Legal, Data Protection, and IT Security

Where can the End User License Agreement (EULA)/Terms of use & privacy policy be found?

You can read the documents in the app by going to the profile and the privacy tab, or here on our web page.

What is the basis of the contractual relationship associated with the use of the app?

The Terms of Use is a contract between the user and Safeture AB.

What are the purposes of the service?

The main purpose of the app is to provide users with useful security-related information before and during business trips, both via Country information and alert messages. The app may include contact information to Assistance and/or Security providers. In addition, the system also allows Safeture to geolocate the user based on the location of the device when the app is running (even when the App is not being used, but just running in the background) and when the user consents to the geolocation function. Safeture will provide this data to the employer, subject to each user’s consent by accepting the Terms of use. Safeture will not use the location data for any other purpose. The system also allows employers to send SMS/Email via the dashboard to employees, based on the email and phone number registered by the employee when registering into the system.

Who are the categories of data recipients?

Safeture AB
The employer

What data can be accessed, and who can access the data?

Safeture AB:

Who can access data from Safeture AB?
Access to the data is strictly monitored (by audit logs) and direct access to the database is only given to certain administrators within Safeture. All passwords are hashed and each and every handset has its own encryption key when communicating with the server backend. The data storage is supervised by very strict firewall rules. Safeture performs security reviews several times per year using external specialists and security patches are applied on the servers and firewalls when released.
What data does Safeture have access to?
Access to all data categories, including position data.

The Employer:

Who can access data from the employer?
Access to the data is defined by your employer. The employees are entirely defined by your company, usually by the responsible for Human Resources, Risk Management, or Security Management.
What data does the employer have access to?
Access to all data categories including position data of all employees registered under the Subscription ID, as well as all sub-groups of that policy.

Who can access tracking/location data?

Safeture AB: Full access to the tracking data is only given to selected Safeture employees when needed for technical development and support issues. The only government authority that may access the data is the Swedish police authority and requires a legal warrant from the Swedish justice system. Safeture keeps strict rules around information access and advanced levels of IT security protection, requiring that each access to the data is logged in an audit log for misuse inspection.

The Employer: Access to the tracking data is only given to the employer related to the Subscription ID/reference you include when registering and only when the user-provided explicit consent in providing the location data. The employer can only see their own end-users and can decide who within the organization that has access to this data. Safeture will not be responsible for any employer’s internal process, which should be controlled and managed by the employer and regarding the data, accessible through the system.

Note that only the very last position for an end-user is provided, and position history can only be provided to companies and partners if requested. Such requests are handled case by case and only if Safeture deems it to be a valid reason for such request and it is for the benefit of the end-user.

Note that the Employer is the data controller and has the legal right to access all employee’s personal data depending on the privacy agreement between the employee and the employer.

What are the categories of the data subjects?

Employees, as stated under privacy policy. Note that the term “employee” is a broad enough term to cover any person with a contractual relationship with the organization using the Safeture platform.

What are the categories of data processed?

Categories of personal data (End-User):

First name
Last name
Country of residence
Network information (E.g. IP-address)
Email address*
Mobile Phone number*
Position data* (restricted and when consent by End-user)

* required data for the service to function properly

The personal data that is processed includes all the above as well as additional personal information added to the system by the user or by the employer (through the web portal), as for example company department, group, etc.

Are any special categories of data processed (i.e. Social security and passport number)?

None, unless the employer includes such data via the web portal, where there are the following non-mandatory fields: Address, Zip Code, City, State, Department, Nationality, Gender, Job title, Passport number, and Line manager.

Which communication steps are intended to notify data subjects about the processing?

This is communicated via the Privacy Policy & Terms of Use.

What is the legal ground for non-European 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 is transferred to a country outside the EU/EEA we will provide 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 support@safeture.com.

For European citizens, personal data is only transferred outside the EU/EEA in case of support cases and no data is transferred outside the EU/EEA for standard operations. For non-European citizens the personal data is stored and processed identically as for European citizens unless local law has specific data transfer legal requirements for local citizens.

Who are the controllers of the data?

If you have received the service through your employer then the employer is the data controller. If you have purchased the service as a consumer directly from Safeture then Safeture is the data controller.

Who are the processors of the data?

The data processor is Safeture AB and the processing of data is conducted in Sweden.

What are the Purposes of Processing?

The purpose for which we process personal data are stated in Privacy Policy & Terms of Use, including the purpose of Safeture regarding usage of 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 basic necessity for the performance of our contract with you regarding the provision of the Service. Please note that you need to enable 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.

How is data security ensured?

Several times every year, external consultants are reviewing the systems from a security overview perspective. They not only perform traditional penetration tests but also review all new source code and perform security checks on the production network and the office network. Extra checks are done when new apps are released, or new specific functions are added to the system. External reports are available at request.

How do you protect customer privacy?

Safeture meets the stringent requirements in accordance with GDPR and adheres to the strict regulations covering information access and IT security.

At the core of the Safeture concept is the idea of protecting the end user’s privacy. The app user can easily disable all service including positioning capabilities. The app user may also set positioning precision to country-level which means that the app will only report which general country or region the user is located in, keeping the user’s location more private. Furthermore, the Risk Manager responsible for the overviewing system at a company or organization can only expose the last known position and not historic positioning information. The technology is tailored in such a way that the end-user is always in control of his or her privacy. Safeture is based in Sweden, a country that has a long history of protecting the privacy and rights of employees. Safeture is required by law to provide any end-user with information on all data stored related to him/her. The deletion of any data related to an individual or organization will be done upon request to support@safeture.com.

Where is the data stored?

Safeture operates all servers and stores all the data within the borders of Sweden that guarantee that the data protection and privacy are under Swedish law and jurisdiction.

How long is data kept in live systems (data retention policy)?

All generated data is stored for up to 18 months. For direct consumers, the data is stored up for 3 months.

Which standard deletion periods are defined (data retention policy)?

Data is deleted after 3, 6, 12, and 18 months, depending on the sensitivity of the data.

3 months: Alerts sent
6 months: Logs, access logs, etc.
12 months: SMS data
18 months: Location data, Personal data

What if I want to obtain data stored which relates to me as an individual?

Safeture is required by law to provide a person with information on all data stored concerning that person and to delete any data related to an individual or organization upon request.

What is the procedure in place in case of disaster/failure?

Full data backup is performed every day and the system is live replicated to several off-sites. The off-sites are running in cold standby and failover to these redundant systems can be done quickly and efficiently.

Do you have a documented Disaster Recovery (DR) plan and how often is it tested?

Yes, it is tested yearly.

Is there a store backup in a secure, separate facility that is of sufficient distance from the main location to enable recovery?

Yes.

Do you have a separate Work Area Recovery site?