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  • PRIVACY POLICY

    GENERAL

    This document was last updated on 09 November 2018.

    “We”, “us” or “our” refers to 2Secure AB, reg. no. 556695-7543, box 34037, 100 26 Stockholm, including its affiliates.

    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).

    This Privacy Policy applies to the processing of Personal Data collected or submitted by you in connection with the use of the products and services (the “Service”) offered by us and our affiliates, partners and suppliers. 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.

    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.

    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.

    Please note that 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.

    Please note that if you use the Service as a service provided by your employer in the capacity as employee, the employer is the responsible controller of your Personal Data within the scope of our provision of the Service. We only process data on behalf of your employer. For questions regarding the processing of your Personal Data in such cases, please contact your employer.

    THE DATA WE COLLECT WHEN WE PROVIDE THE SERVICE TO YOU AS A CONSUMER

    We may process the following Personal Data attributable to you as a user of the Service:

    • Name;
    • E-mail address;
    • Telephone number;
    • Gender;
    • Passport number;
    • Nationality;
    • Job title;
    • Manager;
    • Department/group;
    • Location;
    • Imsi;
    • Base station information;
    • IP address; and
    • Home country.

    THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA

    We process your Personal Data for the purpose of providing you with the Service, including tracking your geographical location. The processing is conducted on the basis that it is necessary for the performance of our contract with you regarding the provision of the Service. Please note that you need to enable the real time positioning and sharing if want to use the real time positioning sharing functionality of the Service.

    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 Service and carry out statistical analysis regarding the usage of the Service for future optimization.

    STORAGE OF PERSONAL DATA

    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 Services, however that location data and base station data will be kept for a maximum period of three months.

    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.

    SHARING OF YOUR PERSONAL DATA

    We may disclose your Personal Data to our data processors, for example companies providing the Service 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.

    THIRD COUNTRY TRANSFER

    To be able to provide the Service, 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 pro-vide adequate safeguards to protect your Personal Data, e.g. that the receiving country has an adequate level of protection. To obtain a copy of the safeguards applied, please contact us at the e-mail address stated below.

    YOUR RIGHTS

    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.

    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.

    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.

    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.

    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.

    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).

    You have the right to complain on the processing of your Personal Data by lodging a complaint to the Swedish Data Protection Authority.

    THE CONTROLLER OF YOUR PERSONAL DATA AND CONTACT DETAILS

    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 at: 2Travel@2secure.se

     

    CHANGES TO THIS PRIVACY POLICY

    We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at https://2secure.se/privacy-policy-2travel/