Privacy Policy - WirelessCar

Introduction

On this page, we provide you with information about how WirelessCar complies with its data protection obligations. We recognize that ensuring the protection of individuals’ right to privacy is not only a legal obligation, but it is also an ethical imperative and a sound business strategy. It is our belief that by demonstrating our commitment to the lawful and fair processing of personal data, we build trust between us and our staff, business clients, end-customers, and other individuals that we interact with.

The purpose of this page is to provide you with clear and straightforward information about how we interact with and approach personal data that we encounter in the course of conducting our business. We also provide you with case-specific notices detailing our use of your personal data in various context (Information Notices).

If you have any questions about this document, feel free to contact us at . You will find further contact information at the end of this page.

WirelessCar as a Data Processor

Our core business is to provide our business clients (actors in the automotive industry) with connectivity-related services that enables their vehicles to provide useful functionality towards their end-customers. In this context, WirelessCar is operating on behalf of our clients and is performing any processing of personal data relating to these end-customers in our roles as a data processor. This means that, in terms of how and why personal data is used, we act on the instructions of our clients, as part of our commercial agreement.

This means that with regard to such processing activities, you (the data subject) are referred to the respective client for further information. This page only addresses processing of personal data which WirelessCar undertakes in our role as data controller, meaning that we are the one fully responsible for the proper and fair use of your personal data.

Our privacy principles

To ensure that we fulfil our legal obligations towards the law and our commitment to our clients, WirelessCar operates on a set of privacy principles that are incorporated into our business operations. These principles encompass the key aspects of data protection and end-customer privacy.

Lawfulness

We recognize that your personal data belongs to you, and we only use it when necessary and legally permitted. For example, in some instances, we may be legally required to process your data, while in other situations we may rely on one or more legitimate interests of use. And in some cases, we will ask for your direct consent, in which case you will always be able to revoke your consent afterwards.

Data minimization

Transparency

Security and integrity

Responsible data sharing

International compliance

WirelessCar is a global company with establishments in several countries outside the European Union. As such, we work to ensure that any cross-border transfers of data between international jurisdictions complies with the relevant data protection requirements. For transferring personal data outside the European Union/European Economic Areas (EU/EEA), we follow the requirements set by the General Data Protection Regulation (GDPR) and the EU Commission.

Your Rights

You have several rights regarding your personal data:

Access: You can request a copy of the personal data we hold about you.
Rectification: You can have incorrect or incomplete data corrected.
Erasure: You can request the deletion of your data under certain conditions.
Restriction: You can request that the processing of your data be restricted.
Portability: You can receive the data you provided in a structured, commonly used format, or have us transfer it to another organization.
Objection: You can object to the processing of your data based on our legitimate interests, especially in direct marketing.
Withdraw Consent: You can withdraw your consent at any time, affecting the lawfulness of processing before the withdrawal.

If you believe your data is not being processed according to the law, you can file a complaint with the local data protection authority, the details of which can be found at www.imy.se.

For any questions, or to exercise your rights, please contact us at:

WirelessCar Sweden AB (556640–4785)
Vädursgatan 6, SE-412 50 Göteborg, Sweden

Information Notices

These information notices provide you with case specific information relating to how we process your personal data.

When you use our website

Online Contact Form
Data we Process	Purpose of Processing	Legal Basis for Processing
Name, email address, and message content.	To respond to your inquiries and provide the requested services.	Consent
Data Retention Period		Data Sharing and Transfers
Until the query is resolved unless a longer retention period is required by law.		Not shared with third parties unless necessary to provide the requested service.

Providing the website (essential cookies)
Data we Process	Purpose of Processing	Legal Basis for Processing
Cookies necessary for basic site functionalities like session management.	To ensure the proper functioning of our website and provide essential services.	Legitimate interests
Data Retention Period		Data Sharing and Transfers
Only as long as necessary for their function. For more information, see Cookie policy.		Shared only if required for technical reasons. For more information, see Cookie policy.

Website Analytics
Data we Process	Purpose of Processing	Legal Basis for Processing
Information about website usage, such as pages visited and interaction metrics.	To analyse and improve our website's functionality and user experience.	Consent
Data Retention Period		Data Sharing and Transfers
For more information, see Cookie policy.		Shared with analytics service providers. For more information, see Cookie policy.

Online Marketing
Data we Process	Purpose of Processing	Legal Basis for Processing
Browsing habits and preferences.	To deliver targeted advertisements that are relevant to your interests.	Consent
Data Retention Period		Data Sharing and Transfers
[13 months EEA UK / 24 months elsewhere or until consent is withdrawn.] For more information, see Cookie policy.		Shared with analytics service providers. For more information, see Cookie policy.

When you work at WirelessCar

Employee Personal Data Processing
Data we Process	Purpose of Processing	Legal Basis for Processing
Individual data (e.g., name, date of birth, SSN)	General administration, salary payments, tax reporting	Contractual obligation, legal obligation
Organizational data (e.g., employee number, job description)	Employment administration, internal reporting, project follow-up	Legitimate interest, contractual obligation
Contact data (e.g., email, address)	Communication, benefits administration, emergency contacts	Contractual obligation, legitimate interest
Compensation and benefits data (e.g., salary, tax deductions)	Payroll management, tax and benefit reporting	Legal obligation, contractual obligation
Employment Administration Data (e.g., employment contract, parental leave)	HR management, employee record maintenance	Contractual obligation, legitimate interest
Time data (e.g., working hours, vacation)	Tracking work time, leaves, and absences for payroll and reporting	Legal obligation, legitimate interest
Union Membership Data (if applicable)	Compliance with labor regulations	Legal obligation, explicit consent (if needed)
Security data (e.g., access cards)	Securing access to WirelessCar's premises and equipment	Legitimate interest, legal obligation
Health and Safety Data (e.g., sick leave, work incidents)	Employee health, workplace safety, compliance	Legal obligation
Performance and evaluation data (e.g., evaluations)	Employee development, assessments, performance reviews	Legitimate interest, contractual obligation
Competence Data (e.g., learning records, training activities)	Employee training and development	Legitimate interest
Travel Administration Data (e.g., business trips, booking details)	Business travel management, expense processing	Legitimate interest, contractual obligation
Help Desk and Support Data (e.g., support queries, IT equipment usage)	Providing necessary employee and IT support	Legitimate interest
IT-related Data (e.g., user-ID, login details)	IT security, system access management	Legitimate interest, contractual obligation
Data Retention Period		Data Sharing and Transfers
During employment, after that, only as long as needed for legal or contractual reasons		Shared within WirelessCar Group and with third-party suppliers, including outside the EU/EEA, with appropriate safeguards (e.g., Standard Contractual Clauses).

When you apply for a job at WirelessCar

Applicant Personal Data Processing
Data we Process	Purpose of Processing	Legal Basis for Processing
Individual data (e.g., name, photo)	General administration, salary payments, tax reporting	Contractual obligation, legal obligation
Contact data (e.g., address, email, phone number)	Employment administration, internal reporting, project follow-up	Legitimate interest, contractual obligation
Competence data (e.g., grades, recommendations, learning records)	Communication, benefits administration, emergency contacts	Contractual obligation, legitimate interest
Experience data (e.g., previous workplaces, CV information)	Payroll management, tax and benefit reporting	Legal obligation, contractual obligation
Data Retention Period	Data Sharing and Transfers
During the application process, after that, only as long as needed for legal or contractual reasons	Shared with recruitment service providers like Teamtailor, and within WirelessCar Group, including outside EU/EEA, based on appropriate safeguards (e.g., Standard Contractual Clauses)

When you work in WirelessCar IT systems

Consultant and Temporary Worker Personal Data Processing
Data we Process	Purpose of Processing	Legal Basis for Processing
Individual data (e.g., name, photo)	Registration in WirelessCar’s systems, general administration of assignment	Contractual obligation
Organizational data (e.g., consultancy number, services description)	Administration of your assignment, tracking consultancy and services provided	Legitimate interest, contractual obligation
Contact data (e.g., work email, phone number)	Communication regarding your assignment, services, and IT support	Contractual obligation, legitimate interest
Consultancy administration data (e.g., contract details, start/end dates)	Managing contract, invoicing, and administration of your assignment	Contractual obligation
Time data (e.g., working hours, worked time)	Tracking work time for billing and compliance purposes	Legal obligation, contractual obligation
Security data (e.g., access cards)	Securing access to WirelessCar’s premises and systems	Legitimate interest, legal obligation
Health and safety data (e.g., work incidents)	Ensuring a safe work environment and compliance with work safety regulations	Legal obligation
Competence data (e.g., training records)	Facilitating and tracking training activities and skills development	Legitimate interest
Performance and evaluation data (e.g., evaluations)	Employee development, assessments, performance reviews	Legitimate interest, contractual obligation
Travel Administration Data (e.g., business trips, booking details)	Business travel management, expense processing	Legitimate interest, contractual obligation
IT-Related Data (e.g., user-ID, login details)	IT security, system access management	Legitimate interest, contractual obligation
Data Retention Period		Data Sharing and Transfers
During the consultancy agreement, afterward, only as long as needed for legal or contractual reasons		Shared with other WirelessCar Group companies or third-party suppliers, including outside the EU/EEA, based on safeguards (e.g., Standard Contractual Clauses)

When you are doing business with WirelessCar

Customer Representatives Personal Data Processing
Data we Process	Purpose of Processing	Legal Basis for Processing
Contact data (e.g., name, email, phone number)	Communication regarding the contract between WirelessCar and your employer, customer relations	Legitimate interest, contractual obligation
Organizational data (e.g., company name, job position, place of work)	Managing relationships with customers, administering contracts, reporting purposes	Legitimate interest
Network-related data (e.g., user-ID, login details)	Ensuring IT security, maintaining logs of system access and usage	Legitimate interest
Communication data (e.g., emails, interactions with WirelessCar)	Handling inquiries, managing customer service, and supporting operational needs	Legitimate interest
Data Retention Period		Data Sharing and Transfers
As long as required for legal and contractual obligations and operational purposes		Shared with WirelessCar Group companies or third-party service providers

Supplier Representatives Personal Data Processing
Data we Process	Purpose of Processing	Legal Basis for Processing
Contact data (e.g., name, email, phone number)	Managing supplier relationships, communication related to contracts and agreements	Legitimate interest, contractual obligation
Organizational data (e.g., company name, job position, place of work)	Managing supplier relationships and administrative purposes related to contracts	Legitimate interest
Financial data (if sole trader, e.g., bank account details)	Processing payments for services provided	Contractual obligation
Contractual data (e.g., purchase orders, agreements)	Managing and fulfilling contractual obligations	Contractual obligation
Network-related data (e.g., user-ID, login details)	Ensuring security and functionality of IT systems	Legitimate interest
Communication data (e.g., emails)	Handling inquiries and managing communication related to contract fulfilment	Legitimate interest
Data Retention Period		Data Sharing and Transfers
As long as necessary for legal or contractual obligations, and operational purposes		Shared with WirelessCar Group companies or third-party suppliers

When you use WirelessCar Console

WirelessCar Console
Data we Process	Purpose of Processing	Legal Basis for Processing
Contact Data (name, email address)	Creating and administering your user account	Legitimate interest
Authentication Data (password)	Securing access to your user account	Legitimate interest
Technical Data (IP address, operating system, browser type)	Maintaining and securing the Portal; improving the Portal; business analytical purposes	Legitimate interest
User Activity Data (audit logs of user activities)	Monitoring and securing the Portal; improving user experience; business analytical purposes	Legitimate interest
Data Retention Period		Data Sharing and Transfers
Retained if you have a user account. Accounts not accessed for one year will be deleted. Personal data may be retained longer to comply with legal obligations or in the event of disputes or claims.		Shared with WirelessCar affiliates and third-party suppliers, including those outside the EU/EEA. Transfers are governed by EU-approved Standard Contractual Clauses or other recognized legal mechanisms.