EEURtrackerEU + YOUR + TRACKER
PRIVACY NOTICE · VERSION 1.0

How Glimit AB processes personal data for EURtracker.

Effective 20 October 2026. EURtracker is provided by Glimit AB, Swedish company registration no. 559606-7099. This notice explains Glimit AB's processing when it acts as controller for service-administration data and clarifies when Glimit AB instead acts as processor for customer project data.

1 · WHO IS RESPONSIBLE?

Two GDPR roles can apply in EURtracker.

Glimit AB as controller: Glimit AB determines the purposes and means for limited personal data needed to operate its own customer relationship, account administration, security, support, billing administration, legal compliance and website operation.

Glimit AB as processor: when a customer places project personal data in a EURtracker workspace and determines why that information is processed, the customer generally acts as controller and Glimit AB processes that data on the customer's documented instructions. That processing is governed by the applicable Data Processing Agreement.

2 · DATA WE PROCESS AS CONTROLLER

Account, customer and service-administration data.

  • Name, business contact details, organisation and role.
  • Account identifiers, authentication and security metadata.
  • Subscription, order, invoice and payment-administration information where applicable.
  • Support requests, feedback and correspondence.
  • Technical request, device, browser, security and diagnostic information generated when the service is used.
  • Website preference information stored locally in the browser where applicable.
3 · PURPOSES & LEGAL BASES

We process only for defined service purposes.

  • Provide and administer the service: performance of a contract where applicable, or Glimit AB's legitimate interest in delivering the customer's organisational agreement.
  • Account and access management: contract and legitimate interests in secure service administration.
  • Security, abuse prevention and troubleshooting: legitimate interests in protecting EURtracker, customers and users.
  • Support and customer communication: contract and legitimate interests in responding to requests and maintaining the customer relationship.
  • Accounting, taxation and legal obligations: compliance with legal obligations.
  • Optional analytics or marketing, if introduced: consent where consent is legally required.
4 · CUSTOMER PROJECT DATA

Project content is controlled by the customer.

Quick Updates, Progress material, project structures, reporting drafts, partner information and related project content may contain personal data. Where Glimit AB processes that data on behalf of a customer, Glimit AB does not independently decide to use it for unrelated purposes.

Customers are responsible for deciding what project personal data is necessary, providing required information to data subjects and establishing the appropriate lawful basis.

5 · AI-ASSISTED PROCESSING

AI processing happens when an authorised user requests it.

Current AI-assisted Progress synthesis and reporting drafts use the OpenAI API when a user invokes those functions. EURtracker sends the selected project context and reporting/source material needed for the request and uses store:false in the API request.

AI-generated wording remains subject to human review before formal submission. EURtracker is not designed to make significant automated decisions about individuals.

6 · SERVICE PROVIDERS

Core providers process data only for defined service functions.

EURtracker currently relies on providers including Supabase for database/authentication services, Vercel for application hosting and delivery, and the OpenAI API for user-requested AI-assisted functions. The current technical roles and public-sector baseline are described in the Security & Compliance page.

Additional suppliers may be used for ordinary business administration where needed. Contract-specific subprocessor information is governed by the applicable DPA.

7 · INTERNATIONAL TRANSFERS

Location and safeguards depend on the real provider configuration.

Some providers may process or make support data available outside the EEA depending on the service configuration. Where GDPR requires a transfer mechanism, Glimit AB uses an applicable safeguard such as an adequacy decision, Standard Contractual Clauses or another lawful mechanism.

Public-sector customers may request contract-specific information about selected regions, subprocessors and transfer safeguards as part of procurement or DPIA work.

8 · RETENTION

Data is kept only while there is a justified purpose.

  • Account and customer-relationship data is generally kept while the relationship is active and thereafter only as needed for legal, accounting, security or claim-handling purposes.
  • Customer project data follows the customer's contract, instructions and DPA, including return/deletion at the end of service.
  • Security and diagnostic records are retained according to the operational purpose and the relevant provider configuration.
  • Support and feedback records are retained while needed to resolve the matter and for a reasonable follow-up period.

Where an exact period is determined by law, contract or provider configuration, that specific rule controls.

9 · YOUR RIGHTS

Individuals can exercise GDPR rights where applicable.

Depending on the processing and legal basis, you may have rights to access, rectification, erasure, restriction, data portability and objection, and to withdraw consent where processing is based on consent.

For project data controlled by a EURtracker customer, requests should normally be directed to that customer. Glimit AB will assist the customer as processor where required.

10 · COMPLAINTS

You may contact the Swedish supervisory authority.

If you believe personal data has been processed contrary to applicable data-protection law, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) or another competent supervisory authority.

11 · COOKIES & LOCAL STORAGE

Optional tracking is not part of the current public-site design.

EURtracker's public website is designed without advertising or marketing cookies. The authenticated application may use strictly necessary session/security technologies and browser-local preferences. More detail is available in the Cookie Policy.

12 · CONTACT & UPDATES

Privacy questions can be sent directly to Glimit AB.

Privacy, data-subject, security or other data-protection questions can be sent to info@eurtracker.com. Customer-specific contractual contact details may also be stated in the applicable order, agreement or DPA.

Glimit AB may update this notice when the service, providers, legal requirements or processing purposes change. Material changes will be reflected by a new effective date and, where appropriate, communicated to affected customers.

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