Privacy notice

Last revised version: 2025-06-23

1 Introduction

Roaring Group AB (“Roaring”) protects your personal privacy and aims to protect your personal data in the best possible way. We comply with the GDPR (General Data Protection Regulation (EU) 2016/679) in our business, and work continuously to ensure that the processing of personal data is performed safely with your privacy in focus. This policy clarifies to what extent and with what limitation we collect, process and store personal data.

If you want to know more or have concerns about how we process personal information, you are welcome to contact us at customer@roaring.io

This privacy policy applies to the services provided through Roaring’s web service and other web services, monitoring, APIs and plugins provided by Roaring Group AB (“Roarings Services”) with Swedish company id 559067-2613.

2 Information we collect about you and why we collect it

2.1 Customers

Roaring collects, processes and stores personal information regarding our existing customers. Information that can be collected is, for example, name, address, company (regarding individual companies), e-mail address, telephone number, IP address, chat or email conversations, which web pages that are visited on any Roaring web site and invoice information.

• The information collected from the registered users, i.e. the Customers employees or consultants using Roaring’s services, can be used for contact by email, improvement of the website, improvement of customer service, accounting and billing purposes.
• The data can also be used for business and method development, market analysis, statistics and risk management. The information that is processed in order to develop and analyse the business is treated on the basis of our legitimate interest to develop the business and to communicate with our customer contacts.
• The information can also be used for direct marketing, where the purpose is to develop the business where the legitimate interest is marketing purposes.

The purpose for this processing is to ensure that agreements with our customers are adhered to. Thus, the legal ground for the processing is normally fulfillment of the contract. The processing of this information is also based on your consent, or when there is a requirement in law that we must process the personal data. In addition, there is a legitimate interest to process the personal data. The purpose and the legitimate interest in processing the personal data is to develop the business and to communicate with users.

We never sell your information to anyone else. We only store personal data for the time it is necessary for the purpose of the processing, and required by law.

2.2 Prospects

Roaring Group AB collects, processes and stores personal information regarding our potential customers. Information that can be collected is, for example, name, address, company (regarding individual companies), e-mail address, telephone number, IP address, chat or email conversations and which web pages that are visited on any Roaring web site.

• The information collected from prospects can be used for contact by email, improvement of the website, improvement of customer service, accounting and billing purposes.
• The data can also be used for business and method development, market analysis, statistics and risk management. The information that is processed in order to develop and analyse the business is treated on the basis of our legitimate interest to develop the business and to communicate with potential customers.
• The information can also be used for direct marketing, where the purpose is to reach new customers where the legitimate interest is marketing purposes.

For potential customers (such as chat users), the purpose and the legitimate interest in processing personal data is marketing, developing the business and communicating with potential customers. The information stored is necessary to communicate with potential customers.

2.3 Customer logs

Roaring collects and stores information about our customer’s customers as a personal data processor. The data is collected when Roarings Customers makes an inquiry into Roarings services.

The information collected from customer’s customers, can be used for evidence and investigation purposes as well as requests from authorities.

The data is stored both due to legal requirements and legitimate interest.

2.4 Job applicants

When applying for a job opening at Roaring, we collect personal data from you as an applicant to evaluate your profile and competence for the purpose of recruiting for a position. The data we collect includes contact info such as name, telephone number, address and email address. The legal ground for this processing is legitimate interests. The information is deleted after the recruitment process unless consent is obtained to store it further.

2.5 Visitor of website

Roaring collects and analyses information from visitors of our website www.roaring.io and app.roaring.io. This is performed by using cookies which we use for marketing and sales purposes. The legal ground for this processing is legitimate interest.

Website visitors' e-mail address is collected through a cookie when the visitor interacts with Roaring by booking a demo or creating a sandbox account. The email is pseudonymised and sent to Roarings advertising partners, as independent data controllers, to be used to measure advertising conversions and improve ad relevance. The email is only collected if the visitor consents to cookies.

The Electronic Communications Act, which came into force on 25 July 2003, requires that all visitors to a website are informed about the use of cookies. We use cookies to keep statistics on how many people visit our website and which pages are visited. Cookies help us to improve the website by continuously learning how the website is used.

A cookie is a small text file that is stored in your computer's browser. It is easy to delete cookies and you can prevent the use of cookies by changing the settings of your browser so that it does not allow cookies to be stored on your computer. However, this may impair and prevent certain features and content. Non-functional cookies used by Roaring always require consent from the website visitor.

For more information about cookies, please review our Cookie policy: https://www.roaring.io/cookie-policy

On Roaring’s website there is also a chat function where the visitor can chat with representatives at Roaring. The data we collect from these visitors may include contact info such as name, e-mail, telephone number, IP address and other information provided by the visitor. The information is in some cases used for the purpose of marketing and sales.

2.6 Social media

Roaring uses different social media platforms for marketing purposes. When you visit or contact us on our social media channels, we collect personal data such as name, e-mail, profile picture and comments/questions. The legal ground for this processing is legitimate interests. Note that the social media platform can be responsible for some parts of your rights as a data subject that is beyond Roaring´s control.

3 Your rights

You have the right to:

• request information from Roaring about the use of the personal data that concerns you.
• request that Roaring correct or delete any personal data that is inaccurate.
• request that the processing of your personal data, in some cases, be limited. If you request that the processing of your information be limited, we may not be able to fulfill our possible obligations to you during the time the information is limited. However, the right to detention or limitation does not apply if, for example, we are required by law to preserve the data.
• receive part of your personal data in a machine-readable format or, if technically possible, to have the information transferred to a third party that you designate. This right only covers information that you have shared with us yourself.
• request that your information is not processed for direct marketing purposes. As a customer you can unsubscribe from such information, if you are not a customer you can contact us by using the contact information below or by using the chat function.

Roaring aims to respond to your request as quickly as possible, and no later than a month.

It is important for us that the personal data we process is correct. The data in Roaring’s database (described in section 5) is updated continuously and if a correction is made by an authority we have the new information shortly, which means that the data is automatically corrected in our register.

Please note that your rights above assume that Roaring is the personal data controller. When providing Roaring’s Services to our customers Roaring is the personal data processor, not the controller, and therefore we recommend you to contact the personal data controller directly. However, in case Roaring receives a data subject request in relation to your individual rights, we will assist the controller by providing any relevant data.

4 Comments or complaints

If you have comments, complaints or suggestions for improvements, you are welcome to contact us directly at customer@roaring.io.

If you are dissatisfied with how we process personal data, you can also file a complaint with a supervisory authority, which in Sweden is the Swedish Authority for Privacy Protection (IMY).

Personal data controller is Roaring Group AB, 559067-2613, Svärdvägen 7, 182 33 Danderyd, +46 (0)8-819 820, https://roaring.io, customer@roaring.io

5 The database is operating under the Swedish Freedom of Expression Act (YGL)

Roaring’s database at app.roaring.io, where Roaring provides data to its customers, is provided by Roaring Group AB – 559067-2613 and is operating under the Freedom of Expression Act (Yttrandefrihetsgrundlagen – YGL).

The responsible publisher is Roaring´s CEO, Johan Jensen.

6 How Roaring protects personal data

Information security is of the essence to us. Roaring uses advanced technical, physical and personnel measures to safeguard all data against any accidental, unlawful or unauthorized use, access, loss, modification or disclosure.

7 How long do we retain data

We keep the data as long as it is used for the purposes for which it is processed, as specified above, unless a longer period is required by law.

8 Changes in the personal privacy policy

We can update our privacy policy when needed. When the personal data policy changes, you see it by us changing the date of the policy “Last Revised Version”. The applicable personal data policy is always available on our website: www.roaring.io.

9 Questions and contact

If you have any questions about this privacy policy or how we handle Personal Data you can contact our customer success team at customer@roaring.io.

Roaring Group AB is committed to be a responsible company running its business in a way that employees can be proud of, ensuring financial strength and transparency, putting customers first and delivering long-term value to its environment and society.

Roaring Group expects its suppliers to uphold the same principles. Suppliers shall do so by providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically and using environmentally responsible practices where practicable.
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Roaring Group is committed to working with suppliers who share our values. We conduct risk-based assessments of our key suppliers to ensure they operate in alignment with the principles set out in this Supplier Code of Conduct (“CoC”) and in full compliance with applicable regulations in the countries where they operate.This CoC goes beyond mere compliance with the law by drawing upon internationally recognised standards, such as the International Labour Organisation (“ILO”) and the Universal Declaration of Human Rights (“UDHR”) to advance social and environmental responsibility.

This CoC sets out the required Supplier conduct regarding compliance with laws and regulations, business ethics and principles and rights at work (human rights, health and safety) and environmental protection.

This Code is reviewed annually and updated as necessary to reflect organizational changes or emerging risks. The COO of Roaring Group is responsible for implementation.

Code of Conduct

Last revised version: 2026-03-10

1 Background

2 General Requirements

2.1 Legal Compliance

Suppliers must comply with all applicable laws and regulations in the countries where they operate and hold all necessary permits. If this Code of Conduct sets higher standards than local legislation, the stricter requirement shall apply—unless it explicitly conflicts with local law. In such cases, the Supplier is expected to make reasonable efforts to fulfill the spirit of this Code of Conduct within the limits of the law.

2.2 Due Diligence

Suppliers are expected to conduct risk-based sustainability due diligence proportionate to the nature and scale of their operations, including their own supply chain. This involves identifying and assessing actual and potential risks and impacts on people, communities, and the environment. If a Supplier causes or contributes to negative impacts, they are expected to take appropriate measures to enable remediation, including compensation and restorative actions where relevant.

2.3 Management Systems

Suppliers are expected to maintain adequate management systems to support compliance with this Code and to promote continuous improvement. These systems should enable the identification and management of relevant risks, the setting of measurable targets, and the monitoring of performance within key areas such as human rights, labor conditions, environmental impact, and business ethics. Suppliers are encouraged to certify their management systems according to international standards, such as ISO 14001 (Environment), ISO 27001 (Information Security), ISO 45001 (Occupational Health and Safety), and ISO 9001 (Quality).

3 Principles and Rights at Work

3.1 Human Rights

Supplier shall ensure its operations and interactions with business partners or suppliers do not make Roaring Group complicit in human rights violations and that all employees are treated fairly and respectfully.

Supplier is therefore required to:

• not discriminate against any employee (ILO 100 and 111);
• not employ any worker below 15 years of age or the minimum age according to national legislation (ILO 138 and 182);
• to fully recognize employees’ rights to meet with the Supplier’s management to discuss salaries and working conditions without negative consequences (ILO 87 and 98);
• to not use forced or compulsory labor (ILO 29 and 105);
• to apply normal working hours that comply with applicable law and collective agreements;
• to pay workers a fair wage. Wages shall be paid directly to the employee on time and in full. Lowest acceptable salary level is the minimum wage according to national legislation;
• ensure that the Supplier’s services and products are not used to abuse human rights.

3.2 Health and Safety

The Supplier is required to provide a safe and healthy workplace. The Supplier shall abide by all applicable work-related health and safety legislation. All employees shall have access to and use appropriate safety equipment and be informed about safety and health risks. The Supplier shall ensure that health and safety incidents are reported and investigated

4 Business Ethics

Suppliers are expected to conduct all business ethically and transparently, in accordance with local legislation and international anti-corruption standards. Suppliers must take proactive measures to prevent, detect, and address all forms of corruption or unethical behavior.

4.1 Corruption and Financial Integrity

Suppliers shall have zero tolerance for all forms of corruption, including bribery, extortion, fraud, and embezzlement. No financial or non-financial benefits may be offered or accepted for the purpose of obtaining undue advantages or influencing decisions. This includes gifts, hospitality, travel, services, or other personal favors. Corrupt practices such as nepotism, favoritism, conflicts of interest, or abuse of power for personal gain are strictly prohibited. Suppliers must also actively prevent financial crimes, such as money laundering, tax fraud, tax evasion, and the misuse of offshore or high-risk structures.

4.2 Export Controls and Sanctions

Suppliers must comply with applicable laws and regulations regarding export controls, trade restrictions, and economic sanctions. This includes ensuring that products, services, technology, and data are not transferred or used in violation of such legislation.

4.3 Competition Law

Suppliers must comply with applicable competition and antitrust laws and must not engage in anti-competitive behavior such as cartels, bid-rigging, market allocation, or the exchange of commercially sensitive information with competitors.

4.4 Data Protection

Suppliers shall comply with applicable data protection legislation, including but not limited to the GDPR. This includes ensuring the security of personal data and following rules for the processing, storage, and transfer of personal data to preserve its confidentiality, integrity, and availability.

4.5 Information Security

Suppliers and subcontractors are expected to have documented and implemented technical and organizational security measures appropriate for their operations, which are regularly reviewed, assessed, and improved. Where relevant, Suppliers shall demonstrate that they maintain the confidentiality, integrity, availability, and resilience of systems, applications, and services provided to Roaring. Certification according to, for example, ISO 27001 or equivalent standards is encouraged.

4.6 Artificial Intelligence (AI)

Suppliers shall comply with applicable laws and regulations for AI, including but not limited to the EU AI Act and other international standards. AI shall be used responsibly, with safeguards to prevent harm, discrimination, violation of rights, or privacy breaches, reflecting principles of accountability, fairness, and responsible innovation.

5 Environment

Roaring Group strives to continually improve environmental performance and reduce its direct and indirect impact on climate change. Roaring Group’s Suppliers are therefore required to aim for a reduction of its negative environmental impact.

The Supplier is required to:

• maintain awareness of current environmental legislative requirements relevant to its business and implement said legislative requirements in its business operations through training, operational control and monitoring.
• set targets to reduce its material negative environmental impact, such as for example energy consumption, waste generation and disposal, water use and business travel and continually follow up on such targets.

6 Compliance with this CoC

Further, Supplier:

• shall implement the material requirements set out in this CoC into its operations. The Supplier assures that a person with the mandate and resources to implement and follow up this CoC is appointed without delay;
• must notify the Roaring Group of any breach of this CoC as soon as possible. The Supplier must then take necessary corrective actions promptly or within an agreed period;
• is obliged to contractually ensure that its subcontractors comply with this CoC;
• gives Roaring Group a right to review the Supplier’s compliance and undertakes to provide evidence, if requested by Roaring Group, of how it monitors, measures and manages material requirements set out in this CoC;
• undertakes to fill in and sign Roaring Groups self-assessment document, based on the requirements in this CoC upon request from Roaring Group, however not more than once annually;
• gives Roaring Group a right to terminate the Parties’ agreement effective immediately.