Privacy Policy

Last updated: 2025-12-03

This Privacy Policy explains how Wapro AB ("Wapro", "we", "our", "us") processes your personal data when you use portal.wapro.io (the "Portal").

We respect your privacy and process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable Swedish data protection law.

1. Who is responsible for your data?

Data controller

Wapro AB

Munkahusvägen 103

374 31 Karlshamn

Org. nr: 556352-1466

Email: albin.engqvist@wapro.se

Phone: +46 70 270 00 34

Wapro AB is the data controller for the personal data processed in connection with the Portal, unless another controller is explicitly stated (for example, your employer or another group using the Portal).

If we appoint a Data Protection Officer (DPO), their contact details will be published here.

2. What does this policy cover?

This policy applies when you:

create and use a user account on portal.wapro.io
register products via QR/NFC codes or manually
create events such as installations, inspections and maintenance
upload images or documents related to products and sites
otherwise interact with the Portal or our support in relation to the Portal.

For our general handling of personal data outside the Portal (e.g. marketing, other websites, ERP/CRM), please refer to our general privacy notices where applicable.

3. What personal data do we collect?

We collect and process the following categories of personal data:

3.1 Account and profile data

Name
Email address
Password (stored as a cryptographic hash)
Group and role (e.g. installer, contractor, distributor, owner, consultant)
Contact details such as phone number (if provided)
Language and region settings

3.2 Portal usage data

Log-in and log-out times
Actions performed in the Portal (e.g. product registration, event creation, document downloads)
IP address, browser type, device information
Log entries in case of errors and security events

When you register products and events, you may submit:

Product identifiers (e.g. serial number, article number, product type)
Installation, inspection and maintenance data (dates, status, notes)
Site information (e.g. project/site name, manhole ID, client reference)
Location data, such as address, municipality, and in some cases GPS coordinates
Images and documents (e.g. installation photos, test reports, inspection documents)
Other free-text information you choose to enter in notes or descriptions

These data may indirectly relate to you as an individual (e.g. if your name appears in notes or filenames), which means they can be personal data under GDPR.

3.4 Communication data

Messages and requests you send to us regarding the Portal (e.g. support tickets, email, phone notes)
Your feedback on functionality, bugs and improvements

3.5 Data from your group or partners

We may receive personal data about you from:

Your employer or the group that invites you to use the Portal
Wapro group companies and authorised distributors
Our ERP/CRM systems (e.g. linking orders, projects or customers to Portal data)

In these cases, the group providing the data may be an independent or joint controller for parts of the processing.

4. For what purposes do we process your data, and on what legal bases?

We always must have a legal basis under GDPR for each processing purpose.

4.1 To provide and administer your Portal account

Legal basis: Performance of contract (GDPR Art. 6(1)(b))

Creating and managing your user account
Authenticating you and keeping your session active
Assigning you to an group and managing your roles and permissions

If you do not provide the necessary information, you may not be able to use the Portal.

4.2 To operate the Portal and deliver core services

Legal basis: Performance of contract (Art. 6(1)(b)) and legitimate interest (Art. 6(1)(f))

Enabling registration of products, installations, inspections and maintenance
Providing product history, documentation and event logs to you and your group
Supporting warranty, claims, service and technical support cases
Ensuring that the right parties (e.g. installers, owners, distributors) can access relevant product and installation data

Our legitimate interest is to run an efficient and secure portal service that supports Wapro's products, customers and partners.

4.3 To improve our products and services

Legal basis: Legitimate interest (Art. 6(1)(f))

Analysing how the Portal is used (e.g. number of installations, typical configurations, service intervals)
Analysing technical performance and failure modes of products over time
Developing new features and services and improving user experience

Where possible, we use aggregated or anonymised information for analytics and statistics so that individuals cannot be identified.

4.4 Security, logging and fraud prevention

Legal basis: Legitimate interest (Art. 6(1)(f)) and legal obligation (Art. 6(1)(c), where applicable)

Maintaining technical logs and audit trails
Detecting and preventing misuse, unauthorised access and security incidents
Ensuring the stability and integrity of our IT systems

4.5 Communication and support

Legal basis: Legitimate interest (Art. 6(1)(f))

Handling support requests and user feedback
Informing you about important changes to the Portal, such as security notices or updates to this Privacy Policy or the Terms of Service

4.6 Marketing and optional communications

Legal basis: Consent (Art. 6(1)(a)) or legitimate interest (Art. 6(1)(f)), depending on context and applicable law

Sending newsletters or invitations to webinars and events about the Portal or related services
Providing tailored information about new functions that may be relevant for your role

Where required, we will ask for your consent separately, and you can withdraw it at any time by following the unsubscribe link or contacting us.

4.7 Compliance with legal obligations and protection of rights

Legal basis: Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f))

Fulfilling legal requirements (e.g. accounting rules, record-keeping)
Handling potential disputes or legal claims
Protecting our, your or third parties' rights and interests

5. Do we use your data for employee monitoring?

The Portal is designed to support product and service quality, not to monitor individual workers. We do not use Portal data to systematically evaluate your personal performance as an employee. However, your employer or commissioning group may use information from the Portal as part of their own project documentation or quality processes. In such cases, they are responsible for informing you about their processing.

6. Who can access your data?

We only share personal data with parties that need it for the purposes described above.

6.1 Within Wapro Group

Your personal data may be accessed by relevant departments within Wapro AB and other Wapro group companies involved in:

product development and quality,
technical support and claims handling,
sales and project support,
IT and security.

Depending on how your account is set up, your personal data and the product/installation data you register may be visible to:

other users in your group (e.g. colleagues, project managers)
related groups involved in the same project (e.g. distributors, main contractors, asset owners), if the Portal configuration allows this.

Access is controlled by roles and permissions defined in the Portal.

6.3 Service providers (processors)

We use trusted service providers that process personal data on our behalf, for example:

hosting and cloud infrastructure providers
email and communication providers
IT security and logging tools
analytics tools (where used and subject to cookie/consent settings)

These providers act as data processors under GDPR, are bound by data processing agreements and may not use your personal data for their own purposes.

6.4 Other disclosures

We may disclose personal data to:

authorities, if we are legally obliged to do so
professional advisors (e.g. lawyers, auditors) under confidentiality
a potential buyer or investor in connection with a business transaction, where permitted by law

We do not sell your personal data.

7. International data transfers

Some of our service providers or Wapro group companies may be located outside the EU/EEA. In such cases, we will ensure that appropriate safeguards are in place, such as:

an adequacy decision by the European Commission, or
Standard Contractual Clauses (SCCs) and, where necessary, additional security measures.

You can contact us for more information about the safeguards used for a specific transfer.

8. How long do we keep your data?

We keep personal data only as long as necessary for the purposes described in this policy, or as required by law.

In general:

Account data: kept for as long as you have an active account. If your account is closed, we will delete or anonymise your personal data within a reasonable time, unless we must keep some information longer to comply with legal obligations or handle disputes.
Product and installation data: may be kept for the expected lifetime of the installed products plus a reasonable period, as these data are often important for safety, maintenance, traceability and warranty. Where possible, we will separate or anonymise information that directly identifies you if it is no longer needed.
Logs and security data: kept for a limited time depending on the purpose (e.g. security logging, troubleshooting) and then deleted or anonymised.
Marketing data: kept until you withdraw your consent or object to further communication, plus a short period to document your choice.

We regularly review our retention periods and remove or anonymise personal data that is no longer needed.

10. Cookies and similar technologies

The Portal uses cookies and similar technologies to:

maintain security and your login session (strictly necessary cookies)
remember certain settings and preferences
[If applicable:] analyse usage of the Portal to help us improve functionality.

Where required by law, we will ask for your consent before using cookies that are not strictly necessary (for example, analytics cookies). You can change your cookie preferences at any time via your browser settings or our cookie banner/tools.

More details are provided in our separate Cookie Policy, if available.

11. Children

The Portal is intended for professional use in connection with installation, maintenance and management of Wapro products. It is not directed at children, and we do not knowingly process personal data of children under the age of 16 without appropriate consent and safeguards.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example when we add new features or when legal requirements change. When we make significant changes, we will inform you in the Portal or by email. The latest version is always available at portal.wapro.io/legal/privacy-policy.

13. How to contact us

If you have any questions, requests or concerns about how we process your personal data, please contact us:

Wapro AB