- SUBSCRIBER PROVISIONS
- DATA COLLECTION AND MAINTENANCE
Generally, we collect or maintain the following categories of data:
Customer Registration Data:
Customer Message Recipient Data:
- PURPOSES OF COLLECTED DATA
We may use the information We collect and maintain, including any personal data, for the following purposes:
- If You have provided Your contact information to Us, we may use such information to contact You for marketing and promotional purposes by various means, including regular mail, e- mail, telephone or SMS (mobile telephone text messages).
- To process Orders, requests and payments, and to communicate with Our Subscribers about their accounts or any requests, Orders or payment;
- To provide requested Services to our Subscribers. The Services we provide may include certain marketing and promotional Services, including sending or facilitating the delivery of communications on behalf of and at the request of Our Subscribers. In such cases, Our Subscribers are responsible for the content and delivery of said communications.
- To respond to any inquiry submitted to Us and to provide technical support to You.
- To tailor the content and information that We may send or display to You or Website visitors, to display targeted advertisements, and to otherwise personalize experiences at the Site;
- To better understand how Website visitors and Users access and use the Site and Services, both on an aggregate and individualized basis, for the purposes of improving the Site and Services and responding to visitor and Subscriber desires and preferences; and
- DISCLOSING COLLECTED DATA
We do not trade personal data, whether Customer Registration Data or Customer Message Recipient Data, without prior consent from the Subscriber. We may however, disclose the information We collect or maintain, including personal data, without prior consent as described below:
Service Providers. We may disclose the information we collect from You to Our representatives, including Amazon, Inc. (“Amazon”) with data storage facilities in Europe, United States of America and/or Asia, and Braintree Payment Solutions, LLC (“Braintree”). with payment processing facilities in the United States of America, who perform on our behalf: processing not limited to data storage and credit card processing to bill You for campaigns and Services and a live chat representative to assist us with customer service, marketing analysis, services to help manage our online advertising, customer relationship management services, internal system monitoring and performance services. These third parties are required to maintain the confidentiality, integrity and accessibility of personal data and are restricted to use such data only as directed by Us under strict confidentiality. Amazon and Braintree are operating under a Data Processing Addendum and has implemented Standard Contractual Clauses (“model clauses”) defined and approved by the European Commission ensuring compliance outside the European Economic Area.
Company Transfer. If we are acquired by, assigned to or merged with another company, if part of our assets is transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal data We have collected to the acquiring legal entity. You will be notified via e-mail or proper notice on the Site thirty (30) days up front of any such disclosure of your personal data.
Aggregated and Anonymous Information. We may share with third-parties aggregated, anonymous (de-identified), Subscriber information, such as data, for purposes of marketing, advertising, research or similar. We do not disclose any personal data to third parties.
- REASONS FOR SENDING YOU E-MAILS
If you received one or more marketing or promotional messages (“Commercial Messages”) from Us, it means that a) your e-mail address is on Our list of Subscribers or Users; or b) You have provided Us Your e-mail address for communication. If You have received an e-mail from Us of which You are not the right recipient, please contact us immediately at email@example.com and delete the e-mail. Subscribers may use Our Services to send Commercial Messages to recipients who have opted- in to receive such SMS, e-mails or other electronic messages, or with whom Subscribers have a previous relationship authorizing such communication. According to Our Anti-Spam Policy, Subscribers are not permitted to send unsolicited marketing or promotional messages and are required to obtain opt-in consent from a recipient, prior to sending a commercial message to a recipient with whom the Subscriber does not have a previous relationship authorizing such communication. While we have a strict Anti-Spam Policy, we cannot guarantee that our Subscribers will always honor such policy. If you believe you have received a message from one of our Subscribers in error or in violation of our Anti-Spam Policy, please contact us immediately at firstname.lastname@example.org and delete the message.
We may send You Our newsletter, using Your name and e-mail address. You may also request Our newsletter. We provide you a way to unsubscribe to Our newsletters by following the unsubscribe link located at the bottom of each newsletter.
Similarly, each commercial e-mail sent by Our Subscribers through Our Services contains an unsubscribe link. Simply click on that link and follow the instructions to unsubscribe Your e-mail address. If You have unsubscribed but continue to receive e-mail from Us or from one of Our Subscribers, you may report this to email@example.com. Please note that unsubscribe requests may take up to five (5) working days to process.
- OPT-OUT FROM RECEIVING SMS, CALLS AND E-MAILS
If You wish to opt-out from receiving various communication relating to topics such as your Account, Services, Legal, Marketing and other topics via SMS, telephone calls or e-mails from Us you can do this at any time in your account settings or by sending us an e-mail at: firstname.lastname@example.org We also provide you the opportunity to ‘opt-out’ of having your Personal Information used for certain purposes at any time we adjust or introduce new services or topics, we ask for this consent on every occasion and you can modify this at any time as detailed above.
- PUBLIC FORUMS
The Site also offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is visible to and may be read, collected, used or disclosed by other registered Site users or public visitors to the Site. To request removal of Your personal data from our blog or community forum, contact us at email@example.com. In order to post Subscriber testimonials on the Site which may contain personally identifiable information We do obtain the Subscriber’s prior consent via e- mail. To request removal of Your personal data from Our testimonials, contact Us at firstname.lastname@example.org.
- SECURITY OF COLLECTED PERSONAL DATA
We employ industry-recognized information technology to protect the security of the information and personal data you submit to us, both during transmission and once we receive it. The importance of security for all Personal Information associated with our users is of utmost concern to us. Our secure servers protect this information using password protection and advanced encryption, and we may use firewall technology for additional protection. When you enter sensitive information (such as a credit card number, login information for our Services, or Geo- Location information) on our Offerings, we encrypt the transmission of that information using secure socket layer technology (SSL). Furthermore, all of the user data we collect is protected against unauthorized access by physical security means. We also encourage our partners and service providers to adopt and follow stringent consumer privacy policies. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. The processing of personal data in accordance with Section 13 of the Norwegian Personal Data Act and the General Data Protection Regulation. The security of Your personal data is important to Us. In the unlikely event of a personal data breach we will inform you immediately as the data controller and if the breach warrants the supervisory authority without undue delay unless that would involve disproportionate effort (in accordance with Article 33 and 34 of GDPR). We will also take measures to mitigate any possible adverse effects of the breach. If You have any questions about security and our services protecting your data, please e-mail Us at: email@example.com. If you wish to report an incident or concern, then please e-mail us immediately at: firstname.lastname@example.org.
- THIRD PARTY WEBSITES
- COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies: When You enter the Site, our web server sends a cookie to Your computer. Cookies are alphanumeric identifiers that We transfer to Your computer’s hard drive through Your web browser for record-keeping purposes. There are two types of cookies: session-based and persistent cookies. In addition, we may permit certain third parties to place cookies through our Site. We do not link the information we store in cookies to any personally identifiable information you submit while on our Site, other than by linking persistent cookies to our Subscribers. Session cookies:Session cookies remain on Your computer after You have closed your browser or turned off your computer. We use persistent cookies that only We, or Our service providers, can read and use, to identify the fact that You are or previously have been a Subscriber. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies.
Disabling Cookies: Most web browsers automatically accept cookies, but if You prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell You how to prevent Your computer from accepting new cookies, how to have the browser notify You when You receive a new cookie, or how to disable cookies altogether. Site visitors who disable their web browsers’ ability to accept cookies will be able to browse the Site but with a limited user experience; however, Unfortunately our services require that you have enabled cookies in order to use our Services but this is your choice.
Clear Gifs (Web Beacons/Web Bugs): We or the third parties we engage to track and analyze Site Data may employ clear gifs (a.k.a. Web Beacons/Web Bugs) to help Us better manage content on the Site. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Users and Site visitors. In contrast to cookies, which are stored on Your computer’s hard drive, clear gifs are embedded invisibly on Site pages. We do not connect the information gathered by clear gifs to our customers’ personally identifiable information.
We also use clear gifs in our HTML-based e-mails. They let Us know which e-mails have been opened by recipients, allowing Us to gauge the effectiveness of certain communications and marketing campaigns. For information on how to opt-out of receiving marketing e-mails from Us, or from Our Subscribers, please see the sections “Newsletters” and “Opt-out from receiving SMS, calls and e-mails” above.
Flash LSOs: We may use local shared objects, also known as Flash cookies, to store Your Site preferences, to personalize Your visit, or to display content based upon what You view on the Site. Third-parties with whom we partner to provide certain features on the Site or to display advertising based upon Your web browsing activity, may use Flash cookies to collect and store information. We do not have access to or control over these third-party cookies. Flash cookies are different from browser cookies because of the amount and type of data stored. In addition, you cannot control, delete, or disable the acceptance of Flash cookies through Your browser. To learn how to manage Your settings for Flash cookies, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.ht ml#117118.
- MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
- YOUR ACCESS TO YOUR INFORMATION AND YOUR OTHER RIGHTS
An important part of the GDPR regulations are your specific rights afforded to you be the data legislation. These rights are:
a. The right of access: You can request to view what your data will be used for (e.g. “email marketing”, “data analysis”), and give you the option to view how the data is being used.
b. The right to object: You can object to your data being used in a certain way, you have the right to opt out, and this will be respected.
c. The right to rectification: You can seek to access any personal data a company retains about you and amend it if necessary.
d. The right to be forgotten: The right to delete your account for a particular service at any time, and also request that any data collected about you be wiped from our system.
e. The right of portability: You can request that an export of your data be given to a third-party client, should you request it.
In order to access, object, rectify, erase or request transfer to any of your personal data We have collected about You. Please download the dsrm form on our website, fill it out and send it to us along with a proof of identity and your contact details at: email@example.com. Requests and Data will be handled provided in a relevant format. Your request will be handled within thirty (30) days upon confirmation of identity and the validity of the request. We will retain Your information for as long as your account is active or as necessary to provide you Services and comply with our legal obligations, resolve disputes and enforce agreements.
Your Rights Upon Termination
We are not storing Your Data longer than necessary for fulfilling the terms of the Agreement including Appendices. You have regardless of any termination the rights as described above. However, withdrawal of Your consent to process Your personal data has no retroactive effect. If You opt-out from various communications such as marketing and other communications, we may with your consent communicate with you regarding your account or services. However, opting out from all communication will be respected. However, if you require Us to delete or stop processing Your personal data or cease to communicate with you it will no longer be possible to provide you with the Services and Your access to the Site will be deemed terminated. Please note that We may need to identify You and to request additional information in order to be able to fulfil Your request. Please also note that applicable law may contain restrictions and other provisions that relate to Your rights.
- YOUR RIGHTS (FROM ANTI-SPAM POLICY)
You have accepted Our Terms of Service prior to using the Services. As part of the Agreement You agreed to only communicate with legal entities or persons who have consented to receiving Your communication or with whom You have a previous relationship authorizing such communication. An opt-in can occur via a sign-up form on a website, either at a point-of-sale sign-up form, or on a physical sign-up sheet. Any opt-in form should include a clear description of what content will be sent from You and the frequency of messages to be sent.
- Send a message and campaign to a recipient who has opted-in to receive your communications.
- Send a message and campaign to a recipient with whom You have a previous relationship authorizing such communication.
- Send out information and content to recipients who have requested to receive content on that topic from Your business or organization (“pull”).
- REFUSAL OF PERSONS UNDER 18 YEARS OF AGE
Our Site and Services are not intended to be used by persons under eighteen (18) years of age. If we discover that a person under eighteen (18) year of age has provided us with personal data, we will remove it from the Site immediately.
- SENSITIVE PERSONAL DATA
Our Services are not allowed to be used to collect or process sensitive personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation as defined in Article 9 of GDPR (“Processing of special categories of personal data”).
- CONTACTING US ABOUT PRIVACY QUESTIONS OR CONCERNS.
Loyalty Communication AS
Willy Thoresens vei 37
General Account or Support
Use of Data and related systems
Exercise your DSRM rights
For any query contact : firstname.lastname@example.org
We have a Data Protection Officer who is responsible for matters relating to privacy and data protection. You can reach the Data Protection Officer at: email@example.com