EFFECTIVE: April 1, 2023
Previous version: DECEMBER, 2020
1. DATA CONTROLLER
On behalf of Virinco Technology AS, the CEO is the data controller for the processing of personal data regarding your use of our websites.
2. WHAT PERSONAL DATA DO WE COLLECT?
Our websites offer a variety of services that are collectively referred to as the “Service.” We collect information from individuals who visit our websites (“Visitors”) and individuals who register to use the Service (“Customers”).
Depending on the legal basis including the purpose of our processing, we may collect personal data from you either as a Visitor, or as a Customer, as described below:
a) Personal data about you as a Visitor
As you navigate our websites, we may collect information through the use of commonly used information-gathering tools, such as cookies and web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our websites (such as the web pages viewed, and the links clicked).
b) Personal data about you as a Customer
When expressing an interest in obtaining additional information about the Service or registering to use the Service, we require you to provide us with the following contact information about you:
- Company name
- Phone number
- Email address
(“Required Contact Information” and/or “Billing Information”)
We may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”).
Required Contact Information, Billing Information, and Optional Information are referred to collectively as “Data About Virinco Customers.”
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect personal data from you when you register on our websites, subscribe to a newsletter, fill out a form, contact us regarding our Service or enter information on our websites.
4. FOR WHAT PURPOSES DO WE USE YOUR INFORMATION?
We may use your personal data for the following purposes:
- To contact you about your interest in our Service
- To perform the Service requested by you
- To send you information about us and our partners for marketing purposes, including information about promotions and events
In addition, we may use simplified and depersonalized data for the following purposes:
- To share site-visit information with third-party web service providers. For example, we may share a web session identifier with Google to display relevant advertisements on Google Display Network.
- To use Web Site Navigational Information to operate and improve our websites, and to provide information about us and our Service to third parties.
5. THE LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA
The processing of data mentioned under section 2 b) above is used to fulfil the agreement with you regarding the provision of our Service. The legal basis of this processing is the General Data Protection Regulation (GDPR) Article 6 (1) (b).
6. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
We do not share, sell, transfer or otherwise disclose personal data to any other third parties unless we are legally obliged to do so.
7. ERASURE OF PERSONAL DATA
Data received or collected in connection with our Service is stored in our active user register as long as is necessary to achieve the purpose of the processing. The data is then deleted or anonymized. Data we are obliged to keep according to the Norwegian Accounting Act (in Norwegian: Bokføringsloven) will be stored for up to 5 years, in accordance with the requirements of the law.
8. INFORMATION SECURITY
We use robust security measures to protect your personal data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of personal data. When our Service are accessed using Secure Socket Layer (“SSL”) technology, we protect your personal data using both server authentication and data encryption. These technologies help ensure that your personal data is safe, secure, and only available to you and those you have granted access.
We host our websites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.
9. COOKIES AND WEB SITE NAVIGATIONAL INFORMATION
We use commonly used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate our websites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information we may collect and how we may use this information.
What is a cookie?
A cookie is a small piece of text sent to your browser by a website you visit. It helps the site remember information about your visit, which can make it easier to visit the site again and make the site more useful to you.
What kind of cookies do we use?
There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.
If you have chosen to identify yourself to us, we use session cookies containing encrypted information to allow us to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your account is placed on your Web browser. These session cookies allow us to uniquely identify you when you are logged into the Service and to process your online transactions and requests. Session cookies are required to use the Service.
We use persistent cookies that only we can read and use to identify browsers that have previously visited our websites. When you purchase the Service or provide us with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that we place on your Web browser. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate our websites, but you will not be able to successfully use the Service.
We may use information from session and persistent cookies in combination with Data About Virinco Customers to provide you with information about us and the services.
Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. We use Web beacons alone or in conjunction with cookies to compile information about your use of our websites and interaction with emails from us. For example, we may place Web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We use Web beacons to operate and improve our websites and email communications.
We may use information from Web beacons in combination with Data About Virinco Customers to provide you with information about us and the Service.
When you visit our websites, we collect your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, we use IP addresses to monitor the regions from which you navigate our websites.
We also collect IP addresses when you log into the Service as part of our “Identity Confirmation” and “IP Range Restrictions” security features.
A transparent pixel is an image file that is embedded in an email or webpage. When the file is loaded into an email or web client the image is uploaded from a Virinco associated server. This enables us to register that an email has been opened. A transparent pixel is the same as any image on an email, this is not strictly required to track an email open; the transparent pixel ensures at least one image is included on every email.
Note: Users not wanting to be tracked by Virinco Transparent pixels can choose not to download images.
10. PUBLIC FORUMS, REFER A FRIEND, AND CUSTOMER TESTIMONIALS
We may provide bulletin boards, blogs, or chat rooms on our web sites. For example through our support service provider zendesk.com.
Any personal data you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. We are not responsible for the personal data you choose to submit in these forums.
You may elect to use our referral service to inform friends about our websites. When using the referral service, we request the friend’s name and email address. We will automatically send the friend a one-time email inviting him or her to visit our web sites. We do not store this information.
We post a list of Customers and testimonials on our websites that contain information such as Customer names and titles. We obtain the consent of each Customer prior to posting any information on such a list or posting testimonials.
11. CUSTOMER DATA
Virinco Customers use the Service to host data and information (“Customer Data”). We will not review, share, distribute, or reference any such Customer Data except as provided in the Consultancy Agreement Terms & Conditions, or as may be required by law. Customers are responsible for maintaining the security and confidentiality of their Virinco Group’s Web sites usernames and passwords.
12. THIRD-PARTY WEBSITES AND APPLICATIONS
13. WHAT ARE YOUR DATA PROTECTION RIGHTS?
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal data.
If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your personal data.
- The right of restriction. You have the right to request that we restrict the processing of your personal data.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal data.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
14. COMMUNICATIONS PREFERENCES
We offer Customers and Visitors who provide contact information a means to cancel from email newsletters and other information from us. Either unsubscribe from our newsletter service or send an email to email@example.com. Customers cannot opt out of receiving transactional emails related to their account with Virinco or the Service.
15. CORRECTING AND UPDATING YOUR INFORMATION
When using our websites, customers may update or change their registration information either by using applicable forms or email firstname.lastname@example.org.
17. CONTACTING US
Virinco Technology AS
3036 Drammen, Norway