European Privacy Seal for Sierra Portugal


Retail Movves (as implemented by Sonae Sierra)

Function as provided in February 2015

Qualification: IT-based service

View the Retail Movves (as implemented by Sonae Sierra) Certificate

Cert. No.



15/04/2015 - 30/04/2017


12/2015 (O.K.)

08/2016: Service currently not in use!

Public report

Retail Movves (as implemented by Sonae Sierra) Short Public Report Image  



Sierra Portugal, SA

Torre Colombo Ocidente
Rua Galileu Galilei nº2 – 3ºPiso
1500 – 392 Lisboa


Retail Movves (as implemented by Sonae Sierra) adheres to the principle of data avoidance and minimisation: (1) Collected GUIDs are de-identifed by means of salted hashes immediately. (2) De-identified information is aggregated prior to being transmitted to a central server (where it is available for statistical evaluation). 


If visitors of shopping centers in which Retail Movves has been implemented do not want their MAC ID and IMSI to be collected by means of the ToE, then their only option is to switch off their mobile devices for the duration of their visit to the respective shopping center. 


The IT-based service Retail Movves (as implemented by Sonae Sierra) is a visitor flow analytic solution for indoor environments. Its objective is providing management information in a statistical way, to support shopping center managers in taking the best decisions. The seal at hand is not awarded for the Retail Movves software that is at the core of the service, but for the implementation of this software by Sierra Portugal at various shopping centers that are run by Sierra. Integral part of each implementation is the installation of antennas that passively collect MAC IDs and IMSIs from visitors' mobile devices. 


The ToE works as follows: Passively collected GUIDs (MAC ID and IMSI) are de-identified by means of salted hashes immediately after their collection. The original data is then discarded without any delay. De-identified information that is related to movements of a single person within a shopping center and that may contain the hashed GUIDs is usually deleted within a day. Only aggregated data is transmitted to a central server and available for statistical analysis by means of a graphical user interface. In the highest resolution, aggregated data is available in the form of hourly snapshots.

Transparency is ensured by means of a pictogram. This pictogram is printed on stickers that are then placed in the entrance doors of a shopping center where Retail Movves is deployed. On the sticker, the pictogram is accompanied by very basic information about the ToE. In addition, the sticker comes with reference to more detailed information that may be accessed by means of a specific website or a flyer that is available inside of the shopping center.  

Flyer and website provide privacy-relevant information about the ToE. Among others, visitors are informed that they must switch-off their mobile devices in order to be excluded from data processing by means of Retail Movves.

Technical Evaluator

Judith Larreta
Sigacus Gestion, S.L.
Plaza Azkoitia, 5, 2-D,
20011 Donostia San Sebastian

Legal Evaluator

Inês Antas de Barros
Vieira de Almeida & Associados
Av. Duarte Pacheco, 26
1070 - 110 Lisboa

Formerly Certified Versions




This register is kept with the utmost care. However, EuroPriSe does NOT guarantee the accuracy of information found on the Site. Your reliance on information found on the Site is at your own risk. For more information please go to EuroPriSe Terms & Conditions.

Sierra Portugal, S.A. proved that its IT-based service "Retail Movves (as implemented by Sonae Sierra)" complies with EU data protection law. Customers of Sierra can be sure that processing of MAC IDs and IMSIs of their mobile devices for the purpose of analysis of visitor flows in shopping centers is in line with the high requirements of EU data protection law: MAC IDs and IMSIs are de-identified immedately and only aggregated (de-identified) information is used for statistical analysis.

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v1.5; service function as provided in 05/2018

Qualification: IT product and IT-based service (processor service)

View the REISSWOLF f.i.t. certificate

Version of Certification Criteria


Cert. No.



24/05/2018 - 31/05/2020




Public Report

f.i.t. Short Public Report Image Image 



Im Heegen 13
22113 Oststeinbek


Access policies can be used to restrict system usage to specific times of the day and/or IP addresses to reduce the attack vector for third-party access. A user session is controlled by means of a cross-tab synchronised session countdown.


Regarding the processing of personal data on third persons by means of f.i.t., it must be highlighted that the (usually) corporate users of the service qualify as controllers whereas REISSWOLF Systems GmbH acts as a processor on behalf of the users. Customers are advised that the legitimate use of the service may require the collection of the data subject's consent and/or declaration of release from confidentiality.


REISSWOLF f. i. t. is a web-based archiving system for data storage and access. It serves the purpose of uploading, storing, managing and exchanging data in the sense of a document management system. f.i.t. is a web application that can be used with common internet browsers. 


REISSWOLF f. i. t. is primarily designed for commercial use. It is distributed by REISSWOLF Systems GmbH and operated as Software as a Service (SaaS) in a data center in Germany.

The ToE includes

  • The web-based service REISSWOLF f.i.t. (for details, please cf. the short public report)

It does not include

  • REISSWOLF f.i.t. mobile app
  • REISSWOLF f.i.t. hotfolder
  • Office module
  • Teamviewer
  • Other alternative interfaces to clients

Technical + Legal Evaluator

Ann-Karina Wrede
Innungsstraße 7
21244 Buchholz

Initial Certification: 05/2018

REISSWOLF f.i.t. provides a web-based service that enables companies to upload, store, manage and exchange data in the sense of a document management system. Users of the service are controllers in respect of personal data on third persons that is processed by means of f.i.t.. The service is designed in a way that facilitates the users' compliance with EU data protection law.



This register is kept with the utmost care. However, EuroPriSe does NOT guarantee the accuracy of information found on the Site. Your reliance on information found on the Site is at your own risk.


European Privacy Seal for REISSWOLF f.i.t.