Privacy policy
Last updated 2 November 2026 · Version 1.0
This policy explains what personal data Unlimit SioS collects when you use the app or a self-checkout terminal, why we hold it, and what you can do about it. It covers the shopper-facing parts of the platform.
Who is responsible for your data
Unlimit Group A/S operates the Unlimit SioS app, the self-checkout terminals and this website, and is the data controller for the personal data described here. You can reach us on +45 25 61 66 55.
What we collect
| Data | Why |
|---|---|
| Name, email address, telephone number | To create and secure your account, and to send receipts you ask for. Legal basis: performance of your contract with us, GDPR art. 6(1)(b). |
| Address, postcode, city, country | Where you provide it, for delivery and for shops that require it. Legal basis: art. 6(1)(b). |
| Identity from MitID: your name, date of birth and CPR number | To confirm you are who you say you are before you are given access to an unstaffed shop. Required to create an account. Legal basis: performance of your contract with us, art. 6(1)(b), and databeskyttelsesloven § 11 for the CPR number. |
| Date of birth | Age verification where a product requires it. Legal basis: art. 6(1)(c), our legal obligation not to sell age-restricted goods to minors. |
| Photograph of your face | Taken when you create your account. Used for face recognition at the terminal — see below. Legal basis: art. 6(1)(b). |
| Face template (biometric data) | Derived from that photograph so a terminal can recognise you — see below. Special category data under art. 9. |
| Your location | Sent by the app when you look for nearby shops and when you open a shop door, to confirm you are at the shop. Used at that moment and not stored. Legal basis: art. 6(1)(b). |
| Bluetooth connection to the door | To open the door of an unstaffed shop. We collect nothing else over Bluetooth. Legal basis: art. 6(1)(b). |
| Camera | Used twice: to take the photograph above, and to read the QR code on a terminal. When you scan a QR code only the code itself is sent to us — the picture is not stored or uploaded. Legal basis: art. 6(1)(b). |
| Gender | Derived from your CPR number at sign-up. We hold it, but nothing in the service uses it, and we are removing it. Legal basis: art. 6(1)(b). |
| Purchases, receipts and loyalty points | To complete the sale, give you a receipt and award points. Legal basis: art. 6(1)(b), and art. 6(1)(c) for the accounting records we are required to keep. |
| Shop entry and exit times | In unstaffed shops, to connect a visit to a purchase and to keep the shop secure. Legal basis: our legitimate interest in preventing theft and resolving incidents, art. 6(1)(f). |
| App and device information | To deliver notifications and keep the app working on your device. Legal basis: art. 6(1)(b). |
Face recognition
Creating an account requires a photograph of your face. From that photograph we create a face template — a mathematical representation of your face — so that a self-checkout terminal can recognise you and link your purchase to your account without you signing in. A face template is biometric data, which is a special category of personal data under GDPR Article 9.
- The template and the photograph are held with Amazon Web Services (AWS Rekognition) in the EU, in Stockholm.
- They are used for one purpose only: recognising you at a terminal. They are never used to track you between shops, and never shared with other customers or with the shop staff.
- At present this applies to every account that has a photograph, and the app does not yet give you a switch to turn it off by yourself. We are changing that. In the meantime you can ask us to delete your face data at any time by calling +45 25 61 66 55, and we will remove it without closing your account.
- Deleting your account deletes the template and the photograph automatically.
Payment
Card payments are handled by our payment providers. We never see or store your full card number. What we keep against a sale is the payment reference and the card product name — the same information printed on a paper receipt — so that a purchase can be matched to a payment and refunded if needed.
How long we keep it
- Sales and receipts: five years. Danish bookkeeping law (bogforingsloven §12) requires accounting records to be kept for five years from the end of the financial year. This applies even if you close your account.
- Account details: for as long as your account is open. When you delete it, they are anonymised — see your data rights.
- Face data: until you ask us to delete it, or you delete your account.
- Shop entry and exit records: for as long as your account is open. They are deleted when you delete your account.
- Support messages: for as long as your account is open, then deleted with it.
- Your location: not stored at all. It is used to answer the request you made and then discarded.
Who we share it with
We do not sell personal data. We share it only with the parties needed to run the service:
- the retailer whose shop you bought from;
- Idura (formerly Criipto), which operates the MitID login on our behalf;
- Amazon Web Services, for hosting, file storage, email and face recognition, in the EU (Stockholm);
- Hetzner, which hosts our servers in the EU (Germany);
- Google, for push notifications to your phone (Firebase) and for maps and address search in the app;
- ICT, whose system operates the doors of unstaffed shops;
- payment providers, to take and settle the payment at the terminal;
- an SMS provider, for the messages you ask us to send;
- e-conomic, our accounting system, for the records we are required to keep;
- authorities, where the law requires it, and the police where a theft or other crime is reported.
Each of these processes data on our instructions under a data processing agreement.
Where your data is held
Your account, your purchases, your photograph and your face template are all held inside the EU — the face template in Stockholm. Two things leave it: push notifications and the map and address search in the app both go through Google LLC in the United States. Those transfers rely on the EU–US Data Privacy Framework, with the European Commission’s standard contractual clauses as a fallback. You can ask us for a copy of the safeguards.
Automated decisions
We do not make decisions about you purely by automated means that have a legal effect or a similarly significant effect. Face recognition at a terminal identifies you so your purchase can be linked to your account; it does not decide anything about you, and a member of staff can always be reached on +45 25 61 66 55.
Children
An account requires MitID and the ability to enter a binding agreement, so the service is not intended for young children. We do not knowingly collect personal data from a child who cannot consent for themselves; under Danish law (databeskyttelsesloven § 6) that is a child under 13. If you believe a child has created an account, call us on +45 25 61 66 55 and we will remove it.
Cookies on sios.dk
This website sets no cookies at all. There is no analytics, no advertising and no tracking on these pages, which is why you have not been asked to accept anything.
Keeping it safe
Traffic between the app, the terminals and our servers is encrypted. Passwords are stored hashed, never in readable form, and access to our systems is limited to the people who need it. Profile photographs are currently stored so that anyone holding the file’s address can open it; we are changing that so they can only be opened through the app.
Your rights
You can see, correct, export or delete your data, and object to or restrict how we use it. How to exercise those rights.
Contact
Telephone +45 25 61 66 55, or write to Unlimit Group A/S, Denmark. If you are not satisfied with our answer you can complain to the Danish Data Protection Agency (Datatilsynet), datatilsynet.dk.