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Privacy Policy

Covering the APEQS Developer Kit (Free and Pro tiers) and apeqs.com

Effective Date: 2026-10-27

Data Controller: APEQS Technologies AB, a company registered in Sweden under organization number 559539-8586, with its registered address at Pumpgatan 1 c/o United Spaces, Gothenburg, Sweden ("Company," "we," or "us").

1. Scope

1.1 This Privacy Policy describes how Company collects, uses, and shares personal data in connection with the APEQS Developer Kit (Free and Pro tiers) and the apeqs.com website. It does not cover the APEQS Platform, which is addressed in a separate agreement and privacy notice provided to Platform customers.

1.2 This Policy should be read together with the Developer Kit End User License Agreement ("EULA"), particularly Section 7 (Usage Data and Privacy), and with our separate Cookie Policy for apeqs.com.

2. Personal Data We Collect

2.1 Account Data. When Customer signs up for the Developer Kit, we collect either:

  • Email sign-up: the email address provided, and confirmation that the associated address is valid; or
  • GitHub sign-up: the profile information returned by GitHub under the requested authorization scopes (read:user, user:email) — specifically username, public display name, public email address (or a GitHub-provided proxy address), and publicly visible profile fields such as company and location, where the Authorized User has made them available.

2.2 Usage Data. As described in Section 7 of the EULA, the Software transmits the following each time it runs:

  • Information necessary to enforce Free Tier limits (element, repository, and element-type counts);
  • The installed Software version, to check for and notify Customer of available updates;
  • Basic technical information, such as operating system and Software configuration, for diagnostic and product-improvement purposes.

2.3 Usage Data does not include the substantive content of Customer's requirements or source code, unless Customer separately opts into a feature that requires it.

2.4 Support Communications. If Customer contacts us for support, we collect the content of that communication and any information Customer chooses to provide in it.

2.5 Website Data. Our use of cookies and similar technologies on apeqs.com is described in our separate Cookie Policy.

2.6 Demo and Contact Requests. If Customer or a prospective customer submits a demo request, contact form, or similar inquiry on apeqs.com, we collect the information provided — typically name, business email address, company, and the content of the message — to respond to that request.

3. How We Use Personal Data

3.1 We use personal data described in Section 2 to:

  • Create and administer Customer accounts;
  • Provide the Software and enforce the Free Tier limits described in the EULA;
  • Notify Customer of available Software updates;
  • Diagnose errors and improve the Software;
  • Respond to support requests;
  • Respond to demo requests, contact form submissions, and other inquiries submitted through apeqs.com;
  • Send important service communications (for example, security notices or changes to this Policy or the EULA);
  • With Customer's consent, or as otherwise permitted by law, send product updates, newsletters, and other marketing communications, and contact Customer for feedback on the Software or to discuss Company's products and services;
  • Comply with our legal obligations, including under EU cybersecurity and product-safety legislation.

3.2 Customer may opt out of marketing communications at any time — using the unsubscribe link included in any such communication, or via the contact details in Section 10 — without affecting Customer's ability to use the Software. Service communications necessary to operate the Software (such as security notices) are not affected by this opt-out.

3.3 We do not use personal data collected under this Policy for third-party advertising, and we do not sell personal data.

4. Legal Bases for Processing

4.1 Where the GDPR applies, we rely on the following legal bases:

  • Performance of a contract (Article 6(1)(b)): Account Data, the portion of Usage Data necessary to operate the Free/Pro tier distinction described in the EULA, and responding to demo requests or other inquiries submitted at Customer's own initiative (as steps taken prior to entering into a contract).
  • Legitimate interests (Article 6(1)(f)): diagnostic and product-improvement elements of Usage Data, responding to support requests, and — for existing Customers only, on an opt-out basis — marketing communications about Company's own similar products and services.
  • Consent (Article 6(1)(a)): marketing or sales outreach to individuals who are not yet Customers, and any marketing communication for which Customer has been asked to opt in. Customer may withdraw consent at any time as described in Section 3.2.
  • Legal obligation (Article 6(1)(c)): retention and disclosure required under applicable law, including vulnerability-reporting obligations under the EU Cyber Resilience Act.

4.2 Customer may object to processing based on legitimate interests, or request that non-essential Usage Data collection be disabled, using the contact details in Section 10.

5. Data Retention

5.1 We retain Account Data for as long as Customer's account remains active, and for 12 months after account deletion, to the extent necessary to comply with legal obligations or resolve disputes.

5.2 We retain Usage Data for 12 months, after which it is deleted or aggregated such that it no longer identifies an individual.

6. Sharing and Sub-processors

6.1 GitHub. If Customer signs up using GitHub, GitHub, Inc. (a US company) acts as an identity provider for that sign-up. GitHub's own privacy practices govern the data GitHub holds about Customer; our receipt and use of the profile data GitHub provides to us is governed by this Policy.

6.2 Telemetry / Usage Data hosting. Usage Data described in Section 2.2 is processed on infrastructure operated by Company, located within the European Union. We do not engage a third-party analytics or telemetry provider for this data. The specific EU hosting region and any underlying cloud provider will be confirmed and, if applicable, named here as an infrastructure sub-processor before this Policy is published.

6.3 We do not otherwise share personal data with third parties, except where required by law, to enforce our agreements, or in connection with a merger, acquisition, or sale of assets, in which case we will notify Customer in accordance with Section 9.

7. International Data Transfers

7.1 GitHub, Inc. is based in the United States. Where Customer signs up using GitHub, personal data is transferred to the United States on the basis of GitHub's own compliance mechanisms, including the EU-U.S. Data Privacy Framework where applicable.

7.2 Usage Data described in Section 2.2 is hosted within the European Union, as described in Section 6.2, and its processing does not involve a transfer of personal data outside the EU/EEA.

8. Your Rights

8.1 Subject to applicable law, Customer (or the individual Authorized User whose data is processed) has the right to:

  • Access the personal data we hold;
  • Correct inaccurate personal data;
  • Request deletion of personal data;
  • Restrict or object to certain processing, including processing based on legitimate interests;
  • Receive a copy of personal data in a portable format;
  • Lodge a complaint with a supervisory authority — in Sweden, the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY).

8.2 To exercise these rights, contact us using the details in Section 10.

9. Changes to this Policy

9.1 We may update this Policy from time to time. For material changes, we will provide reasonable notice (for example, by email or an in-product notice) before the changes take effect, consistent with Section 15 of the EULA.

10. Contact Us

10.1 Questions about this Policy, or requests to exercise the rights in Section 8, can be directed to support@apeqs.com.