Cookie usage and consent management designed to align with EU ePrivacy Directive and Swedish law
This policy is designed to follow the EU ePrivacy Directive and Swedish Electronic Communications Act (ECA). We aim to stay up to date with future IMY and EU guidance. Your consent choices are respected and can be changed at any time.
Company:: Bromander Global AB
Address:: Ringaby 432, 718 92 Frövi, Sweden
Contact:: support@bromanderglobal.com
Supervisory Authority:: Swedish Post and Telecom Authority (PTS)
This Cookie Policy explains how Bromander Global AB uses cookies and similar technologies on our website. We are committed to transparency and following the principles of the EU ePrivacy Directive and Swedish Electronic Communications Act.
Our digital services (Shinery, Smart Bookkeeping) may have additional cookie considerations for their specific features. This policy covers the Bromander Global website.
We process cookies based on the following legal grounds under EU and Swedish law:
Swedish ECA § 28 exemption for cookies that are strictly necessary for service provision:
All other cookies require explicit consent before placement:
Swedish authorities (IMY/PTS) actively enforce cookie consent requirements. In April 2025, new guidelines prohibited "dark patterns" in consent interfaces, requiring equal treatment of "Accept" and "Reject" options.
We comply with Swedish and EU requirements for cookie consent, following 2025 enforcement guidelines:
Initial Visit: Cookie banner appears with clear accept/reject options
Change Preferences: Access cookie settings at any time via footer link
Withdraw Consent: Disable any non-essential cookies instantly
Browser Settings: Additional control through browser preferences
Following IMY guidelines from April 2025, our consent mechanism avoids "dark patterns" and ensures genuine user choice. All consent is documented and can be audited.
The digital age of consent in Sweden is 13 years. Users under 13 require parental consent for any data processing, including cookies that collect personal information.
We carefully select third-party services and ensure they comply with EU/Swedish data protection laws:
Purpose: Website analytics and performance monitoring
Data Processing: EU servers, IP anonymization enabled
Consent Required: Yes - Analytics category
Cookies Set: _ga, _ga_*, _gid, _gat_gtag_*
Duration: 13-24 months
Google Privacy PolicyPurpose: B2B marketing analytics and audience insights
Data Processing: EU/US with Standard Contractual Clauses
Consent Required: Yes - Marketing category
Cookies Set: li_sugr, lidc, UserMatchHistory
Duration: 30 days to 2 years
LinkedIn Privacy PolicyPurpose: Performance, security, and DDoS protection
Data Processing: EU servers, essential functionality
Consent Required: No - Strictly necessary
Cookies Set: __cflb, __cf_bm, cf_clearance
Duration: Session to 1 year
CloudFlare Privacy PolicyUnder Swedish and EU law, you have comprehensive rights regarding cookies and tracking:
Chrome: Chrome: Settings → Privacy and security → Cookies and other site data
Firefox: Firefox: Preferences → Privacy & Security → Cookies and Site Data
Safari: Safari: Preferences → Privacy → Manage Website Data
Edge: Edge: Settings → Cookies and site permissions
Essential Cookies: Cannot be disabled; may prevent basic website functions
Analytics Cookies: Website remains functional; we cannot improve user experience
Functional Cookies: May require re-entering preferences on each visit
Marketing Cookies: Less relevant content and advertising
Access your cookie preferences at any time:
Session Cookies: Deleted when you close your browser
Persistent Cookies: Automatically expire after specified duration
Analytics Data: Aggregated and anonymized after 26 months
Consent Records: Maintained for 3 years for compliance purposes
We follow GDPR data minimization principles, collecting only necessary cookie data and retaining it for the shortest time required for its stated purpose.
Some third-party cookies (Google Analytics, LinkedIn) may transfer data outside the EU. We ensure adequate protections through Standard Contractual Clauses and adequacy decisions.
Minor Changes: Updated immediately with new "last updated" date
Material Changes: 30 days advance notice via email and website banner
New Cookie Categories: Fresh consent required before deployment
Version History: Previous versions archived for compliance audit
EU ePrivacy Directive: Implemented via Swedish ECA
GDPR: Article 6 legal basis and Article 7 consent requirements
Swedish Authorities: PTS (technical) and IMY (data protection) oversight
2025 Guidelines: Compliant with IMY dark patterns guidance
We conduct quarterly reviews of our cookie inventory, consent mechanisms, and compliance with evolving Swedish and EU requirements to ensure ongoing legal compliance.
As cookie technology evolves (e.g., Topics API, Privacy Sandbox), we will update this policy and obtain fresh consent as required by Swedish law.
For questions about cookies, consent management, or this policy, please contact us:
Bromander Global AB
Örebro, Sweden
For cookie-related complaints in Sweden:
Swedish Post & Telecom Authority (PTS): pts.se | Email: pts@pts.se
Swedish Authority for Privacy Protection (IMY): imy.se | Email: imy@imy.se
Cookie questions: Cookie questions: 3 business days
Consent issues: Consent issues: Same day
Technical problems: Technical problems: 24 hours
Legal inquiries: Legal inquiries: 5 business days
If you need this Cookie Policy in an alternative format for accessibility reasons, please contact us and we will provide it in a suitable format within 3 business days.
This Cookie Policy is effective as of the last updated date and applies to all visitors to our website. By continuing to use our website after reading this policy, you acknowledge understanding of our cookie practices.