Policy

This policy has been developed to describe Strands Group AB’s (reg. no. 556625-0105) handling of personal data based on the requirements of the EU’s Data Protection Regulation.

Strands Group AB stores and processes personal data for staff, customers and suppliers with whom we have agreements. We also handle personal data for those who have actively shown an interest in Strands Group AB as an employer, collaboration partner or for skills exchange. We will also, for marketing purposes, register contact details of people who represent possible partners, customers and possible candidates for employment based on a balancing of interests as described below. Registration of candidates can be based on tips from private individuals, recruitment companies or on information that the person concerned has published himself.

What information do we collect?

When you come into contact with us or are a customer, we may collect information about:

Personal and contact information Name, date of birth, social security number, address, e-mail address, telephone number, etc.

Financial information – negative payment history etc.

Unit information ‐ex. IP address, language settings, browser settings, time zone, operating system, platform and screen resolution (via Google analytics).

Handling of personal data on the company’s websites

No personal data that visitors have not knowingly provided will be saved.

Cookie policy

To ensure that you receive the most relevant information and the best service when you use our and our partners’ online services, information is collected through so-called cookies on your equipment.

A cookie is a text file that is saved to your device so that the website can recognize your device

This cookie does not contain any personal information. There are two types of cookies, permanent and temporary (so-called session cookies). Permanent cookies are stored as a file on your device for a longer period, while session cookies are temporarily placed on your device and are only used during the time you browse the page and disappear thereafter.

If you want to know when your device receives a cookie, you can set your browser to notify you. In this way, you have the option to accept or reject a cookie. Your device can also be set to reject all cookies. If you choose not to accept cookies, please note that certain features of our online services will no longer function as intended.

Legal support for the processing of personal data

All processing and storage of personal data at Strands Group AB must take place in a legal, correct and transparent manner in relation to the data subject.

The conditions that describe what is a legal treatment and that Strands Group AB refers to are consent, to fulfil an agreement, fulfil a legal obligation or based on a balancing of interests. These terms are described below.

Consent

If there is no other legal support for the processing of personal data, consent must be requested from those concerned. Strands Group AB must then be able to show that the data subject has given consent. The data subject can withdraw their consent at any time and have the relevant data deleted.

Complete agreement

“The processing is necessary to fulfil an agreement to which the data subject is a party or to take measures at the request of the data subject before entering into such an agreement.” – Data Protection Regulation Article 6 point 1b.

The above normally applies to persons mentioned in business agreements that Strands Group AB signs. Also applies to most information linked to employment and terms of employment regulated in employment contracts.

Fulfil legal obligation.

“The processing is necessary to fulfil a legal obligation incumbent on the person in charge of personal data.” – Data Protection Regulation Article 6 point 1c.

This mainly applies to data and processing required to fulfil laws and authority requirements, e.g. requirements in the Accounting Act and requirements from the Tax Authority.

Balance of interests.

“The processing is necessary for purposes relating to the legitimate interests of the person in charge of personal data or a third party, unless the interests or fundamental rights and freedoms of the data subject outweigh” – Data Protection Regulation Article 6 point. 1 f.

Strands Group AB makes the assessment that there is a mutual interest in finding candidates for recruitment and representatives for possible customers or partner companies. Strands Group AB can therefore choose to collect contact information such as (name, role, e-mail address, telephone number) and other information that the person has given us orally or in writing.

Your rights according to the data protection regulation

(Articles 15–18)

You have the right to receive confirmation as to whether personal data concerning you is processed or stored at Strands Group AB. If there is information, you can request access to it and information about the purpose for which it is processed.

Furthermore, you have the right to request that the data be deleted if there is no legal requirement that it be saved. In addition, you can request that incorrect information be corrected.

How do you contact Strands Group AB with questions about the privacy policy?

To find out if we have information about you and if you want to receive copies of this or request, if supported by law, to have your information deleted, please contact [email protected]

Background

The company’s Quality Policy has been developed on behalf of the management team and serves as a document providing guidelines regarding quality and factors affecting quality. All employees are expected to follow this policy.

Purpose

The goal of the company’s quality work is satisfied customers. The company’s name should be associated with high quality in terms of personnel, products, and customer service.

Guidelines

Management shall set clear quality objectives that are communicated, monitored, and regularly revised. As a tool in quality work, the company uses the international quality standard ISO 9001.

Customer Satisfaction

Our primary success factor is satisfied customers. Therefore:

• we base our work on what is best for the customer in the long term
• we are always cooperative in our dealings with customers
• we demonstrate our expertise and convey a competent impression
• we provide safe, time-saving, user-friendly, and cost-effective products

Employee Satisfaction

A good and productive work environment is a success factor. Therefore:

• all employees work as a team, understanding the importance of individual contributions
• critical information is made available to ensure quality and successful work
• we recognize and reward success
• we ensure the right person is in the right place through well-planned recruitment and training
• we follow our guidelines

Owner Satisfaction

Satisfied owners and value growth ensure the company’s survival and development. Therefore:

• all employees are responsible for the company’s long-term survival
• goals are clear and communicated
• we always strive to achieve set objectives

Society

The company operates within a broader context. Therefore:

• we comply with laws, regulations, and internal ethical rules and policies
• we consider the lifecycle perspective in decision-making
• we minimize negative impact on air, water, and land
• we minimize consumption of water and energy

Continuous Improvement

Our environment and business concept require continuous improvement. Therefore, we strive to:

• base decisions on facts and measurements
• continuously improve our quality management system
• do the right things at the right time and in the right way
• work proactively to prevent problems and risks
• engage employees and stakeholders in daily improvement work to increase customer satisfaction

———————————————–

Johan Carlos – CEO

Background

Environment refers to the surroundings in which the organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interactions (according to ISO 14001).

The company shall be characterized by preventive and continuous environmental work and viewed as an ongoing improvement process. The company shall be a leader in environmental work, conducted systematically and in a structured manner.

Purpose

This policy is directed at employees and stakeholders and aims to describe the company’s environmental work, including responsibilities, goals, and structure.

Guidelines

Principles and Requirements

• The substitution principle: less efficient or harmful technology is continuously replaced with better, more environmentally adapted alternatives
• The precautionary principle guides decisions involving significant risks
• The circular (lifecycle) principle shall be followed, based on the waste hierarchy and EU waste directive

Applicable laws, regulations, and requirements must be followed. Pollution caused by operations should be continuously reduced and prevented.

Environmental Objectives

Objectives shall be set and reviewed annually. Measurements and reporting are conducted regularly and form the basis for improvement work.

Ongoing Environmental Work

• Environmental work shall be well documented and traceable for evaluation
• Clear rules, guidelines, and procedures shall enable employees to make environmentally friendly decisions
• Environmental considerations shall be part of daily work and decision-making to promote sustainable development

The company shall:

• act as a role model for customers and suppliers
• encourage suppliers to actively work with environmental issues
• collaborate closely with stakeholders on environmental matters
• conduct internal environmental work leading to continuous improvements
• consider environmental risks and opportunities in business decisions

Resource Use

• Products should be environmentally adapted and resource-efficient
• Raw materials, production, transport, and waste shall be handled as environmentally friendly as possible
• Waste shall be managed according to the waste hierarchy
• Hazardous chemicals shall be replaced with less harmful alternatives whenever possible

Climate Impact

• Workplaces and premises shall be environmentally friendly and energy-efficient
• Travel and transport shall use environmentally friendly alternatives whenever possible
• The company shall invest in modern, energy-efficient technology
• Digital meetings shall replace physical meetings when possible, without compromising quality

Implementation and Follow-up

Environmental work is an ongoing process:

• Environmental assessments lead to reports and action plans
• Key questions include:
  • What are our environmental views and goals?
  • How do we proceed?
  • What is our environmental impact?
  • What actions reduce impact?

Follow-ups are conducted annually, with deeper reviews every three years.

Responsibility

Management is responsible for ensuring employees understand and can follow the policy. They should also encourage responsibility and preventive environmental work.

Employees are encouraged to contribute ideas, but ultimate responsibility lies with management.

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Johan Carlos – CEO

Strands PXP & Strands Lighting Division mobile application (iOS and Android)

Last updated: 22/09/2026

Strands PXP & Strands Lighting Division App is used to configure and control Strands PXP Force Box and PXP Force Button lighting hardware installed in vehicles, over a Bluetooth connection. This policy explains what personal data the app collects, why, who we share it with, how long we keep it, and what rights you have. It applies to both the iOS and the Android version.

1. Who is responsible for your data

Strands Group AB (company registration number 556625-0105), Hagalundsvägen 1, 51172 Fritsla, Sweden, is the data controller. For any privacy question or to exercise your rights, contact [email protected].

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and Swedish data protection law.

2. What we collect and why

Email address and password

Why: to create your account and sign you in. The password is stored only as a salted one-way hash and cannot be read or recovered by anyone.

Legal basis: Article 6(1)(b) — necessary to perform our contract with you.

User ID assigned to your account

Why: to identify your account and link your data to it.

Legal basis: Article 6(1)(b) — necessary to perform our contract with you.

Vehicle name you choose, Bluetooth mesh network identifier, and the unique identifiers of the Strands hardware units paired to the vehicle

Why: to save your installation and address the correct hardware each time you connect.

Legal basis: Article 6(1)(b) — necessary to perform our contract with you.

Function configuration: names, types, icons, input and output mapping, fuse amperage and voltage thresholds

Why: to save your lighting setup so it is there when you sign in again.

Legal basis: Article 6(1)(b) — necessary to perform our contract with you.

Vehicle membership and access codes

Why: to let you share an installation with, or hand it over to, another user you authorise.

Legal basis: Article 6(1)(b) — necessary to perform our contract with you.

Location permission, on Android 11 and earlier only

Why: Android requires this permission before an app may scan for Bluetooth. Your position is never read, stored or transmitted.

Legal basis: Article 6(1)(f) — our legitimate interest in the app working on older Android versions.

If you enter a vehicle registration number as your vehicle name, that number is personal data. You are not required to use one and may choose any name.

While scanning, the app processes Bluetooth identifiers of nearby devices in your phone's memory. This is not transmitted to us, apart from the identifiers of the Strands units you deliberately pair. When a firmware update is available, the app downloads the file from our servers and transfers it to your hardware.

An account is required to use the app. The app does not collect your location, analytics, usage statistics, crash reports, contacts, photos, camera, microphone or files. It contains no advertising and no tracking software. We carry out no automated decision-making or profiling, and we process no special category data.

3. Who we share it with

We do not sell your personal data and do not share it for advertising.

We use one processor: Supabase, Inc., which provides authentication, database hosting and file storage. It processes your account data, vehicle and installation data, memberships and access codes under a written data processing agreement in accordance with Article 28 GDPR, and only on our instructions.

Our database is hosted in the European Union (Ireland), so your data is not transferred outside the EU/EEA. We may disclose data where required by law or a competent authority.

4. Security

Data is encrypted in transit using TLS and encrypted at rest. Passwords are stored as salted one-way hashes. Access to the production database is restricted and protected by row-level access rules, so each account can only reach the vehicles it is a member of.

5. How long we keep it

We keep your account and installation data until you request to delete your account and erase it within 30 days of your request. Bluetooth scanning data is not retained; it exists only in your device's memory during a session.

If a vehicle is shared with other users, deleting your account removes your membership and your link to it. The vehicle configuration remains available to the remaining members, because it is their installation data too. Where you are the only member, the vehicle is erased with your account.

6. Your rights

Under the GDPR you have the right to access your data, to have it corrected or erased, to restrict or object to our processing, and to receive your data in a machine-readable format (Articles 15 to 21).

To exercise any of these, contact [email protected]. We will respond within one month.

You may also complain to a supervisory authority — in Sweden, Integritetsskyddsmyndigheten (IMY), Box 8114, 104 20 Stockholm, imy.se — or to the authority in the EU or EEA country where you live or work.

If you are outside the EU or EEA we extend the same rights to you so far as your local law permits.

7. Deleting your account

You can request deletion of your account and all associated data at any time by emailing [email protected], or through our support page at strandseurope.com/contact.

Please send the request from the email address associated with your account so that we can verify your identity. We will confirm receipt and complete the deletion within 30 days.

Deletion removes your account, your email address, your membership of any vehicle, and any vehicle and configuration data of which you were the only member. Deletion is permanent and cannot be reversed.

8. Permissions the app requests

• Bluetooth / nearby devices — to discover your Strands hardware and send lighting commands to it
• Location, on Android 11 and earlier only — required by Android before an app may scan for Bluetooth. Not requested on Android 12 and later and not requested on iOS. Your position is never read or stored
• Internet — to sign you in, synchronize your configuration and download firmware

You can withdraw any permission in your device settings. Without Bluetooth access the app cannot connect to your hardware.

9. Children

The app is intended for adult and professional use and is not directed at children. We do not knowingly collect personal data from anyone under 13 and will erase any such data if we become aware of it.

10. Changes

If we change how we handle personal data we will update this policy and the date at the top. Where a change materially affects your rights we will notify you in the app or by email.

11. Contact

Strands Group AB
Hagalundsvägen 1
51172 Fritsla, Sweden
Company registration number: 556625-0105
Email: [email protected]