related presentation, however, do not affect the payment methods available to you. You can object to this at any time by contacting Klarna using the details provided below. This processing constitutes profiling. Please read Section 6 for more information on profiling.	Identification and contact information, information about goods and services, information about your interaction with Klarna, and information about your interaction with stores.	If you have accepted Klarna's Terms of Service set out in Section 4.4, the applicable legal basis is the fulfillment of contractual obligations. However, if you have not accepted those terms, Klarna bases this processing on legitimate interest, as Klarna (and you as a customer) have a legitimate interest in having your preferred payment method in the foreground. checkout . It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Conduct surveys with users/customers regarding their level of satisfaction with our Services (for example, after having used Klarna's customer service) via email, SMS, telephone or otherwise. You may always object to this data processing. You will also be informed of your right to object ( opt-out ) from such communications whenever your email address or telephone number is used for this purpose.	Identification and contact data, information on goods/services and information regarding the interaction between the user/customer and Klarna and between the user/customer and the stores.	Klarna has a legitimate interest in conducting customer satisfaction surveys. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Conduct credit and fraud assessments to determine which payment methods we can offer you based on Klarna's internal data.	Identification and contact data, information on goods/services and financial information (if already available internally), information regarding the interaction between the customer and Klarna and between the customer and the store, as well as device data.	Klarna has a legitimate interest in carrying out credit and fraud assessment activities to determine which payment method to offer you. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Conduct credit assessments before granting credit (Please see Section 4.1 for information about our Credit Services and Section 7 for information about how we cooperate with credit reference agencies).	Identification and contact information, financial information and information regarding the interaction between the customer and Klarna.	Comply with legal obligations if the provision of credit is regulated by legal provisions. In the absence of legal obligations to be respected, the processing occurs for the purpose of fulfilling contractual obligations.
Prevent cyber attacks (e.g. DDoS attacks) aimed at Klarna Services as part of our commitment to ensuring the continuity and security of our Services.	Identification and contact data, information regarding the interaction between the customer and Klarna and between the customer and the stores, as well as data relating to device used.	Pursuing Klarna’s legitimate interest in ensuring the security of its Services. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Ability to manage the client's vulnerability (if, due to personal circumstances, they are in a vulnerable position).	Identification and contact data, information regarding the interaction between the user and Klarna, special categories of personal data.	Based on customer consent.
To improve our Services, to train our operators and ensure the quality of the services as well as to document what has been agreed and decided between you and Klarna's customer service.	Recording of telephone conversations.	Klarna has a legitimate interest in improving its Services, and in providing training and quality assurance. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Share your information with stores, suppliers and others. (See Section 7 for more information about how and why we share your information.)	All categories of personal data referred to in paragraph 2.	Depending on the recipients, please refer to Section 7. For example, Klarna, for the purpose of providing the Services, has a legitimate interest in using providers and may be subject to a legal obligation to communicate data to the authorities. The communication of data to payment service providers is required for the purpose of executing the payment agreement concluded with the user.
To carry out risk analysis, prevent fraud and manage risks (for example by verifying your identity and carrying out checks with fraud prevention agencies and similar). Please see paragraph 7 for a more specific description of the fraud prevention companies we cooperate with.	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, special categories of personal data, information on the device .	Klarna and other parties (in particular, its customers) have a legitimate interest in carrying out business risk management activities, for example addressing fraud risks. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed. Klarna also has legal obligations to establish the identity of its customers. Special categories of data are processed on the basis of your explicit consent.
Carry out activities related to debt collection (e.g. debt collection and assignment).	Identification and contact details, information about goods/services, financial information and information regarding the interaction between the customer and Klarna and between the customer and the stores.	Klarna has a legitimate interest in carrying out debt collection and assignment activities. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.

Product improvement and research

Anonymize your personal data for the purpose of analyzing customer behavior for product development.	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, information on the device , specific information about the Services.	Klarna has a legitimate interest in anonymizing your personal data for product development purposes and for analyzing customer behavior. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Perform data analysis to improve and test products (for example, to improve models to prevent risk and fraud).	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, information on the device , information from external sanctions and politically exposed persons (PEP) lists, specific information on the Services.	Klarna has a legitimate interest in analyzing data for product development and testing. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Enable internal analysis and development of statistical models.	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, information on the device , specific information about the Services.	Klarna has a legitimate interest in enabling internal analyses for the development of statistical models. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Allow external research, for example conducted by universities or other entities.	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, information on the device , specific information about the Services.	Klarna has a legitimate interest in enabling external research and contributing to the general interest of society in supporting research. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.

Compliance and mitigation of Klarna's exposure to legal action

Comply with applicable regulations, such as anti-money laundering and accounting regulations and those relating to compliance with capital adequacy requirements.	Identification and contact details, payment data, information on goods and/or services, financial information, information regarding the interaction between the user and Klarna, information regarding the interaction between the user and stores, information on the device , information from external sanctions and politically exposed persons (PEP) lists, specific information on the Services.	Compliance with legal obligations.
Analysis of sanctions and politically exposed persons (PEP) lists.	Identification and contact details, information contained in sanctions lists and politically exposed persons (PEPs).	Compliance with legal obligations.
Protect Klarna from legal action and enforce its rights under the law.	All categories of personal data referred to in paragraph 2.	Klarna has a legitimate interest in defending itself from legal claims, and in enforcing its rights arising from the law. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.

Commercial offers

Provide customers with proposals and commercial offers regarding our services. It is always possible for the user to opt-out. by contacting us: see paragraph 13.	Identification and contact data, information regarding the interaction between the customer and Klarna and between the customer and the stores, specific information on the Services.	Klarna has a legitimate interest in providing customers with marketing activities and commercial offers. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Select commercial offers to provide to the user. This data processing ceases when the user opts out of receiving commercial offers.	Identification and contact details, information on goods/services, information regarding the interaction between the customer and Klarna and between the customer and the store, information on the device , specific information about the Services.	Klarna has a legitimate interest in selecting the marketing offers to provide to you. It ensures that the processing carried out for these purposes is necessary to achieve our legitimate interest, and that our interest outweighs that of the user in not having their data processed.
Supply link sponsored by the stores' products and services.	Information on products/services, information on the interaction between the user and Klarna, information on the interaction between the customer and the stores, information on the device and specific information about services.	Klarna has a legitimate interest in providing link sponsored to promote our stores in the Klarna app and on our website. We ensure that the processing carried out for this purpose is necessary to satisfy our legitimate interest, and that our interest outweighs your interest in not having your data processed.

4. Processing of specific personal data for certain Services

This section describes the processing operations of the user's personal data carried out specifically for certain Services. Please refer to the terms and conditions of the relevant Service for further information regarding our Services and their features.

4.1 Klarna Credit Services

The following Services are for the provision of credit to you: Deferred Payment (Invoice), Instant Payment (in the case of Direct Debit), Financing, the Klarna Card and the disposable card (both available in the Klarna App). In order to provide these Services, we carry out a credit assessment of you, based on the identification and contact details you provide, information regarding your/customer's interaction with Klarna and financial information. Financial information includes information obtained externally from credit rating agencies, such as income and payment reports. Please see section 7 for further information on our treatment of credit rating.

The Klarna Card and Disposable Paper

When you apply for the Klarna Card and the disposable card (available in the Klarna App), Klarna conducts a credit assessment of you/your customer in the same way as with other Credit Services. If you have the Klarna Card, your credit assessment is constantly updated, and is based on your interaction with Klarna.

We share information about you and your purchases when you use your Klarna Card with VISA and VISA network members, as necessary to process card transactions, prevent fraud and comply with applicable rules. If you renew your Klarna card or receive a new one, we transfer this information to VISA so that VISA can inform third parties with whom you have stored your card details (for example, in the case of recurring transactions).

If you add your Klarna Card to your e-wallet, we may also need to share your data with your e-wallet provider as described in that provider's privacy policy.

4.2 You click on one of our promotions or event announcements posted by third parties on social media

If you click on one of our promotions or event announcements posted by third parties on social media, we may receive the contact information about you that you provided in connection with your profile on that social media (such as your name, email address and telephone number and any other relevant business information such as your company name, address and industry).

4.3 Klarna accounts (savings and payment accounts)

If you have an account with Klarna, Klarna will also process your transaction and funds data. If you make transactions or payments to other accounts, Klarna will pass your name and account number to the recipient and the recipient's financial institution.

Additionally, if you have made payments to a Klarna account, Klarna will process the data received from the bank you used for the transaction including your name and account number.

4.4 The user experience offered by Klarna under the Terms of Services

In order to provide you with a seamless shopping experience, before and after your purchase, Klarna offers the services described below, which are also described in more detail in the Klarna Terms of Services. By using these Services, we process your personal data as follows:

Operation history

We store information about the goods and services you purchase through our Services, or that you have otherwise allowed us to access, in order to display them to you.

Automatically fill in information

Automatically filling in users' contact information can be done in two ways: through user interaction and/or via cookies.

Autofill through user interactions

When you use the Services, we may ask for your contact information, such as your name, address, telephone number, email, date of birth and/or national identity card number. We will store this information in our systems and when you return, you will only need to provide some contact information, such as your telephone number, email, postal code or national identity card (depending on the country) so that we can automatically fill in the remaining fields with additional information.

Autofill via cookies

Another method of automatic data filling is through the installation of a Klarna cookie on the device of the user (computer, tablet, mobile phone) that allows the user to decide to save their data such as name, address, telephone number, email, date of birth, identity card number and card details on the Klarna platform. In this case we will use the cookies to import data already stored by Klarna when you use our services with the same user device . We will then automatically fill in the data when you interact with Klarna.

Disabling the autofill function

If you do not want to use the autofill function, you can contact us so that we can deactivate this setting. You can also change your settings directly through the Klarna App or during the purchase process in a store. Finally, you can delete the cookies from your device, thus eliminating ours as well.

Pre-selected preferred payment methods

Klarna can determine your preferred payment method for purchases and pre-select it for you. However, this does not affect the payment methods available to you. For this purpose, Klarna processes data from interactions between you and Klarna, such as data regarding your previous payment methods, purchase, amounts and store. This data processing constitutes profiling. Please refer to section 6 for more information on profiling.

Offers and benefits

In order to offer you offers and benefits such as discounts, special events, pre-sales of products, promotions, commercial offers, samples, freebies, etc., we take into account information relating to your interactions with Klarna (such as the number of purchases in a given period of time) and data to contact and identify you. These are activities that may involve profiling. Please refer to paragraph 6 for further information on profiling.

This data will form the basis for Klarna's marketing and customer analyses, business and process development, as well as for statistical purposes.

As part of the offers and benefits program, Klarna, its suppliers and subcontractors (on behalf of Klarna) may use this data to communicate offers and benefits to you via regular mail, SMS, e-mail , social media and other digital channels. Klarna and its suppliers and subcontractors will not use any digital channels. marketing directed for this purpose (for example e-mail or text messages) if the user has expressed the opt-out to receive shares of marketing direct (i.e. if the user has not expressed the opt-in if this is provided for by national legislation).

To express the opt-out To receive offers and benefits, the user can unsubscribe through the link indicated in the emails sent by Klarna or by contacting Klarna (see paragraph 13).

The Klarna App

If you use the Klarna App, some additional personal data (e.g. information uploaded by you based on your consent) will be processed in order to ensure the provision of the Services you choose to use within the App, as set out below. Additionally, when you choose to redeem rewards or participate in specific offers, the provider of those offers may infer that you have used Klarna's services. Personalisation of content constitutes profiling of your data, which is an integral part of the Klarna Shopping Assistant App online ; for more information see Section 6.

• Personalised items and ads : You may see personalised items and ads based on your previous purchases, contact and identification data, data about goods or services, data about your interaction with Klarna, data about your interaction with stores, device data and service-specific data.

• Sponsored links : if the user clicks on a link sponsored ad promoting a store, product or service, the user will be redirected to the store's website through a third party, a so-called "affiliate network" (see paragraph 7.14 for further explanation). The affiliate network may place tracking technology on the user's device containing data relating to the user's click on the link sponsored in the Klarna App and which is then used to track the user's visit to a store in order to calculate a potential commission to Klarna.

• Personalized Klarna overview : You can view the overview to see the status of your Klarna purchases and their history, access any refunds and pay or extend payment terms.

• Personalized shopping collections : If you have shared with Klarna information, topics, products and services that interest you in general, Klarna will use this information to provide you with personalized shopping collections, where you can find tailored products and services that are personalized to your interests.

• Shipping and tracking of packages : the user can, in some cases, track the path of shipments.

• Ability to “follow” stores : If you choose to “follow” a store, you will receive information about offers related to that store. Klarna will automatically evaluate whether those purchases grant access to discounts or other offers within the current offer.

• Credit Services : We may offer credit to users based on previous purchases.

• Shopping with a disposable card : Shopping via the Klarna App is one of the ways to use Klarna's payment methods in almost all stores with a disposable card. When you use your disposable card, Klarna collects information about your purchases and displays them to you in the App.

• Customer Service : When you contact Customer Service through or in connection with the Klarna App, we will have access to the information you provide.

• Email Connect: If you have connected your email account to the Klarna Email Connect service, Klarna will regularly access your email account to extract additional information about your goods and services and your interaction with the stores, in order to upload this information to the Klarna App. You can deactivate the service at any time by removing Klarna's access.

• Find the store: You may choose to share your location with Klarna, in which case you will allow Klarna to use this information to show you nearby stores. You can withdraw your consent by turning off sharing on your device. Klarna will not retain your location after showing you stores.

• The web browser in-app : The Klarna App contains a web browser where you can access store websites and online stores and then make purchases with Klarna payment methods even with stores that do not yet use our payment methods. Klarna collects information about your browser usage in order to provide you with relevant offers. In addition, websites you visit may set their own cookies and other tracking technologies on your device.

• Visual Search : You can choose to upload product photos, either by taking a photo of the product or choosing a photo from your phone's library, and Klarna will try to find products similar to those uploaded to show you.

• Wishlist : You can choose to add products and services in the Klarna App to your Wishlist, so you can find them later or keep track of their prices. You can also share your Wishlist with other people, such as friends and family, who can then see your profile photo and username. In some cases, if you are logged in to a store's website, the link to a product or service you have chosen to add to your Wishlist may include personal information such as your email address.

• 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 with your connected bank accounts. When you choose to use this Service, Klarna will process information about your external account and other accounts (such as card accounts) that you choose to connect, and collect personal data such as account number, bank, transaction history, available funds and assets. Based on this data, Klarna will display and provide you with tools to control your finances through offers tailored to your specific situation (based on profiling, as explained in paragraph 6). This is done by comparing your spending with other users of the Service. Based on this comparison, Klarna, together with its partners, can offer ways to minimize fixed and non-fixed costs.

• Profile picture: You may choose to upload a profile photo to the Klarna App, in which case you consent to the image being displayed in various Klarna interfaces (such as in the checkout Klarna in a store, or in the Klarna App). Klarna interfaces may also be installed in store apps. The photo may also be shown to others if you share your device with others (using autofill through the cookies ), or if you choose to share the content of your Klarna App with others. You can withdraw your consent at any time in accordance with paragraph 5, and Klarna will then delete the image.

5. Revocation of consent

Where Klarna processes your personal data based on your consent, including explicit consent (for example, if you provide a power of attorney that allows another individual to access your data, or if you declare your vulnerability, or if you upload special data to our Services), you can withdraw your consent at any time by contacting us or by deleting your data uploaded in the Klarna App. Withdrawing your consent will not affect you as this data is not required for the provision of the Services.

6. Profiling and automated decision-making

"Profiling" is the automated processing of personal data to examine certain personal characteristics of the user, such as aspects of their financial situation or their preferences, such as purchasing preferences. We use profiling of the personal data we have about users in order to make individual or automated decisions about the user for the purposes set out below.

Decisions without legal effect or similar relevance

Klarna makes the following decisions which have no legal effect or similar relevance for you:

• predict commercial content potentially of interest. The user can always oppose this type of commercial proposal and unsubscribe from marketing or profiling by contacting us. Please refer to paragraph 3 for further information on the processing of personal data for marketing purposes;

• decide which loyalty rewards are best for you. Please see section 4.4 "Offers and Benefits" for more information;

• decide the most appropriate way to inform the user about his/her current debt position. Please refer to paragraph 3 for further information;

• select the content you want to display to users in the Klarna App. Please see section 4.4 "The Klarna App" for further information;

• select the order in which the different payment methods should be presented to the user at checkout in store.

Additionally, some of our Services (such as connecting bank accounts and other similar accounts with the Klarna App) use profiling in order to provide the applicable Service to you, such as communicating relevant financial information to you or a range of offers, in accordance with the terms of the Service.

Decisions having legal effect or of similar relevance

Automated decision-making with legal effect or automated decisions with similar significance means that certain decisions in our Services are based solely on automated means, without any interaction from our employees, and have a significant impact on you as a consumer. Through automated decisions, objectivity and transparency in decisions in the provision of those Services is increased.

We use this type of automated decision-making when:

• we decide to approve your request to use a Credit Service;

• we decide not to approve your request to use a Credit Service;

• we decide whether you are engaging in fraudulent or money laundering behavior, if our processing operations reveal that your behavior is related to money laundering or fraudulent behavior, or that your behavior is inconsistent with your previous use of the Service, or if you have deliberately misrepresented your identity. If applicable, Klarna also checks whether or not a particular customer is on a so-called anti-money laundering list.

Please refer to paragraph 3 for further information on the type of data processed for these purposes.

You always have the right to challenge an automated decision that has legal effects or similarly significant consequences (together with the related profiling) by contacting us via the email address referred to in paragraph 13. A Klarna employee will then deal with the case.

7. Disclosure of User Information

We may need to share your personal data with the categories of recipients listed below for the purposes listed below. The recipients and the purposes for which the data is communicated depend on the Services used by users. When we share your personal data, we take all reasonable contractual, legal, technical and organizational measures to ensure that your personal data is treated with an adequate level of protection and in compliance with applicable law.

7.1 Suppliers and subcontractors

Klarna may share your personal data with suppliers and subcontractors used by Klarna to provide the Services. Suppliers and subcontractors are companies authorized to process data received from Klarna or on behalf of Klarna. Examples of these include software providers, data storage providers, payment processing providers and business consultants.

7.2 Shops

Klarna shares personal data with stores you visit or shop with (which may include the store's group companies, if the store has informed you). This is to allow the store to fulfill and manage your purchase and administer your relationship with the store or its group, such as verifying your identity, sending you merchandise, handling queries and disputes, sending you relevant offers and preventing fraud. Personal data shared with a store will be subject to their privacy policies.

7.3 Payment Service Providers (“FSPs”) and Financial Institutions

FSPs provide merchants and Klarna with services for accepting and managing electronic payments through a variety of payment methods, including credit cards, direct debit payments, bank transfers etc. Some merchants use FSPs with whom they share your data for payment processing. This sharing is done in accordance with the merchants' privacy policies. Merchants may also require us to share your information with FSPs for payment processing and administration. Some FSPs collect and use your data themselves, in accordance with their own privacy policies. This is the case, for example, if you use an e-wallet.

Additionally, in order to process transactions, Klarna may share your data with other financial institutions when you make transactions with your account.

7.4 Credit rating agencies

If you apply to use a Credit Service (see paragraph 4.1 for the specification of the relevant Credit Services), your personal data may be shared with credit reference agencies (“ARCs”). to assess your credit score in relation to your credit application, to confirm your identity and contact details, and to protect you and other customers from fraud. Such sharing constitutes a credit check.

In Italy, Klarna sends your address, date of birth and tax code to Credit Reference Agencies in order to receive a verification on your profile.

Our checks impact the Credit Reference Agencies' assessment of your credit profile. Klarna also shares information about your repayments (including late repayments and undisputed missed payments) with the Credit Reference Agencies, and this data may be included in credit default files, which may also impact the Credit Reference Agencies' assessment, and may be accessed by third parties. The Credit Reference Agencies process your data in accordance with their own privacy policies; Below you can find a list of the Credit Reference Agencies we cooperate with.

Please note that Klarna only stores the credit assessment received from an ARC in data script format. We therefore recommend that you request a copy of the assessment directly from the ARC if you wish to view it in a legible form.

7.5 Fraud prevention and identity verification agencies

Your personal data may be shared with fraud prevention and identity verification agencies for the purposes of verifying your identity, the accuracy of the data provided and the prevention of criminal activity. The agencies we cooperate with in Italy are listed here . The user's attention is drawn to the fact that These companies process data in accordance with their own privacy policies.

7.6 Klarna Group Companies

Your data may be shared with other companies in the Klarna group, based on Klarna's legitimate interest in conducting 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 alongside us, in accordance with their applicable privacy policies.

7.8 Subject holding power of attorney provided by the user

Klarna will share your data based on your consent if we have received a power of attorney from you for a third party. This sharing will be done based on your consent.

7.9 Google

When you use Google Maps in checkout (for example, by searching for your address in the search section) or the Klarna App, Google will process your information subject to the Google Maps/Google Earth terms of service and privacy policy. Additionally, when you use the Klarna App via a browser, Google collects information about your device through the reCAPTCHA service implemented therein, sometimes in combination with any information entered into the reCAPTCHA service. Google will process this information in accordance with its privacy policy . Klarna processes this data on the basis of its legitimate interest in conducting its business, as the reCAPTCHA service prevents abuse of its Services.

7.10 Authority

Klarna may disclose necessary data to police, tax or other authorities if required by law or by you in certain circumstances or if necessary to administer tax deductions. For example, disclosures required by law include those related to anti-money laundering or terrorist financing obligations.

7.11 Logistics and transport companies

Klarna may share your personal data with logistics and transport companies for the delivery of your goods or if you have chosen to track/monitor your shipment. For example, we may share your contact and identification data and your shipment number. Please note that logistics and transport companies will process your data in accordance with their own privacy policies.

7.12 Partners in the Personal Finance Service and in the Offers and Benefits program

If you choose to participate in offers and benefits that Klarna provides in the Personal Finance Service or through the Offers and Benefits Program, Klarna may share personal data necessary to enable you to access offers made in cooperation with our partners (this includes the fact that you are a Klarna customer). Information on what data is shared is provided with each offer. 

7.13 Debt collection agencies and other buyers of outstanding debts

Klarna may share your data in the event that we assign your outstanding debts to third parties or assign them for the collection of such debts, for example to debt collection agencies. Such sharing of personal data is done on the basis of our legitimate interest in carrying out debt collection and assignment. Debt collection agencies or any other acquirers may process your personal data in accordance with their own privacy policies or on behalf of Klarna.

Debt collection agencies or any other buyers may also report your unpaid debt to credit reference agencies, which may affect your credit score and ability to get credit in the future.

7.14 Affiliate Networks

Klarna may share the information that the user has clicked on link sponsored links (i.e. links that promote stores, products or services) with so-called "affiliate networks". This sharing occurs when you click on a sponsored link, as you are redirected to the store's website through the "affiliate network". The affiliate network may place tracking technology on your device that contains the information that you have clicked on a sponsored link in one of Klarna's interfaces, in order to track your visit to a store to calculate potential commissions to Klarna. Affiliate networks may process your personal data in line with their own privacy policies.

7.15 Transfer

• If Klarna buys or sells any credit, business or well, it can share the user's personal data to the potential buyer or seller of the credit, business oh well .

• If Klarna itself or substantially all of its business is acquired by a third party, personal data of Klarna customers may be shared.

8. How Klarna stores your personal data

We strive to process your personal data within the EU/EEA. In certain circumstances, for example when we share your personal data with a Klarna Group company, supplier or subcontractor based outside the EU/EEA, your personal data may also be transferred to and processed at a location outside the EU/EEA. If the store where you make your purchase is located outside the EU/EEA, sharing your personal data with the store will also result in a transfer of data outside the EU/EEA.

We ensure that an adequate level of protection for your personal data is maintained and that appropriate safeguards are in place in accordance with applicable data protection legislation such as the GDPR when your personal data is transferred outside the EU/EEA. These safeguards consist of ensuring that the third country or state in question is subject to an adequacy decision by the European Commission, or implements European Commission standard contractual clauses.

9. Duration of processing of personal data

We process your data for the period of time necessary to achieve the purposes of the processing. These purposes are described in this Privacy Policy. Therefore, your personal data will be maintained even if a purpose ceases to exist if it is required for different purposes, and exclusively for the same. In particular:

• if the user has accepted the Terms of Service Klarna and for the duration of these Terms (by asking or instructing us to delete data for example by virtue of the right to erasure/to be forgotten), we will process personal data necessary to provide the Services to you, including without limitation data relating to previous purchases;

• we process your personal data relating to stock receivables for the purposes of new credit assessments for a period of 90 days from the date of the search;

• we process personal data relating to debts for the purposes of re-assessing creditworthiness for a period of 3 years from the date of settlement of the debt by means of a settlement, write-off or assignment carried out by Klarna;

• we retain telephone recordings for a period of 90 years to ensure quality assurance;

• We process your personal data in compliance with applicable laws, such as consumer protection, banking, anti-money laundering and accounting regulations. Depending on applicable law, your personal data may be retained for a maximum period of 10 years from the end of the relationship with the customer.

10. Your rights regarding your personal data

• Right of access to information. The user You have the right to obtain information on how your data is being processed. We comply with this obligation with this Privacy Policy, through the information available on the website and with our responses to requests sent to us by the user.

• Right of access to data. You may request a copy of your data if you wish to know what data we hold about you. We can provide you with a copy of this data in electronic format (i.e., “data portability”).

• Right to rectification. The user has the right to obtain the rectification of inaccurate or incomplete data concerning him.

• Right to erasure (to be forgotten). You have the right to request the deletion of your personal data, for example when it is no longer necessary for the purposes for which it was collected or when you have withdrawn your consent. As specified in paragraphs 3 and 9 above, Klarna must however comply with certain legal obligations that prevent us from deleting some of your personal data immediately.

• Right to limit data processing or to object to data processing. If the user believes that the data is incorrect or that it is being processed unlawfully , these you have the right to ask us to stop processing. You can also object to processing where you believe there are circumstances that would make such processing unlawful. In addition, you can always object to our use of your data for direct marketing.

• Right to challenge an automated decision. You have the right to challenge an automated decision made by Klarna. See Section 6 for more information on how Klarna uses automated decisions.

• Right to withdraw consent. As set out in Section 5, where Klarna processes your data based on your consent (whether explicit or not), you may withdraw your consent at any time.

• Rights to apply the instructions post-mortem . You have the right to give (or designate the person authorised to do so) instructions on the storage, deletion and communication of personal data after your death).

• Right to lodge a complaint. You have the right to lodge a complaint with a national supervisory authority or the Swedish Data Protection Authority. The complaint to the Swedish authority can be submitted via the website https://www.datainspektionen.se/other-lang/in-english/ .

• Checking service settings. In the Klarna App, Klarna allows you to customize your preferences for certain Services, such as whether you want to receive personalized notifications or marketing. We will always respect your choices.

11. Cookies and other tracking technologies

We use cookies and similar tracking technologies to provide a pleasant and personalized experience in our interfaces. online , such as on our website, the Klarna App and the checkout of stores that cooperate with Klarna. You can find information about the tracking methods used by Klarna, and accept or reject the tracking technologies in the relevant interface.

12. Updating the Privacy Policy

We are constantly working to improve our Service offerings to provide you with an increasingly enjoyable experience. This includes both changes to existing Services and offering new Services over time. It is therefore important that you read this Privacy Policy each time you use a Klarna Service, as the processing of your personal data may be different than the last time you used the Services.

13. How to contact us

Klarna Bank AB (publ) is a company registered in the Swedish Companies House under number 556737-0431. Klarna's head office is at Sveavägen 46, 111 34 Stockholm, Sweden.

Klarna has a Data Protection Officer and a team of data protection specialists dedicated exclusively to data protection and privacy. Klarna also has a dedicated team of customer service specialists for data protection issues. Further information can be requested by writing to privacy@klarna.co.uk.

Klarna Bank AB (publ) is subject to Swedish data protection law. Further information about Klarna can be found on the website www.klarna.com .

The controller of your personal data is Klarna Bank AB (publ), a company subject to the Swedish Data Protection Act. For more information about Klarna, please visit https://www.klarna.com/international/ .

Last updated: December 3, 2020