4. Privacy policy

9 February 2022

This privacy policy describes the processing of Personal Data that occurs when the User uses the Safeture Services.

4.1 General

4.1.1 We are committed to protecting your privacy and to comply with applicable data protection and privacy laws. Throughout this privacy policy, (the “Privacy Policy”), the term “Personal Data” means information relating to an identified or identifiable individual (i.e. a natural person).

4.1.2 This Privacy Policy applies to the processing of Personal Data collected or submitted by you in connection with the use of the products and the Safeture Services, offered by us and our affiliates, partners, suppliers and customers. Please read this Privacy Policy carefully to understand how we collect, use, transfer, and store your data as you make full use of the Service.

4.1.3 Please note that if you read this Privacy Policy in the capacity of a representative or contact person of one our potential or existing customer, partner, supplier or other business contact, we kindly refer you to our general external privacy policy, available at www.safeture.com/privacy-policy-for-external-contacts, which describes our processing of your personal data.

4.1.4 We recognize our responsibility to protect the Personal Data and other information you have provide us with. We take appropriate technical and organizational information security measures to safeguard your Personal Data against loss and misuse, as well as unauthorized access.

4.1.5 In this Privacy Policy, we explain which types of Personal Data we may process about you and for what purpose we process them. We also detail our processing of Personal Data as well as what choices and rights you have in relation to such processing. We kindly ask you to carefully review our Privacy Policy and acquaint yourself with its content.

4.1.6 Please note that if you use the Safeture Services as a service provided directly from Safeture then this Privacy Policy relates to processing of Personal Data for which we are the controller. This means that we are responsible for the processing of your Personal Data. It also means that you should turn to us with questions or remarks, or if you wish to enforce any of your rights in relation to our processing of your Personal Data.

4.1.7 Please note that if you use the Safeture Services as a service provided by your employer or contracted party, in your capacity as an employee, consultant, agent or other representative, the employer or contracted party is the responsible controller of your Personal Data within the scope of our provision of the Safeture Services. We only process data on behalf of your employer or contracted party.

4.1.8 Unless your employer or contracted party has provided you with a privacy policy informing you about the processing applicable to the Safeture Services, this privacy policy shall apply between you and your employer or contracted party. Please note that if your employer or contracted party is located outside of the EU/EEA, there may be limitations to which rights you as a data subject may exercise due to local mandatory law. For questions regarding the processing of your Personal Data in such cases, or if you want to exercise your rights, please contact your employer or contracted party as instructed in your employer’s or contracted party’s general privacy policy.

4.2 The data we collect when we provide the service

4.2.1 As described in section 2.3.3 the Personal Data processed by Safeture due to your use of the Safeture Services is divided into two sensitivity classes A and B. Class A is sensitive Personal Data, i.a. passport information and medical data, and class B is less sensitive Personal Data, i.a. your name and telephone number. Safeture accounts for the sensitive nature of Class A Personal Data, and takes additional precautions for the processing of such Personal Data.

4.2.2 A full list of the User Personal Data processed by Safeture in the provision of the Safeture Services, including a categorization of such data as Class A Personal Data and Class B Personal Data, can be found at Safeture’s website www.safeture.com/personal-data-classification:

4.2.3 If you use the Safeture Services as a service provided by your employer or contracted party in your capacity as an employee, consultant, agent or other representative, and your employer or contracted party has purchased additional services which include processing of Class A Personal Data, we may process such data. In this situation your employer or contracted party is the data controller and is, as such, the party responsible for ensuring that the processing of the Class A Personal Data is lawful.

4.2.4 If you use the Safeture Services as a consumer and Safeture acts in the role of a data controller, then Safeture will never process the specific Class A Personal Data, such as your medical data, which has been detailed as such at Safeture’s website www.safeture.com/personal-data-classification. For clarity, Safeture’s processing of such detailed Class A Personal data will only occur in the circumstances set out in section 4.2.3 above.

4.2.5 In addition to the Personal Data described above, Safeture may process information of how you use the Safeture Services in order to compile statistics that are used in order to improve the Safeture Services and to provide you with relevant functionality of the Safeture Services. Your personal data will be pseudonymized before Safeture processes it for the purposes mentioned in this section 4.2.5.

4.2.6 If you use the Safeture Services in your capacity as an employee, consultant, agent or other representative, and your employer or contracted party in writing has objected to our processing of the information of how you use the Safeture Services described in Section 4.2.5, we will not process such information. In such event, we will only process information of how you use the Safeture Services in accordance with section 4.3.4 below.

4.3 The purposes for which we collect and process your personal data

4.3.1 We process your Personal Data for the purpose of providing you with the Safeture Services, including tracking your geographical location. Location data is collected both when using the service actively and passively in the background. The type of location data that is collected is dependent on your privacy settings. The location data is processed to keep track of User's location in order to fulfill the security service. If you use the Safeture Services as a service provided by your employer or contracted party in your capacity as an employee, consultant, agent or other representative, your employer or contracted party may have access to the location data and other Personal Data for the purpose of providing security services. The processing is conducted on the basis that it is necessary for the performance of our contract with you regarding the provision of the Safeture Services. Please note that you need to enable the real time location and sharing of the location data if want to use functionality of the Safeture Services that is dependent on location data.

4.3.2 The Personal Data described in Section 4.2.2 is processed for the purpose of providing you with a functionality of the Safeture Services as agreed between your employer or contracted party and Safeture. The functionality, and the Personal Data described in Section 4.2.3, is processed by your employer or contracted party for example when assessing the medical risks with an upcoming business trip or to ensure that you obtain the correct medical treatment in case of emergency. The processing is conducted on the basis of your consent. Your employer or contracted party is the data controller and the party responsible for obtaining your consent.

4.3.3 The Personal Data described in Section 4.2.5 is processed for the purpose of improving the Safeture Services and to provide you with relevant functionality of the Safeture Services by understanding how the Users use the Safeture Services. The processing is conducted on the basis of our legitimate interest to collect information to maintain and improve the functionality, content, and security of the Safeture Services.

4.3.4 We may also process your data for the purpose of further analysis, statistical information and to optimize the user experience. Prior to such processing, your Personal Data will be anonymized, meaning that the Personal Data will no longer be attributable to you and thus not considered Personal Data. The anonymization is conducted on the basis of our legitimate interest to be able to improve the Safeture Services and carry out statistical analysis regarding the usage of the Safeture Services for future optimization.

4.4 Storage of personal data

4.4.1 We store your Personal Data as long as necessary for us to fulfil the purposes of the processing. This means that we will process your Personal Data as long as you are an active user with our Safeture Services, however location data will be kept for a maximum period of eighteen (18) months.

4.4.2 When your Personal Data is no longer necessary for the purposes of the processing, it will be deleted or anonymized. We will, however, store your Personal Data if and to the extent we are required to do so according to law.

4.5 Sharing your personal data

We may disclose your Personal Data to our data processors, for example companies providing the Safeture Services or hosting and cloud services companies. In such cases, a data processing agreement will be entered into which ascertains that your Personal Data is processed in accordance with this Privacy Policy.

4.6 Third country transfers

To be able to provide the Safeture Services, your Personal Data may be transferred to a country outside of the EU/EEA. If your Personal Data are transferred to a country outside the EU/EEA we will provide adequate safeguards to protect your Personal Data. If Safeture is the controller of your Personal Data you can obtain a copy of the safeguards applied by contacting us at the e-mail address stated below. Your Class A Personal Data may not be subject to a third country transfer unless your employer or contracted party, specifically instructs us to transfer such Personal Data. If your employer or contracted party is the controller of your Personal Data you must then contact your employer or contracted party to obtain a copy of the applied safeguards.

4.7 Your rights

4.7.1 You have the right to receive confirmation on whether or not we process Personal Data concerning you, and in such cases get access to such Personal Data and also information regarding the Personal Data and how we process it.

4.7.2 You have the right to have inaccurate Personal Data concerning you rectified without undue delay. Taking into account the purposes of the processing, you also have the right to have incomplete Personal Data about you completed.

4.7.3 You have, under certain circumstances, the right to have Personal Data concerning you erased, for example if the Personal Data are no longer necessary in relation to the purposes for which they were collected or if the Personal Data have been unlawfully processed.

4.7.4 In some circumstances you have the right to obtain restriction of the processing of your Personal Data. For example if you contest the accuracy of the Personal Data, you can also require that we restrict the processing of your Personal Data for such a period that enables us to verify the accuracy of the Personal Data.

4.7.5 You have the right to object to processing of your Personal Data that is based on our legitimate interests. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your Personal Data.

4.7.6 You have the right to receive the Personal Data relating to you and that you have provided to us, in a commonly used electronic format. You have the right to transmit that data to another controller (data portability).

4.7.7 You have the right to complain on the processing of your Personal Data by lodging a complaint to the Swedish Authority for Privacy Protection or any other relevant data protection authority governing the processing of your employer or contracted party.

4.8 The controller of your personal data and contact details

4.8.1 If Safeture is the controller of your Personal Data, and if you have any additional questions or concerns about this Privacy Policy or our information practices, please feel free to contact us at any time.

Safeture AB

Attention: DPO

Kung Oskars väg 11 c

222 35 Lund

Sweden

4.8.2 Contact to the data protection officer: dpo@safeture.com

4.8.3 If your employer or contracted party is the controller of your Personal Data, please contact your employer or contracted party for any questions or concerns.

4.9 California Residents

Please refer to the California Privacy Rights Notice at www.safeture.com.