Privacy Policy for Business Customers

1. About this policy

This privacy policy is addressed to you as a contact person, decision-maker, or administrator at a company or organisation that uses — or is evaluating — GymLensIQ. It describes what personal data we process about you in your professional role, why we do so, and what rights you have.

This policy does not apply to individual employees' training data. Such data is processed by your company as the data controller, with GymLensIQ acting as data processor. This is governed by the data processing agreement signed at contract stage.

2. Data controller

Lumos Ignite AB Org. no.: 559547-4197 Email: hello@lumosignite.com Website: gymlensiq.se

3. What personal data we process

We process personal data about contact persons at existing and prospective business customers. This may include:

• Name and job title
• Company name and registration number
• Work email address and phone number
• Communication via email or contact forms
• Information about ongoing or completed agreements

We do not process data about individual employees' training or health — this data stays in the app and is outside our access.

4. Purposes and legal basis

We process your data in order to:

• Handle enquiries and customer contacts (legal basis: legitimate interest)
• Enter into and fulfil agreements (legal basis: contract)
• Administer invoicing and payments (legal basis: contract and legal obligation)
• Send relevant information about the service (legal basis: legitimate interest)
• Fulfil accounting requirements and other statutory obligations (legal basis: legal obligation)

5. How long we retain your data

We retain your data for as long as necessary for each purpose:

• Customer contacts and contract documents: 7 years after the agreement ends (required by the Swedish Accounting Act)
• Enquiries that did not result in an agreement: 12 months
• Marketing communications: until you unsubscribe

6. Who we share your data with

We do not share your personal data with third parties for marketing purposes. We may share data with:

• Sub-contractors and system providers that help us operate the service (e.g. cloud services, CRM and billing systems) — these act as data processors under agreement
• Accounting firms or auditors when required by law
• Public authorities if we are legally required to disclose data

7. International transfers

Some of our system providers may process data outside the EU/EEA. In such cases we ensure that appropriate safeguards are in place, for example the EU standard contractual clauses.

8. Your rights

Under the General Data Protection Regulation (GDPR) you have the right to:

• Request a copy of your data (right of access)
• Request correction of inaccurate data
• Request erasure of your data (right to be forgotten), where there is no legal basis to retain it
• Request restriction of processing
• Object to processing based on legitimate interest
• Request data portability for data you have provided and that is processed on the basis of a contract or consent

Contact us at hello@lumosignite.com to exercise your rights. We will respond within 30 days.

9. Right to lodge a complaint

You have the right to lodge a complaint with the Swedish Authority for Privacy Protection (IMY) if you believe we are processing your data in violation of applicable law.

IMY: www.imy.se

10. Cookies

We use strictly necessary cookies to make the website function. We do not use tracking or advertising cookies. If we introduce cookies that require consent in the future, we will inform you accordingly.

11. Security

We implement technical and organisational measures to protect your personal data against unauthorised access, loss, and alteration. These include encrypted communications and restricted access controls.

12. Automated decision-making

We do not make automated decisions that have legal or similarly significant effects on you.

13. Changes to this policy

We may update this policy from time to time. Material changes will be notified by email to registered contact persons or through a prominent notice on the website.

14. Contact us

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

Email: hello@lumosignite.com Lumos Ignite AB, org. no. 559547-4197