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Privacy + cookie policy

  1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies to all Sobreiras AS websites and services as well as where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.5 In this policy, «we», «us» and «our» refer to Sobreiras AS. For more information about us, see Section 13.

 

  1. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).

 

  1. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services («usage data«). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your personal data that you provide to us in the course of the use of our services («service data«). The service data may be processed for the purposes of providing our services, ensuring the security of our websites and services, maintaining back-ups of our databases and communicating with you (including requesting feedback regarding our services). The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business.

3.4 We may process your website user account data («account data«). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.5 We may process information that you post for publication on our website or through our services («publication data«). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6 We may process information contained in any enquiry you submit to us regarding goods and/or services and/or any other data you voluntarily provide in response to questionnaires, download forms, chats and/or registration to newsletters («enquiry data«). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or the taking steps, at your request, to enter into such a contract.

3.7 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website. («transaction data«). The transaction data may include your contact details, your card details and the transaction details. The source of the transaction data is you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters («notification data«). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and/or our legitimate interests, namely communications with our website visitors and service users and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.9 We may process information contained in or relating to any communication that you send to us by email, chat or any similar communications system («message data»). The message data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms or chat. The message data may be processed for the purposes of communicating with you (including where appropriate sending you sales or marketing materials) and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business and communications with users, prospective customers and customers.

3.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks.

3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3.14 If you would like us to destroy information we hold about you, please let us know. However, please note that if you use any of our services which require you to provide personal information, deleting our records may mean that you will need to resubmit it to continue using such services.

3.15 We may disclose aggregate statistics about our site visitors, clients and sales in order to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.

 

  1. Providing your personal data to others

4.1 If you make an enquiry seeking a quotation for or information about our professional services, we may disclose your enquiry data to one or more third party partners for the purpose of enabling them to contact you so that they can provide the quotation or information, or otherwise offer, market and/or sell to you relevant professional services.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 Your personal data held in our website database will be stored on the servers of our hosting services providers Siteground.com, Drift.com and Hubspot.com.

4.4 Financial transactions relating to our websites and services are handled by our payment service provider, Stripe. We will share transaction data with our payment service provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/privacy.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

  1. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 The hosting facilities for our website are situated in the USA. The European Commission has made an «adequacy decision» with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.3 The servers of some of our cloud services providers are situated in the USA. The cloud services providers in question include Siteground (web hosting), Namecheap (email provider), Drift (chat and conversation systems) and Hubspot (CRM and marketing).The European Commission has made an «adequacy decision» with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

 

  1. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) usage data will be retained for a period of 30 months following the date of collection;

(b) account data and service data will be retained for so long as the associated account remains open and for a period of up to 7 years following the end of the year during which the corresponding account was closed;

(c) publication data will be retained for the period of publication and for a period of up to 12 months following the date it ceases to be published;

(d) enquiry data will be retained for a period of up to 7 years following the end of the year during which the relevant communication was sent.

(e) transaction data will be retained for a period of up to 7 years following the end of the year during which the relevant transaction occurred;

(f) notification data will be retained for so long as the relevant person remains opted-in to notifications; and

(g) message data will be retained for a period of up to 7 years following the end of the year during which the relevant communication was sent.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

  1. Your rights

7.1 In this Section 7, we have listed the rights that you have under data protection law.

7.2 Your principal rights under data protection law are:

(a) the right to access – you can ask for copies of your personal data;

(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure – you can ask us to erase your personal data;

(d) the right to restrict processing – you can ask use to restrict the processing of your personal data;

(e) the right to object to processing – you can object to the processing of your personal data;

(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

 

  1. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either «persistent» cookies or «session» cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

 

  1. Cookies that we use

9.1 We use cookies for the following purposes:

(a) authentication and navigation – we use cookies to identify you when you visit our websites and as you navigate our websites;

(b) shopping cart – we use cookies to maintain the state of shopping carts as you navigate our websites;

(c) personalisation – we use cookies to store information about your preferences and to personalise our websites for you;

(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our websites and services generally; and

(e) analysis – we use cookies to help us to analyse the use and performance of our websites and services.

 

  1. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

10.3 We use Hubspot. Hubspot gathers information about the use of our website and notifications (email and chat) by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Hubspot’s use of information and review their privacy policy at https://legal.hubspot.com/privacy-policy.

10.4 We use Drift. Drift gathers information about the use of our website and chat notifications by means of cookies. The information gathered is used to create reports about the use of our website and to communicate with its users. You can find out more about Drift’s use of information and review their privacy policy at https://www.drift.com/privacy-policy/.

10.5 We use Facebook Ads. Facebook gathers information about the use of our website by means of cookies. The information gathered is used to measure the effectiveness of advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. You can find out more about Facebook’s use of information and review their cookie policy at https://www.facebook.com/policies/cookies/.

10.6 We use Google Adwords. Google gathers information about the use of our website by means of cookies. The information gathered is used to measure the effectiveness of advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. These ads may contain cookies. While we use cookies in other parts of our Website, cookies received with banner ads are collected by our ad company, and we do not have access to this information. You can find out more about Google’s use of information and review their cookie policy at http://www.google.com/privacypolicy.html. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page at http://www.google.com/ads/preferences/.

10.7 We use Hotjar. Hotjar gathers information about the use of our website by means of cookies. Hotjar assists us in providing you / the end users with a better experience and service as well as assist in diagnosing technical problems and analyzing user trends. Most importantly, through Hotjar’s services, the functionality of our site can be improved, making it more user-friendly, more valuable, and simpler to use for you / the end users. You can find out more about Hotjar’s use of information and review their cookie policy at https://www.hotjar.com/legal/policies/privacy. You may opt-out from having Hotjar collect your information when visiting a Hotjar Enabled Site at any time by visiting https://www.hotjar.com/legal/compliance/opt-out  and clicking ‘Disable Hotjar’ or enabling Do Not Track (DNT) in your browser.

 

  1. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

 

  1. Amendments

12.1 We may update this policy from time to time by publishing a new version on our website.

12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

12.3 We may notify you of significant changes to this policy by email.

12.4 The new policy will replace any previous policy wording and all conditions and terms of use will be in force from the date of publication.

 

  1. Third party websites

13.1 Our websites includes hyperlinks to, and details of, third party websites.

13.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

 

  1. Updating information

14.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

 

  1. Your choices

15.1 You can control cookie and tracking tools. If you turn off cookies, certain features and functions of the USGA Products may not be available to you.

15.2 You can opt out of receiving promotional emails from the Sobreiras Studios.  To do so, email us at [email protected] or follow the instructions in any promotional message you get from us.  Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.

 

  1. Acting as a data processor

16.1 In respect of personal data which falls within the scope of any data processing contract that we have entered into, we do not act as a controller of that personal data; instead, we act as a processor of that personal data.

16.2 Insofar as we act as a processor rather than a controller, this policy shall not apply. Our legal obligations as a processor are instead set out in the contract between us and the relevant controller.

 

  1. Our details

17.1 This website is owned and operated by Sobreiras AS.

17.2 We are registered in Norway under registration number 921882246, and our registered office is at Eiler Baanrudsvei 2, 2212 Kongsvinger.

17.3 Our principal place of business is at Eiler Baanrudsvei 2, 2212 Kongsvinger.

17.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website chat;

(c) by telephone, on the contact number published on our website; or

(d) by email, using the email address published on our website.

 

  1. General Data Protection Regulation (GDPR)

18.1 We are a Data Controller of your information.

18.2 Sobreiras AS legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information:

(a) Sobreiras AS needs to perform a contract with you

(b) You have given Sobreiras AS permission to do so

(c) Processing your personal information is in Sobreiras AS legitimate interests

(d) Sobreiras AS needs to comply with the law

18.3 Sobreiras AS will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Our Privacy Policy was generated with the help of GDPR Privacy Policy Generator.

18.4 If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.

(a) In certain circumstances, you have the following data protection rights:

(b) The right to access, update or to delete the information we have on you.

(c) The right of rectification.

(d) The right to object.

(e) The right of restriction.

(f) The right to data portability

(g) The right to withdraw consent

 

  1. Tracking technologies

18.1 We collect information about users across websites and over time when you use our websites (including mobile versions of the sites), mobile apps, and other services and platforms. We also have third parties that collect information this way. To do this, we and our vendors and service providers use several common tracking tools, including browser cookies, web beacons, flash cookies, and similar technologies.

18.2 We use tracking tools, including cookies, on our platforms:

(a) To recognize new or past visitors.

(b) To store your password if you create an account on our site.

(c) To improve our website and to better understand your visits on our platforms.

(d) To integrate with third party social media websites.

(e) To serve you with interest-based marketing and advertising.

(f) To observe your behaviors and browsing activities over time.

(g) To better understand the interests of our users.

 

  1. Log Files

19.1 Sobreiras Studios follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

 

  1. Children’s Information

20.1 Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. Sobreiras Studios does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

 

  1. Third Party Privacy Policies

21.1 Sobreiras Studios’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. 

 

  1. Sale of business

22.1 If this business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

 

  1. Data protection officer

23.1 Our data protection officer’s contact details are: Kristian Walby, +47 4848 5000, [email protected].

 

Last updated 1. September 2019