This privacy notice explains how Marksman Training Systems AB (org. nr 556175-5041), Finlandsgatan 18, 164 74 Kista, Sweden — referred to as “Marksman”, “we”, “us”, or “our” — processes your personal data when you use our website, purchase or use our products (including ST-Classic, ControlHub, and ST3 simulator systems), or interact with our services.
Marksman is the data controller for the processing described here. We process personal data in accordance with Regulation (EU) 2016/679 (GDPR), the Swedish Act (2018:218) with supplementary provisions to the GDPR, and other applicable EU and national privacy legislation.
If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY). We ask that you contact us first at info@marksman.se so we can try to resolve your concern.
Keep your information accurate. Email info@marksman.se if any personal data we hold about you changes.
Section 2
What we do with your personal data
With your consent where required, we send you emails about our products, services, events, and simulator demonstrations.
When you buy from us or register a system, we process the information you provide to deliver products and support, manage licenses, and maintain your customer relationship. This includes purchase history, support correspondence, and — where you have not opted out — how you interact with our website, emails, and offers.
Section 3
Categories of personal data
Personal data means any information relating to an identified or identifiable natural person. It does not include anonymised data that cannot be linked back to you. We may process the following categories:
- Identity data — name, professional title, organisation, date of birth where relevant.
- Contact data — billing and delivery address, email, telephone numbers.
- Financial data — bank account and payment card details (processed via payment providers).
- Transaction data — orders, invoices, license keys, support tickets.
- Technical data — IP address, browser type and version, device identifiers, time zone, operating system, and logs from devices connecting to ControlHub or our web services.
- Profile data — account credentials, simulator configuration preferences, interests, and feedback.
- Usage data — how you use our website, software, and training products.
- Marketing and communications data — your preferences for receiving marketing and records of consent or opt-out.
Section 3.1
Sensitive and special-category data
We do not seek to collect special categories of personal data under GDPR Article 9 (such as health, biometric, or political data) or information about criminal convictions. If you voluntarily include such information in free-text support messages, we will delete it unless we have another lawful basis to retain it.
Section 4
How we collect personal data
We collect data through:
- Direct interactions — forms on our website, orders, demo requests, competition entries, surveys, email, phone, or post.
- Automated technologies — cookies, server logs, and similar technologies when you browse our site or when licensed software checks for updates. See Section 8.
- Third parties — analytics and advertising partners (e.g. Google), payment processors, distributors acting as our sales agents, and publicly available business registers such as Bolagsverket where you are a business contact.
Section 5
Lawful bases and purposes
We process personal data only where a lawful basis under GDPR Article 6 applies. The table below summarises our main purposes:
Table for Lawful bases and purposes| Purpose | Data categories | Lawful basis |
|---|
| Provide, manage, and support our products and services | Identity, contact, financial, transaction, technical, profile, usage | Performance of a contract (Art. 6(1)(b)); legitimate interests in operating our business (Art. 6(1)(f)) |
|---|
| Comply with legal and regulatory obligations | Identity, contact, financial, transaction | Legal obligation (Art. 6(1)(c)) |
|---|
| Send relevant product news, events, and offers | Identity, contact, technical, profile, usage, marketing preferences | Consent (Art. 6(1)(a)) or legitimate interests where permitted (Art. 6(1)(f)); soft opt-in for existing customers where applicable |
|---|
| Improve our website, software, and customer experience | Technical, profile, usage, aggregated analytics | Legitimate interests in developing our products (Art. 6(1)(f)) |
|---|
Section 5.1
Marketing communications
You receive marketing from us if you requested information, purchased from us, or explicitly opted in — and you have not opted out.
Where consent is required, we obtain it before sending marketing email or SMS. You may withdraw consent at any time by emailing info@marksman.se or using the unsubscribe link in our messages.
Opting out of marketing does not affect processing necessary to fulfil a contract (for example license delivery or critical service notices). Some personalised website features may be limited if you refuse optional analytics cookies.
Section 6
Who we share data with
We do not sell or rent your personal data.
We share data with processors that help us deliver services, including IT hosting, email delivery, payment processing, accounting, legal advisers, and insurers. They may use your data only on our instructions under written data-processing agreements required by GDPR Article 28.
We share data with Marksman distributors and dealers who represent us outside Sweden when you contact them through our channels.
We may disclose data to Swedish or EU authorities when law requires it, or to acquirers if our business is merged or sold — subject to the same privacy commitments.
Section 7
International transfers
Some service providers are located outside the European Economic Area (EEA), including in the United States. When we transfer personal data outside the EEA, we ensure appropriate safeguards under GDPR Chapter V, such as:
- An adequacy decision by the European Commission (including the EU–US Data Privacy Framework where the recipient is certified);
- Standard Contractual Clauses (SCCs) approved by the European Commission, supplemented by transfer impact assessments where required;
- Binding corporate rules or other mechanisms recognised under GDPR.
Section 7.1
Note on US transfers
The EU–US Privacy Shield was invalidated in 2020. We no longer rely on it. Where US providers are used (for example certain analytics or cloud services), we rely on the EU–US Data Privacy Framework and/or SCCs as applicable. Contact info@marksman.se for details on safeguards for a specific transfer.
Section 8
Cookies and similar technologies
Our website uses cookies and similar technologies for essential operation, preferences, analytics, and — where you consent — marketing measurement. Non-essential cookies are placed only after you accept them through our cookie banner, in line with the ePrivacy Directive and Swedish electronic communications law.
You can change cookie preferences at any time through your browser settings or our cookie controls when available. Blocking essential cookies may prevent parts of the site from working.
We implement technical and organisational measures appropriate to the risk, including access controls, encryption in transit, and confidentiality duties for staff and processors.
Access to personal data is limited to people who need it for their role. We maintain procedures to detect, report, and investigate personal data breaches. Where required under GDPR Article 33, we notify IMY within 72 hours and affected individuals without undue delay when high risk is likely.
Our site may link to third-party websites. We are not responsible for their privacy practices. Read their policies before submitting data.
Section 10
How long we keep data
We retain personal data only as long as needed for the purposes collected, including legal, accounting, and reporting requirements.
Swedish accounting law requires us to keep basic customer and transaction records for seven years from the end of the financial year in which the transaction occurred.
Support and marketing data are deleted or anonymised when no longer needed. You may request erasure where GDPR Article 17 applies; we may retain certain records if law requires.
Under GDPR, you have the right to:
- Access your personal data (Article 15);
- Rectify inaccurate data (Article 16);
- Erase data in certain circumstances (Article 17);
- Restrict processing (Article 18);
- Data portability where processing is automated and based on contract or consent (Article 20);
- Object to processing based on legitimate interests or for direct marketing (Article 21);
- Withdraw consent at any time, without affecting prior lawful processing (Article 7(3));
- Lodge a complaint with IMY — integritetsskyddsmyndigheten.se.
Section 11.1
Exercising your rights
Email info@marksman.se to exercise any right. We do not charge a fee unless a request is manifestly unfounded or excessive. We may ask for information to confirm your identity before disclosing data.
We aim to respond within one month. Complex or multiple requests may take longer; we will tell you if so.
Further guidance on data subject rights is available from IMY: integritetsskyddsmyndigheten.se.
Section 12
Automated decision-making
We do not use automated decision-making or profiling that produces legal or similarly significant effects on you within the meaning of GDPR Article 22.
Our products and website are directed at businesses, training facilities, and adults. We do not knowingly collect personal data from children under 16 without parental consent. Contact us if you believe we have collected a child's data.
Section 14
Changes to this policy
We update this notice when our processing changes. The “Last updated” date at the top reflects the latest revision. Material changes will be highlighted on this page or communicated to active customers where appropriate.
If you do not agree with an updated policy, you may stop using our website and contact us to close your account. Continued use after notice of non-material changes constitutes acceptance of the updated notice for website use.
Data controller: Marksman Training Systems AB, Finlandsgatan 18, 164 74 Kista, Sweden. Email: info@marksman.se.
For privacy requests, subject lines such as “GDPR request” help us route your message promptly.
