Locka Privacy Policy

Your Privacy Matters

Your privacy is of the utmost value to us and it really matters here at Locka. Due to the nature of the services that we offer, the need to collect and process your data, including personal data, is limited to a minimum.

Locka Group AB and its affiliates (hereinafter referred to as “Locka” or “we”) are providing this Privacy Policy to describe and explain our practices regarding the collection, storage, and transfer of information, and choices that you can make about the way your data is collected and used by us.

To the extent Locka collects your personal data as a data controller, the data controller is Locka Group AB with its seat in Trollhättan SE-461 32, Drottninggatan 1, Sweden. For purposes described in this Privacy Policy, your data may be processed by all Locka legal entities.

All the data processed by Locka are duly secured and used only for the purposes indicated in this Privacy Policy. The scope of collected data is always adequate and proportionate to these purposes.

Scope of Data and Ways We Collect Them

Through your interaction with and use of our websites or web or mobile applications (our software services), Locka may collect personal information that should be understood as information that identifies an individual or relates to an identifiable individual. Personal information may include but is not limited to, your name, personal identification number, physical address, telephone number, e-mail address, and associated information. More typically, Locka may collect other information through your interaction with and use of our websites or web or mobile applications, which does not reveal your specific identity or does not directly relate to an individual. Such other information may include but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, geographic or geo-location information, statistical and aggregated information. Locka uses best measures to ensure that your data are secured and processed in compliance with applicable laws.

As a general rule, you can freely visit Locka websites and use their content. Access to our web or mobile applications (software solutions) is granted only to persons authorised by our customers who have a subscription agreement with Locka for our software services, partners who have a partnership agreement with Locka, or prospects who requested a demo from Locka. However, persons who are not of the age of majority should not be eligible to use Locka website(s), and we ask that no information in relation to such persons are submitted to us.

Unless agreed otherwise with the Locka's customer, prospect or partner (so far as it relates to your use of Locka web and mobile applications), personal information like your name, surname, and e-mail address is obtained only when voluntarily provided to us, in particular when completing contact/newsletter forms or other forms available on our websites or otherwise made available by Locka. We use cookies to assist you in navigating and using a given site or application and to improve your experience with Locka sites (please see more about the use of cookies below). Technical information, like details about your device and IP address, may be collected by virtue of your use of certain Locka web or mobile applications.

Locka may collect your information in several ways, including:

To provide you with timely, high-quality information, we may also ask you to provide us with information regarding your professional interests and experiences with our services. Providing us with this information is optional.

Personal data or other data collected online may also be combined with information you provide to us through other sources such as sales meetings, marketing calls, or in conjunction with events such as trade shows, training seminars, webinars, and conferences. Information that you supply may be associated with the relationship that Locka has with you or your organisation.

Purposes of Data Processing

Locka may use your personal information to:

Our Global Presence

To foster your data privacy rights and comply with EU General Data Protection Regulation (GDPR) and other applicable laws, we are required to provide you with information about how we process your personal data.

Please read more in General Privacy Information for Locka sites users

If you are a candidate applying for a job in a Locka EU-based legal entity, please read Privacy Notice for Candidates


Data Controller. The data controller of www.locka.com and Locka web and mobile applications is Locka Group AB with its seat in Trollhättan SE-461 32, Drottninggatan 1, Sweden. It means that Locka is responsible for the lawful processing of all your personal data collected by us.

Data Protection Officer. Locka's data protection officer can be contacted via moc.akcol@ycavirp.

What does Locka do with my Personal Data? Locka will process your personal data only as set out in this Privacy Policy. Further information regarding legal grounds for our processing of your personal data can be found below.

Processing of your personal data. Locka is permitted to process your personal data under the following legal grounds:

(i) Entering into and performing a contract. If you enter into a direct agreement with Locka (acting as an individual), Locka will use your Personal Data that you enter into the contract or an order or which you provide to us for contract or order drafting – i.e. usually (a subset of) your name, (email) address, telephone number, company name and address, your job title and role and, payment details (like your bank account) only to enter into and perform the contractual obligations. This may include taking the necessary steps prior to entering into the contract with you, responding to your related inquiries, providing you with billing information, feedback, and fulfilling our contractual obligations etc. This may also include conversation data contained in emails, provided via telephone, contact forms on on website or other communication channels. We may use your email address to send you notices of payments, to send you information about changes to our products and services, information related to your business relationship with Locka, or to send notices and other disclosures as required by law. If you participate in Locka tutorials, webinars or training sessions, Locka needs your contact details to enable you to take part in a given learning service.

Generally, you cannot opt-out of communications which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), Locka will provide you with the opportunity to opt-out if you do not want to receive further marketing-related types of communication from us. You can opt-out of these at any time by sending an email to moc.akcol@ycavirp.

(ii) Our legitimate interest. Each of the cases below constitutes a legitimate interest of Locka to process or use your personal data. If you do not agree with this approach, you may object to our processing of your personal data as set out below.

When you represent our customer, prospect or partner. If you represent our prospect, partner or customer, either prior to entering into an agreement with Locka or during a business relationship betweeen Locka and the legal entity which you represent, we may process your basic contact details (e.g. your name, surname, job position, company name, e-mail, and phone number) so far as necessary to carry out the joint business relationship.

Questionnaires and surveys. Locka may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any personal data. If you nonetheless enter personal data in a questionnaire or survey, we may use such personal data to improve its products and services.

Aggregated data sets. Locka may anonymise (some of) your personal data to create anonymised aggregated data sets, which will then be used to improve Locka products and services.

Recording. In case of telephone calls or chat sessions, Locka may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of our products and services.

Existing business relationship – keeping you up-to-date. Within an existing business relationship between you (or the company which you represent) and Locka, Locka may inform you, where permitted in accordance with applicable laws, about its products or services, webinars, seminars or events which are similar or related to such products and services you (or the Company which you represent) have already purchased/subscribed to or used from Locka or participated in. For instance, we may send you some marketing information related to an extension of your company’s existing services package or a new product offer. Furthermore, where you have attended a Locka webinar, seminar or event, or (the Company which you represent) subscribed to Locka products or services, we may contact you for feedback regarding the improvement of the relevant webinar, product or service.

You may object to Locka using your Personal Data for the above purposes at any time by contacting us via moc.akcol@ycavirp. If you do so, Locka will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless Locka is permitted to use such Personal Data for another purpose set out in this Privacy Policy or Locka determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.

(iii) Your consent In some cases Locka will ask for your consent before starting the processing of your Personal Data, in particular:

Marketing of Locka services

Even though Locka Services are addressed to legal entities (and not individuals), we ask for your consent to process your personal data for marketing purposes, to send you marketing-related materials about Locka offerings and to contact you directly. If you leave your contact details (like name, surname, e-mail, telephone) on our websites (and assuming you are not representing an existing customer or partner), please tick the consent or submit box.

With regard to marketing-related types of communication (i.e. emails and phone calls), Locka will provide you with the opportunity to opt-out if you do not want to receive further marketing-related types of communication from us.

User experience research and analysis

If you are an end-user of Locka's web or mobile applications, we ask for your consent before conducting an interview with you about your experience of using Locka's web or mobile applications.


In our job offers, we ask you for consent to process your personal data which you provide to us when applying for a job, for current and future recruitment purposes. Consent for processing of your personal data for future recruitment purposes is not required to carry out a current recruitment process.

Cookies and other technologies

As set out in this Privacy Policy, Locka uses cookies and other technologies, in particular, to ensure the proper function of its sites, improve user experience, enable your login to our web or mobile application and analyse web traffic. As required by existing laws and regulations, we ask for your consent for using cookies (in a cookie pop-up banner). Your cookie preferences may be easily set in your browser settings.

Revocation of consent. You may at any time withdraw the consent granted to Locka by sending an email to moc.akcol@ycavirp. In the case of marketing-related newsletters, you will also have the possibility to unsubscribe. In case of withdrawal, Locka will not process Personal Data subject to this consent any longer unless legally required to do so. In case Locka is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal will have no effect on the past processing of personal data by Locka up to the point in time of your withdrawal.

(iv) Processing is necessary for compliance with a legal obligation to which the controller is subject. To exercise your data subject’s privacy rights, you can contact us by sending an email to moc.akcol@ycavirp. To handle your request properly, we need to collect your basic contact details and we ask you to describe your request. If your request concerns Locka Services, please let us know which Services you use.

End Users of the web and mobile applications

If you are an end-user of Locka's web or mobile applications, your end-user information (i.e. name, surname, email, telephone number etc.) processed in our web or mobile applications may be regarded as personal data processed on the customer’s instructions (behalf). Based on this assumption, Locka is the data processor of your end users’ personal data while our customer (your employer/partner/real estate developer) is the data controller of this information. To set out the legal framework for the processing of end-users personal data by Locka, we encourage all our customers to enter into Locka's standard Data Processing Addendum (DPA) which is compatible with GDPR.

Duration of the processing. Where Locka is processing and using your personal data as permitted by law or under your consent, Locka will store your personal data (i) only for as long as is required to fulfil the purposes set out below or (ii) until you object to Locka's use of your personal data (where Locka has a legitimate interest in using your personal data), or (iii) until you withdraw your consent (where you consented to Locka using your personal data). However, where Locka is required by mandatory law to retain your personal data longer or where your personal data is required for Locka to assert or defend against legal claims, Locka will retain your personal data until the end of the relevant retention period or until the claims in question have been settled.

Why am I required to provide Personal Data? As a general principle, your granting of any consent and your provision of any personal data hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which Locka cannot take action without certain Personal Data, for example, because this Personal Data is required to provide you with a Locka offering or newsletter. In these cases, it will unfortunately not be possible for Locka to provide you with what you request without the relevant personal data.

Where will my Personal Data be processed? As part of a global group of companies, Locka has affiliates and third-party service providers within as well as outside of the European Economic Area (the “EEA”). As a consequence, whenever Locka is using or otherwise processing your Personal Data for the purposes set out in this Privacy Policy, Locka may transfer your Personal Data to countries outside of the EEA including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually provide that your personal data is subject to a level of data protection that applies within the EEA. Locka may transfer your Personal Data to other entities in the Locka Group as necessary for an applicable legitimate purpose. Transfers within Locka Group are further governed by Locka Intracompany Data Processing Agreement with Intracompany Confidentiality Undertaking. Your personal data may also be made available to reliable Locka partners who may conduct marketing activities for the Locka Group or may be processed by reliable third-party cloud tools for analytical, business or marketing purposes. We may store or require you to provide your basic personal information to reliable communication tools used for training, learning, user experience analysis, marketing, contact or other business purposes (for instance: Microsoft Teams).

Your rights. You can request from Locka at any time information about which personal data Locka processes about you and the correction or deletion of such personal data. Locka can delete your personal data only if there is no statutory obligation or prevailing right of Locka to retain it. If you are an end-user of Locka's web or mobile applications, your request to delete personal data from our applications shall be directed to Locka's customer who subscribed to Locka services (for instance, your employer, real estate developer, etc.), to Locka's prospect who requested a demo, or to a partner who has been given access to Locka's services; as Locka acts as a data processor in relation to your personal data processed in our services. We will cooperate with your data controller to exercise your rights.

If Locka uses your personal data based on your consent or to perform a contract with you, you may further request from Locka a copy of the personal data that you have provided to Locka. In this case, please contact us and specify the information or processing activities to which your request relates, and whether the personal data is to be sent to you or another recipient. Locka will carefully handle your request.

Furthermore, you can request from us that Locka restricts your personal data from any further processing, especially in the following events: (i) you state that the personal data Locka has about you is incorrect, (ii) there is no legal basis for Locka processing your personal data and you demand that we restrict your personal data from further processing, (iii) or in case you object to the processing of your personal data by us (if the processing is based on Locka's legitimate interest) unless Locka has a prevailing interest or legal obligation in processing your personal data.

Please send all your requests to moc.akcol@ycavirp.

Right to lodge a complaint. If you believe Locka is not processing your Personal Data lawfully, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which Locka has its registered seat.

Use of this website by children. This site is not intended for anyone under the age of 16 years. If you are younger than 16, you should not use this site.

Profiling. Your personal data is not subject to automated decision-making, including profiling.

Links to other websites. This website may contain links or references to third-party sites (i.e., not belonging to Locka Group companies). Locka is not responsible for the privacy practices or the content of websites outside the Locka Group. Therefore, we recommend that you carefully read the privacy statements of such third-party sites.


If you are applying for a job at Locka, please additionally read the following privacy information:

Locka follows all data protection principles and treats your personal data with the utmost care. As per data protection laws, please be informed that:

  1. The Data controller of your personal data is the Locka country-specific legal entity to which you apply. It means that Locka is responsible for the lawful processing of all your personal data collected by us.
  2. The Data Protection Officer of Locka Group is possible to contact via moc.akcol@ycavirp. You can submit your data subject's requests and exercise your rights by contacting us at the email address.
  3. The basis for the processing of your personal data is your consent. Your personal data will be processed for the legitimate purposes indicated in your consent. Furthermore, some of your data may be processed by Locka based on its legitimate interests as a data controller: for general statistical and business purposes (e.g. management and analysis of recruitment processes).
  4. Recipients. Your personal data may be made available to Locka affiliates as necessary for an applicable legitimate purpose. Your data will be also processed in the cloud application used in the recruitment process. If necessary for a given recruitment process, we may make available your basic personal data to reliable recruitment firms engaged in the recruitment process. Within the extent described herein, your data may be transferred outside of the EU.
  5. Nature. Providing your personal data is voluntarily but at the same time necessary for us to carry out the recruitment process. Failure to provide certain personal data will make it impossible for us to carry it out.
  6. Your rights. As per General Data Protection Regulation, you have the right to
    1. Access, rectify or erase your personal data, restrict their processing, object to their processing and the right of data portability,
    2. Withdraw your consent for data processing at any time,
    3. Lodge a complaint with a supervisory body.
  7. Profiling. Your personal data is not subject to automated decision-making, including profiling.
  8. Retention. Your personal data will be stored only for the time necessary to fulfil the applicable legitimate purpose. At a later stage personal data may be kept only for the time permitted by the law.

Use of cookies, other technologies and your preferences

Certain technologies, called “cookies”, can be used to provide tailored information from Locka's websites or web or mobile applications. A cookie is an element of data that a website or web or mobile application can send to your device or browser, which may then be stored on your system. Some pages on our websites, web and mobile applications use cookies that assist you in navigating and using a given site or application, for example, to help you access secure areas. Cookies used by Locka are associated with a browser or a device by which you enter the web, not with your name or surname. It is based on the concept of anonymised users to ensure that your privacy is always protected and unharmed.

Please be aware that cookies are important for the proper function of our websites and web and mobile applications. We assure you that they are in no way intended to intrude on your privacy. Instead, they are used to make your experience with Locka easier and better. For this purpose, Locka uses cookies to provide secure log-in (session cookies), collect statistics to optimise the functionality of sites and applications, and deliver content tailored to your interests and needs (Matomo & Google Analytics).

You should be aware that cookies may also be used on our websites or web or mobile applications to remember certain choices you make such as your geographical region, your user name (email), or other personalisation or customisation. We use these cookies to improve your user experience so that we can better serve you when you use our products or return to our websites or web or mobile applications.

What is more, Locka may use third-party cookies to provide advertising and marketing-related activities in accordance with this Policy. We may work with selected third-party partners who set cookies to provide you with Locka-related content, including advertisements, on their sites or elsewhere on the Internet. We use Matomo cookies for the purpose of monitoring web traffic. Sometimes, some cookies/online identifiers may be used to enable some of our applications functionalities to work properly.

By using our website or our web or mobile applications, you agree to the use of cookies in accordance with your current browser or device settings. If allowed by your browser or device, you can reject the use of cookies by changing the settings in your browser or device at any time. For more information, please refer to the user information provided with your browser or device. However, please note that if you disable cookies, some functionality of our websites or applications may be limited and it may impair the function of certain tools.

Matomo and Google Analytics

Our websites, web and mobile applications may use the Matomo & Google Analytics tools. The data used in these tools are not intended to identify you as an individual. They are used for general business, statistical, marketing and analytical purposes.

Web Server Logs

In the process of administering our web or mobile applications, we may track usage through web server logs. Web server logs provide information such as what types of browsers are accessing our site, what pages receive high traffic, and the times of day our servers experience significant load. We may use this information to improve the content and navigation features of our site. Anonymised or aggregated forms of this data may be used to identify future features and functions to be developed for the site and to provide better customer service. As we base on the concept of an anonymised user, your privacy is always protected and unharmed.

Web Beacons (Embedded Pixels/Pixel Tag)

We may use Web Beacons in conjunction with cookies to compile aggregate statistical information about the usage of a website or a given web or mobile application. When it comes to the purpose of Web Beacons, it is quite similar to the use of cookies. They generally help to provide web services tailored to your needs and do not harm your privacy. A Web Beacon is an electronic image, called a single-pixel/pixel tag (1×1) or clear GIF. Web Beacons can recognise certain types of information on a visitors computer such as a visitors cookie number, time and date of a page view, and a description of the page where the Web Beacon is placed. You may render some Web Beacons unusable by rejecting their associated cookies.

Embedded URLs

From time to time, we may also create a unique web URL link for certain visitors of our web pages. If you visit our websites, you may find certain forms that are already filled out with your (user)name or other types of information you have previously indicated an interest in, based on the information you have given us before.

We may also personalise the content of newsletters, e-mail offers, invitations, or Locka advertisements provided to you on our third-party partners websites, based on topics in which you have previously indicated an interest. We may collect information about how you consume this type of personalised information in order to help us provide you with other information that is better tailored to your interests. If you choose to visit one of these personalised web URL links, you agree to allow Locka to collect information about your visits and also to compile that information with other information about you and your relationship with Locka. If you do not wish your information to be used in this way, do not accept the invitation to visit these sites.

Other Technologies

Locka may also use other technologies to capture specific data such as your access times, your IP address, and system configurations and settings, to support your use of Locka-affiliated technologies, provide you with relevant content, and assist you with questions you may have regarding our products and services.

Locka may also use some third parties to administer a limited set of Locka advertisements on third-party channels or websites. We may use advertising technologies and participate in advertising technology networks that collect information not being personal data (from Locka websites or from other sources) to show you Locka-related advertisements on third-party websites.

Sensitive Data

We do not collect any of your sensitive data, i.e., information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, trade union membership, etc. We kindly ask you not to send any such information to us.

Compelled Disclosure

Locka may disclose your personal information if necessary or appropriate: (a) under applicable laws, including laws outside your country of residence; (b) to comply with a legal process; (c) to respond to requests or injunctions from public government or judicial authorities, including public government and judicial authorities outside your country of residence.

Your Right To Opt-in and Opt-Out

Locka offers you the choice of receiving different types of communication and information related to our company, products, and services. You may subscribe to e-newsletters (available on our website) and/or choose to receive marketing communications and other special offers from us via e-mail or by way of direct contact.

You should be aware that you can at any time request information about your personal data processed by Locka Group. You may access, review, update, modify, rectify, and erase such data as well as withdraw your consent for data processing by sending an email to moc.akcol@ycavirp. In the case of newsletters and other marketing communications, we provide you with unsubscribe links as an opt-out mechanism for your convenience.

Retention of Your Data

To the extent Locka processes your personal data, we will retain such data for as long as it is needed for the legitimate purposes outlined in this Privacy Policy; as necessary to comply with our legal obligations, resolve disputes, and perform agreements with our customers, prospects or partners; or to the extent permitted by applicable laws.

After the retention period, Locka will delete your personal data in a manner designed to ensure that it cannot be reconstructed, intercepted, or read.

Data Security

Locka is concerned about the security of your information. To prevent unauthorised access, disclosure, loss, alteration, misuse, and destruction of your data, to maintain data accuracy, and to ensure the appropriate use of information, we have put in place reasonable physical, electronic, administrative and managerial safeguards to secure the information we collect. We use security protocols and encryption technology when collecting or transferring data such as logins or passwords to prevent any data privacy breaches.

Third-Party Websites

Links to third-party websites on our websites are provided solely for your convenience. If you use these links, you will leave Locka's website. We do not control these third-party sites. Therefore, we do not assume responsibility for any of these sites, their content, or their privacy policies. We do not endorse or make any representations about them or any information, software, or other products or materials found there, or any results that may be obtained from using them.

Dispute Resolution

Locka is committed to resolving complaints about our collection or use of your personal information. EU citizens with inquiries or complaints about our privacy policy should first contact Locka by sending an email to moc.akcol@ycavirp.

If you do not receive timely confirmation of your complaint from us (within 45 days) or if we have not processed your complaint to your satisfaction, you may also make complaints about the improper collection or use of personal data directly to an EU data protection authority (“DPA”).

Locka's GDPR Commitment

The General Data Protection Regulation ('GDPR') is a European privacy law that has taken effect on May 25, 2018. Locka perceives this regulation as an important step forward in enhancing individuals data privacy and streamlining data protection laws across the EU. Locka is committed to compliance with GDPR across its cloud services. We continuously work to ensure that our current business operations, services, contracts and documentation comply with the GDPR.

California Residents

Locka does not sell your personal information. However, if you are a California resident, the California Consumer Privacy Act (“CCPA”) gives you certain rights with respect to the processing of personal data. We carry out all data processing activities respecting your rights and our applicable obligations under the CCPA. You will be not discriminated for exercising any of your rights under the CCPA. Please find out more in Locka California Residents.


In case we make any amendments to this Privacy Policy, we will promptly provide the updated version of the same to ensure you are always informed. The revised Privacy Policy will be effective when provided.

Your Assent

By using Locka's websites or web or mobile applications, you agree to this Privacy Policy.

Contact Us

Should you have any concerns, comments, or questions related to this Privacy Policy or to how Locka processes your (personal) data, you may contact us via moc.akcol@ycavirp. While the majority of issues related to your data can be handled quickly, complex requests may take more research and time.

Also, if you have any reservations or complaints regarding our compliance with this Privacy Policy, please first contact us and we will investigate and do our best to resolve all of them.

You may also contact us via postal mail at the following address:

Locka Group AB
ATTN: Data Protection Officer
Drottninggatan 1
SE-461 32 Trollhättan

Last version: 11 april, 2024