Legal

Privacy policy

Controller: Goobit Group AB (publ), org. nr 556952-8671 Postal address: Goobit Group AB (publ), c/o Goobit AB, Kivra: 556911-9992, 106 31 Stockholm, Sweden Email: info@goobit.se

Last updated: 2026-09-02


1. About this policy

Goobit Group AB (publ) ("Goobit", "we", "us") is the controller for the personal data processed through this website, goobit.se. This policy explains what we collect, why, on what legal basis, how long we keep it, and what rights you have under the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR").

goobit.se is an informational and investor relations website. You cannot open an account, buy anything or use a financial service here.

What this policy does not cover. Our products operated under separate brands, including BTCX (bt.cx), have their own privacy notices. Processing of shareholder data in the share register and in connection with general meetings is carried out by Euroclear Sweden AB and is described in the relevant notice of meeting.

2. What we process

2.1 Subscription to press releases

The press release subscription offered on our investor relations pages is operated by Modular Finance AB through its MFN service. When you subscribe, you submit your email address and choice of language to Modular Finance, which maintains the distribution list and sends the releases.

Modular Finance processes your email address in accordance with its own privacy policy, available at mfn.se/privacy-policy. If you want to unsubscribe, correct your address or have it deleted, use the unsubscribe link in any message you receive, or contact Modular Finance directly. You can also contact us at info@goobit.se and we will point you to the right place.

The legal basis for sending you the releases is your consent, Article 6(1)(a) GDPR, given when you confirm your subscription by email. Consent is also required for marketing by email under section 19 of the Swedish Marketing Act (marknadsföringslagen (2008:486)). You may withdraw it at any time, which does not affect the lawfulness of processing before withdrawal.

2.2 Contacting us

If you write to us at info@goobit.se or another address published on the site, we process the information you choose to include: typically your name, email address, and the content of your message.

Purpose: to receive, handle, answer and keep a record of your enquiry.

Legal basis: our legitimate interest in responding to enquiries addressed to us, Article 6(1)(f) GDPR. Where your enquiry concerns a possible business relationship, the basis is Article 6(1)(b) GDPR, steps taken at your request before entering into a contract.

Please do not send sensitive personal data or confidential information by ordinary email.

2.3 Operation and security of the site

The site is built and hosted on the Lovable platform. Content delivery and security are provided through Cloudflare. Technical logs are generated automatically when the site is accessed and may contain IP address, timestamp, requested page, HTTP status and browser user agent.

Purpose: to deliver the site, keep it available, and detect and prevent attacks, abuse and technical faults.

Legal basis: our legitimate interest in operating the site securely and reliably, Article 6(1)(f) GDPR.

2.4 What we do not do

We do not use analytics or tracking tools on goobit.se. We do not build visitor profiles, run behavioural advertising, or carry out automated decision-making that produces legal effects for you or similarly significantly affects you (Article 22 GDPR). We do not sell or rent personal data. The site is not directed at children and we do not knowingly collect personal data from children.

3. What we store on your device

goobit.se sets no cookies of its own for statistics, marketing or tracking, and no consent banner is shown.

The only data stored on your device by us is security and delivery data set by Cloudflare, used to protect the site against attacks and to serve content efficiently. Under the Swedish Electronic Communications Act (lagen (2022:482) om elektronisk kommunikation) this does not require your consent, because it is necessary to provide the service you have requested. You can clear it at any time through your browser settings.

Fonts. The typefaces used on the site are hosted by us. No font files are requested from third-party servers, so no data about your visit is sent to a font provider.

Investor relations pages. Our press release feed and the press release subscription form are components supplied by Modular Finance AB. They are third-party components that may set their own cookies, and for that reason they load only after you actively choose to display them. Once loaded, the data they process is governed by Modular Finance's privacy policy at mfn.se/privacy-policy.

If we later introduce anything else that requires consent, we will ask for it before it is used.

4. Who we share personal data with

We do not sell or rent personal data. It is shared only with:

PurposeProviderRoleLocation
Website platform and hostingLovable AB, SwedenProcessorEU/EEA
Content delivery and securityCloudflare, Inc., USAProcessorGlobal, see section 5
Press release distribution and subscriptionsModular Finance AB, SwedenOwn controller for the subscriber listEU/EEA
EmailGoogle Ireland LimitedProcessorEU/EEA

Each provider acting as our processor is bound by a data processing agreement under Article 28 GDPR and may process personal data only on our instructions.

We may also disclose personal data to advisers and auditors, to companies within the Goobit group where necessary for the purposes above, and to authorities where we are legally required to do so or where it is needed to establish, exercise or defend a legal claim.

5. Transfers outside the EU/EEA

We aim to keep processing within the EU/EEA. Cloudflare operates a global network, so limited technical data such as IP addresses may be processed outside the EU/EEA. Where that happens, the transfer is protected by an appropriate safeguard under Chapter V GDPR, normally the European Commission's Standard Contractual Clauses together with supplementary technical measures. You can request information about the safeguards in place by writing to info@goobit.se.

6. How long we keep personal data

DataRetention
Press release subscriptionHeld by Modular Finance for as long as your subscription is active, and deleted according to its policy after you unsubscribe
Correspondence and enquiries24 months after the matter is closed, or longer where needed to establish, exercise or defend a legal claim
Technical and security logsAs determined by our hosting and security providers, normally no longer than 12 months

Where a longer period is required by law, for example under the Swedish Accounting Act, that period applies instead.

7. Your rights

Under the GDPR you have the right to:

  • Access. Obtain confirmation of whether we process personal data about you, and a copy of it.
  • Rectification. Have inaccurate data corrected and incomplete data completed.
  • Erasure. Have your data deleted, for example when it is no longer needed or you withdraw your consent.
  • Restriction. Have processing restricted in certain circumstances.
  • Objection. Object to processing based on our legitimate interest, and object at any time to direct marketing.
  • Data portability. Receive data you have provided, where processing is based on consent or contract, in a structured, commonly used and machine-readable format.
  • Withdrawal of consent. Withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand.

To exercise a right, write to info@goobit.se. We respond without undue delay and within one month of receiving your request. That period may be extended by up to two further months if the request is complex, in which case we will tell you. We may need to verify your identity first. For the press release subscription, requests are handled by Modular Finance, and we will forward yours if you prefer.

Complaints. If you believe we process your personal data unlawfully, you can lodge a complaint with the Swedish supervisory authority:

Integritetsskyddsmyndigheten (IMY) Box 8114, 104 20 Stockholm, Sweden imy@imy.se +46 8 657 61 00 imy.se

You may also complain to the supervisory authority in your EU country of residence or place of work.

8. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, loss and disclosure. These include encryption in transit (TLS), access limited to personnel who need it, and contractual security requirements on our providers. No transmission over the internet can be guaranteed to be completely secure.

9. Data protection officer

Goobit Group AB (publ) is not required to appoint a data protection officer for the processing described here and has not appointed one. Data protection questions about goobit.se can be sent to info@goobit.se.

10. Changes to this policy

We may update this policy, for example if we change how the site works or which providers we use. The current version is always published at goobit.se with the date of the latest update at the top. If a change materially affects processing based on your consent, we will obtain your consent again where required.