This privacy policy applies to processing of personal data by Segelman Virtual Stores AB (hereinafter

referred to as “Virtual Stores”).

Virtual Stores is committed to the protection of your personal data and to ensuring compliance with

applicable data protection legislation, including without limitation Regulation (EU) 2016/679 of the

European Parliament and of the Council of 27 April 2016 on the protection of natural persons with

regard to the processing of personal data and on the free movement of such data (the “GDPR”).

This privacy policy explains how and for what purposes Virtual Stores processes your personal data

when you use Virtual Stores’ system (hereinafter the “App”) on the mobile computer at your

workplace. The privacy policy also explains what rights you have in relation to the processing of your

personal data.

Virtual Stores is the controller of personal data processed in accordance with this privacy policy. If

you have any questions regarding the processing of your personal data you can contact Virtual Stores

using the following contact details:

Virtual Stores AB, reg. no.: 556888-7615, e-mail: [email protected]

Categories of personal data

Virtual Stores may process the following personal data when you use the App on the mobile

computer:

• username;

• name;

• email;

• password (encrypted);

• gyroscope data;

• accelerometer data;

Purposes of processing and legal basis for processing

Virtual Stores needs to process the personal data to be able to provide the functions of the

App/system. The processing is also necessary for Virtual Stores to be able to analyse the movement

of the staff within the storage area and for Virtual Stores to be able to analyse and improve the

functioning of the positioning technique. The legal basis for the processing is that the processing is

necessary for Virtual Stores’ legitimate interests to provide the functions of the App and to analyse

the movement of staff within the storage area as well as for Virtual Stores’ legitimate interest to

evaluate and improve the functioning of the App.

The processing is based on a balancing of Virtual Stores’ legitimate interests and the interests, rights

and freedoms of yourself and the other persons that the personal data relate to.

Disclosure of personal data

Virtual Stores will disclose limited personal data, such as statistical data, to your employer,

Veddestagruppen.

Virtual Stores may also disclose personal data to service providers engaged by Virtual Stores. Virtual

Stores will only disclose personal data to service providers to the extent necessary for the

performance of the service providers’ services for Virtual Stores. Service providers need to enter

written data processing agreements with Virtual Stores prior to gaining access to and processing

personal data on behalf of Virtual Stores. Such data processing agreements contain provisions on

confidentiality as well as provisions that entail that the service providers need to comply with Virtual

Stores’ written instructions when processing personal data. For the avoidance of doubt, service

providers will not be entitled to process personal data for other purposes than those determined by

Virtual Stores.

In exceptional cases, Virtual Stores may disclose personal data to competent authorities and/or to

other authorized receivers of personal data if Virtual Stores is obligated to do so under mandatory

legislation and/or according to a binding decision of a competent authority.

Transfers of personal data to countries outside of the EU/EEA

Virtual Stores processes personal data on servers located in Sweden and Ireland.

Virtual Stores’ service providers may, however, engage sub-processors, which are located outside of

the EU/EEA, to process personal data, i.e. for support purposes.

Virtual Stores will ensure that any transfers of personal data to countries outside of the EU/EEA will

be performed in accordance with the GDPR. Transfers of personal data to countries outside of the

EU/EEA are subject to appropriate safeguards (such as the standard data protection clauses adopted

by the Commission and, where necessary, appropriate supplementing measures).

Data retention and deletion

Virtual Stores will only retain personal data for as long as it is necessary in order to fulfill the relevant

purposes described in this Privacy Policy. Data collected by Virtual Stores through your use of the

App will be anonymized by Virtual Stores when it is no longer necessary to identify you or another

person for the relevant purposes of the processing. Virtual Stores analyses and anonymizes personal

data every two years in order to ensure that personal data is not retained for longer than is

necessary for the fulfilment of the relevant purposes of the processing.

Your legal rights

The GDPR confers several rights on you in your capacity as a data subject. Virtual Stores is

responsible for ensuring that your rights under the GDPR are complied with when processing your

personal data.

You are entitled to access personal data that Virtual Stores processes about you. You are also entitled

to receive an extract of the data.

You also have the right to have incorrect personal data about you rectified. You may also request

that Virtual Stores deletes personal data that relate to you and/or that Virtual Stores restricts the

processing of such data. You may also object to the processing of personal data that relate to you.

Virtual Stores will respond to requests regarding your rights under the GDPR as soon as possible.

Virtual Stores will comply with all requests that are justified under the GDPR or other applicable data

protection laws.

You may always contact the Swedish Data Protection Agency (Sw. Integritetsskyddsmyndigheten) if

you have complaints regarding Virtual Stores’ processing of personal data.