Privacy Policy

Leyra AB (Accedo Magine AB)
Last updated: March 8, 2026

Version 2.0

Company Name: Leyra AB (Accedo Magine AB)
Organisation Number: 559551-3366
Registered Address: Magnus Ladulåsgatan 63, 118 27 Stockholm, Sweden
Privacy Contact: privacy@leyra.com
Websites covered: leyra.com, accedo.one, maginepro.com and all sub-domains

1. Introduction and Scope

Leyra AB (“Leyra”, “we”, “us”, or “our”) is a Swedish registered company providing end-to-end OTT streaming platform services to business customers. This Privacy Policy describes how we collect, use, store, and share personal data when you interact with our digital properties or engage with us in one of the capacities described below.

This policy applies to the following digital properties: leyra.com, accedo.one, maginepro.com, and all sub-domains of each (collectively, the “Digital Properties”). The legacy domains accedo.one and maginepro.com are owned and operated by Leyra AB following an asset transfer completed on 19 January 2026.

1.1 Who This Policy Covers

This policy applies to three categories of data subjects:
  • Marketing & Sales contacts — individuals who visit our Digital Properties, download content, request demos, or interact with our marketing activities
  • Job applicants & candidates — individuals who apply for employment or submit their details in connection with a recruitment process
  • Pre-contract business contacts — individuals at prospective or existing customer organisations who interact with our Digital Properties or correspond with us before a formal contract is in place

1.2 What This Policy Does Not Cover

This policy does not cover the following:
  • End-users of our customers’ streaming platforms — where Leyra processes End-users of our customers’ streaming platforms — where Leyra processes personal data on behalf of its B2B customers as a data processor, such processing is governed by a separate Data Processing Agreement (DPA) entered into with each customer, not by this policy.
  • Contracted customer contacts — once a commercial relationship is formalised by contract, there is an additional and separate Data Processing Agreement  governed by the relevant Master Services Agreement, which is in addition to this Privacy Policy.
  • Supplier and vendor contacts — personal data of individuals at supplier organisations beyond section 1.1, is handled in the context of procurement and is not covered by this policy.

If you are an end-user of a streaming service powered by Leyra, please refer to the privacy policy of the service operator, who is the data controller for your personal data.

2. Data Controller

The data controller responsible for your personal data under this policy is:

Controller: Leyra AB (Accedo Magine AB)
Organisation number: 559551-3366
Address: Magnus Ladulåsgatan 63, 118 27 Stockholm, Sweden
Contact: privacy@leyra.com

3. Category 1 — Marketing & Sales Contacts

This section applies to individuals who visit our Digital Properties (leyra.com, accedo.one, maginepro.com and all sub-domains), request information, download content, register for demos, subscribe to communications, or otherwise engage with our marketing and sales activities.

3.1 Personal Data We Collect

3.1.1 Data You Provide Directly
  • Identity data: full name, job title, company name
  • Contact data: business email address, telephone number, LinkedIn profile
  • Communication data: content of enquiries, demo requests, feedback forms, and correspondence
  • Subscription data: newsletter preferences and content download history
3.1.2 Data Collected Automatically
  • Technical data: IP address, browser type and version, operating system, device type
  • Usage data: pages visited, time on page, click paths, referral source, session duration
  • Location data: approximate geographic location derived from IP address (country/city level)
  • Cookie and tracking data: as described in Section 3.4 and our separate Cookie Policy

3.2 How We Use Your Data and Legal Basis

Purpose Legal Basis Details
Responding to enquiries and demo requests Contract / pre-contract steps (Art. 6(1)(b)) Processing necessary to respond to your request for information or a product demonstration
Sending marketing emails and newsletters Consent (Art. 6(1)(a)) Only where you have given explicit, freely given, informed, and unambiguous consent at the point of data collection
Website analytics and performance monitoring Legitimate interest (Art. 6(1)(f)) Improving the performance, security, and user experience of our Digital Properties. Balanced against low intrusiveness of aggregate analytics
B2B prospecting and sales outreach Legitimate interest (Art. 6(1)(f)) Identifying and contacting business professionals likely to have a genuine interest in Leyra’s services, proportionate to the B2B context
Fraud prevention and security monitoring Legitimate interest (Art. 6(1)(f)) Detecting and preventing misuse of our Digital Properties, bot traffic, and security incidents
Compliance with legal obligations Legal obligation (Art. 6(1)(c)) Where processing is required by applicable Swedish or EU law

 

3.3 Marketing Consent

We will only send you marketing emails, newsletters, or promotional communications if you have given us explicit opt-in consent (where regulation requires it) at the point of submitting your personal data (for example, by accepting the terms by proceeding to submit your data and / or checking a consent box on a contact form, demo registration, or content download form).

You may withdraw your consent at any time by clicking the unsubscribe link in any marketing email, or by contacting the Privacy Contact at the top of this document. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

Following marketing withdrawal, we will cease marketing communications immediately. We will retain your contact data on a suppression list for a period of 2 years in order to honour your opt-out and prevent accidental re-subscription. This retention is based on our legitimate interest in compliance with marketing regulations and prevention of unsolicited communications. 

3.4 Cookies and Tracking Technologies

Our Digital Properties use cookies and similar tracking technologies. By visiting our Digital Properties, you will be presented with a cookie consent banner. Non-essential cookies will only be activated following your explicit consent.

We use the following categories of tracking tools:

Our Digital Properties use cookies and similar tracking technologies. By visiting our Digital Properties, you will be presented with a cookie consent banner. Non-essential cookies will only be activated following your explicit consent.

We use the following categories of tracking tools:

Category Purpose
Analytics / Marketing CRM tracking, form submissions, visitor identification, email open and click tracking. Data processed in this category is covered by GDPR regulated clauses or Standard Contractual Clauses.
Marketing / Advertising Conversion tracking for advertising campaigns, retargeting audiences, and demographic insights on page visitors. Data processed in this category is covered by GDPR regulated clauses or Standard Contractual Clauses.
Analytics Aggregate website usage analytics including page views, session data, traffic sources, and user behaviour flows. Data processed in this category is covered by GDPR regulated clauses or Standard Contractual Clauses.

 

For full details of all cookies in use, their duration, and how to manage your preferences, please refer to our Cookie Policy available at leyra.com/cookie-policy

3.5 Sub-Processors and Service Providers

To operate our Digital Properties and deliver our services, we engage third-party sub-processors and service providers. All sub-processors are appointed under written data processing agreements that impose GDPR-equivalent obligations and, where required, appropriate international transfer safeguards. We use sub-processors in the following categories:

  • CRM and marketing automation providers — for contact management, email delivery, lead tracking, and marketing analytics
  • Advertising and social media analytics providers — for advertising campaign measurement and audience insights on our Digital Properties
  • Website analytics providers — for aggregate traffic analysis, performance monitoring, and user behaviour insights on our Digital Properties
  • Cloud infrastructure and hosting providers — for website hosting, content delivery, and platform operations
  • Legal and regulatory authorities — where required by applicable law

We do not sell your personal data to third parties. We do not share your personal data with unaffiliated third parties for their own marketing purposes. A current list of sub-processors is available on request by contacting the Privacy Contact at the top of this document.

3.6 Data Retention — Marketing & Sales

Data Category Retention Period
Website visitor analytics 26 months from date of collection
Marketing contact data (active) Until consent withdrawn, or 5 years from last meaningful interaction, whichever is earlier
Suppression list (post-unsubscribe) 2 years from date of unsubscribe
Demo and enquiry correspondence 5 years from date of enquiry

 

4. Category 2 — Job Applicants and Candidates

This section applies to individuals who apply for a position at Leyra AB, submit a speculative application, or whose details are provided to us in connection with a recruitment process.

4.1 Personal Data We Collect

  • Identity data: full name, date of birth (where provided), personally identifiable information / personal number
  • Contact data: email address, telephone number, postal address
  • Application data: CV/résumé, cover letter, portfolio, references
  • Professional data: employment history, qualifications, skills, certifications
  • Assessment data: interview notes, test results, evaluation records
  • Right to work data: nationality, work permit status (where legally required)
  • Correspondence: communications between you and our recruitment team

 

4.2 How We Collect Your Data

We collect application data through the following channels:

  • Direct email applications to our recruitment address
  • Third-party job boards and platforms (including LinkedIn and other employment platforms)
  • Applicant tracking systems where used for specific roles
  • Referrals from existing employees or professional contacts

 

4.3 Legal Basis for Processing

  • Pre-contractual steps (Art. 6(1)(b)) — processing necessary to evaluate your application and progress recruitment
  • Legal obligation (Art. 6(1)( c)) — verifying right to work and complying with employment law obligations
  • Legitimate interest (Art. 6(1)(f)) — maintaining records to defend against potential employment or discrimination claims, and retaining unsuccessful candidates for future roles (where you have been informed of this)
  • Consent (Art. 6(1)(a)) — where we ask for your consent to retain your details for future roles beyond the active recruitment process

 

4.4 Data Sharing

Your application data may be shared with:

  • Hiring managers and relevant members of the Leyra team involved in the recruitment decision
  • Third-party recruitment platforms and applicant tracking systems acting as data processors
  • Background screening providers, where applicable and with your knowledge
  • Legal and regulatory authorities where required by law

We do not share applicant data with other employers or unaffiliated third parties.

4.5 Data Retention — Job Applicants

If your application is unsuccessful, we will retain your application data for 2 years from the date of the final recruitment decision. This retention period is aligned with the limitation period under Swedish diskrimineringslagen (Discrimination Act) during which claims may be brought in relation to a recruitment process.

If your application is successful and you join Leyra, your application data will be transferred to your personnel file and will be subject to our employee data retention policy.

Where we wish to retain your details for consideration for future roles beyond the standard retention period, we will ask for your explicit consent to do so.

5. Category 3 — Pre-Contract Business Contacts

This section applies to individuals at prospective or existing customer organisations who interact with our Digital Properties, attend events, or correspond with us before a formal commercial agreement is in place.

5.1 Personal Data We Collect

  • Identity data: name, job title, company name
  • Contact data: business email address, telephone number
  • Communication data: meeting notes, email correspondence, proposals
  • CRM data: records of interactions, interests, and commercial discussions held in HubSpot

 

5.2 Legal Basis for Processing

  • Pre-contractual steps (Art. 6(1)(b)) — processing necessary to evaluate and progress a potential commercial relationship
  • Legitimate interest (Art. 6(1)(f)) — maintaining business contact records, tracking commercial discussions, and managing our sales pipeline in a manner proportionate to the B2B context

 

5.3 Transition to Contracted Status

Once a commercial relationship is formalised by a signed contract, the processing of your personal data as a named contact at a customer organisation is governed by the terms of that contract and any associated Data Processing Agreement (DPA). This Privacy Policy ceases to be the primary governing document for that relationship at that point.

5.4 Data Retention — Business Contacts

Data Category Retention Period
Pre-sales correspondence and meeting notes 5 years from last meaningful interaction, or until contract execution
CRM contact records (no contract executed)  5 years from last meaningful interaction
Business communications (contracted period) Governed by contract and DPA

 

6. International Transfers

Some of the service providers we use to operate our Digital Properties and manage our marketing activities process personal data outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place as required by GDPR Chapter V.

 

7. Your Rights

Under GDPR and Swedish dataskyddslagen (2018:218), you have the following rights in relation to your personal data:

Right What it means
Access (Art. 15) Request a copy of the personal data we hold about you and information about how we process it
Rectification (Art. 16) Request correction of inaccurate or incomplete personal data
Erasure (Art. 17) Request deletion of your personal data where there is no compelling reason for continued processing
Restriction (Art. 18) Request that we limit how we process your data in certain circumstances
Portability (Art. 20) Receive your personal data in a structured, commonly used, machine-readable format
Object (Art. 21) Object to processing based on legitimate interests or for direct marketing purposes
Withdraw consent (Art. 7(3)) Withdraw consent at any time where processing is based on consent, without affecting prior lawful processing

 

 

To exercise any of these rights, contact the Privacy Contact at the top of this document. We will respond within one month of receipt of your request, as required by GDPR Article 12(3). In complex or multiple requests, this period may be extended by a further two months, of which we will inform you within the initial one-month period.

We may need to verify your identity before processing your request. There is no fee for exercising your rights unless requests are manifestly unfounded or excessive.

Please note that exercising certain rights may affect your ability to use our services. For example, where you request erasure of your personal data or withdraw consent on which processing is based, we may no longer be able to provide the relevant services to you. In some cases, due to the technical architecture of our platform, we may only be able to implement a restriction of processing (Article 18) by deleting the relevant data rather than by suppressing its use — in which case we will inform you of this before proceeding, so you can make an informed decision.

8. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, role-based access controls, regular security assessments, and incident response procedures.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify Integritetsskyddsmyndigheten (IMY) within 72 hours of becoming aware, and will notify affected individuals without undue delay where required.

9. Privacy Contact

Leyra AB has assessed its obligations under GDPR Article 37. Leyra AB has determined that mandatory appointment of a DPO is not required based on the nature, scope, and scale of its processing activities. Privacy enquiries should be directed to the Privacy Contact at the top of this document.

10. Automated Decision-Making and Profiling

We do not make decisions about individuals that produce legal or similarly significant effects solely by automated means. Our use of analytics and CRM tools (including lead scoring) involves automated data processing, but final decisions regarding sales outreach, recruitment, or business relationships are always made by a human.

11. Scope: Business Professionals Only

Leyra’s Digital Properties and services are directed exclusively at business professionals and organisations. We do not knowingly collect personal data from individuals acting in a consumer capacity. If you believe that a minor or consumer has submitted personal data to us, please contact the Privacy Contact at the top of this document and we will delete it promptly.

12. Supervisory Authority

If you believe that our processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with a supervisory authority. In Sweden, the competent authority is:

Authority Integritetsskyddsmyndigheten (IMY)
Website www.imy.se
Address Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm, Sweden
Telephone +46 8 657 61 00

 

You may also lodge a complaint with the supervisory authority in the EU member state of your habitual residence or place of work.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our processing activities, legal requirements, or business operations. The “Last updated” date at the top of this policy indicates when the most recent changes were made.

For material changes, we will notify you by posting an updated version on our Digital Properties and, where the change affects consent-based processing (such as marketing communications), by sending direct email notification to affected individuals before the change takes effect.

14. Contact Us

For any questions about this Privacy Policy, to exercise your data subject rights, or to raise a privacy concern, please use the contact details at the top of this document, with the subject line marked with “Privacy — [your name]”

© 2026 Leyra AB (Accedo Magine AB). All rights reserved. Organisation number: 559551-3366.

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