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Smir AS (the “Company”, “we” or “us”), takes all necessary steps to ensure that Personal Data Processed by us regarding our customers and website visitors is Processed lawfully and fairly. This policy (the “Privacy Policy”) explains why and how we Process Personal Data relating to our customers and website visitors. The Privacy Policy explains and clarifies your rights in relation to the Company regarding the Processing of your Personal Data and how you can exercise your rights. The Privacy Policy complies with EU General Data Protection Regulation (EU 2016/679) (the “GDPR”).
CUSTOMERS
By using the Company’s Services you, the customer, acknowledge this Privacy Policy and the Company’s approach to protecting your Personal Data. Therefore, it is important that you read and understand the Privacy Policy before using the Services, as defined below. By using the Company’s Services you, the customer, acknowledge this Privacy Policy and the Company’s approach to protecting your Personal Data. Therefore, it is important that you read and understand the Privacy Policy before using the Services, as defined below.
WEBSITE VISITORS
The Company operates the website www.smir.no. When visiting the Company’s website you, the website visitor, have the choice to accept that we use cookies to enhance your experience when using our website. If you accept cookies, you accept that your personal data is Processed in accordance with this Privacy Policy and the Company’s approach to protecting your personal data. Therefore, it is important that you read and understand the Privacy Policy before accepting the use of cookies and continuing using the website.
1. DEFINITIONS
“Personal Data” means any information relating to an identified or identifiable natural person. Personal Data may include information such as personal and professional contact details, social security numbers, address, payment information, and cookies placed on a device;
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; and
2. PURPOSE AND LEGAL BASIS
Customers
Within the scope of the agreement between the Company and you, the customer, and in order to fulfill our obligations as a provider of the Services, we Process the Personal Data that you have provided to us. The Processing of Personal Data is, in this respect, necessary to provide, operate and improve the Services.
The Company may as well Process your Personal Data if there is a legal obligation to do so, for example in accordance with the Norwegian Book-keeping Act.
Website visitors
Using cookies is necessary for providing and improving your website experience. The legal basis for the Processing is your consent, which you provide to us by actively clicking “I accept” to the question of whether you accept cookies or not.
If you provide us with your contact information through the contact form on our website, we will Process your Personal Data in order to respond to your request.
All
If you have chosen to receive our newsletter or any promotional material from the Company, as set out in section 7 below, we Process your Personal Data, i.e. your contact information, based on your consent, for the purpose of sending you the requested material.
We process your personal data for the following purposes:
To facilitate your use of the website, our services, and products
To contact you as part of the ordinary customer relationship
To send you newsletters or other marketing material, including surveys and event invitations
To provide general customer service and support
To gain customer insights and knowledge of how our various services, including websites, are used as well as evaluation and improvement thereof
To comply with any applicable law
3. STORAGE
The Company takes all reasonable steps to ensure that your personal data is processed and stored securely. Your personal data will never be stored longer than permitted by applicable law or longer than necessary to fulfill the above-stated purposes. Your personal data will be processed by us during the following time periods.
The Company will only store and Process your Personal Data for the following periods of time:
Personal Data that has been provided to us through the contact form on our website
Depending on the character of the specific matter but as a general rule, until the specific matter has been handled. There may be instances in which Smir stores this contact form data for longer periods, specifically to analyze the data and improve our customer support;
Personal Data relating to promotional materials
Until you unsubscribe from this service.
Personal Data for direct marketing purposes
We may process your personal data for direct marketing purposes unless you object to your personal data being used for direct marketing purposes
Personal Data relating to purchases
For as long as the customer relationship lasts, and for five years after that. However, when the customer relationship ends, only your name and information about what purchases and/or what kind of requests you have made will be stored.
Legal obligation
The Company saves any documentation that constitutes accounting information in accordance with applicable accounting legislation.
Consent
In cases where we process your personal data based on your consent, we will only save your personal data for as long as we still have your consent.
3.1. WP Engine, Inc (“WP Engine”)
This website’s hosting services are offered by WP Engine. WP Engine is committed to observing the EU data protection law. The website is secured in the following ways, among others: 24 h surveillance, HTTPS protection, regular updates, and storing collected information in databases protected by firewalls, encryption techniques and limited access control and network access. More information on WP Engine’s terms can be found here: https://wpengine.com/legal/privacy/
3.2. Google LLC (“Google Analytics”)
We use Google Analytics to measure the use of our web services. Google Analytics may place cookies on the user’s device to collect data for example on website’s visitor numbers. More information on Google Analytics’ terms are found here:
https://policies.google.com/privacy/partners?hl=en
4. TRANSFER OF DATA
The Company may transfer Personal Data about its website visitors or customers to a third party. Such transfers may be made to companies within the EU or the EEA (i.e. all EU member states together with Iceland, Norway, and Lichtenstein). Transfers may also be made to Third countries which are recognized by the EU Commission to have an adequate level of protection. For example, Smir may work with certified companies in the United States that comply with legal frameworks that establish an equivalent level of protection with EU law. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list. These third parties are the Company’s service providers or collaboration partners who perform tasks assigned to them on the Company’s behalf.
5. COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
5.1 Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Stripe Payments Europe, Ltd (“Stripe”)
The payment processor, ‘Stripe’, may provide us with unique authentication tokens to make payments requests with. The payment processor ‘Stripe’ may also provide us with information such as your name, credit card type, expiration date, and the last four digits of your credit card number. This information is used only to make single payment requests, or register the user for an ongoing subscription that requires automatic payments in the future. It’s important to note that we do not store any of this payment information or process any of your payments on our servers. Any information regarding your payment processing and security must be verified in Stripe’s own Terms of Service Agreement: https://stripe.com/gb/terms
5.2 Analytical/performance cookies
They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Google LLC (“Google Analytics”)
Smir is using Google Analytics in order to gain further understanding of how the Smir website is used. Data such as pages viewed and time on site is stored in Google Analytics. You can opt-out of having your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on: https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en
Sendinblue
We use Sendinblue to manage our newsletter and other email lists. There’s no third-party tracking in messages we send through Sendinblue besides Sendinblue’s own analytics, which may aggregate how many subscribers open a message or click the links inside. Sendinblue’s privacy policy is available at
https://www.sendinblue.com/legal/privacypolicy/
5.3 Functionality cookies
These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). They are not used to track visitors on sites that are not hosted by Smir.
Examples:
akm_mobile – stores whether a user has chosen to view the mobile version of a site.
botdlang – used to track the language a user has selected
wp_sharing_{id} – used to track whether or not a user has already performed an action.
5.4 Targeting cookies / Third party advertising
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. If you choose not to provide personal data Smir will not be able to personalize advertising targeted towards you in the same way.
Facebook, Inc (“Facebook”)
Smir is using a so-called Facebook pixel to gather information about visitors for marketing purposes. Details about the cookies Facebook use and the data collected can be found in the Facebook Cookie Policy: https://www.facebook.com/policies/cookies/
It is also possible to opt out of all targeted Facebook advertising here: https://www.facebook.com/help/568137493302217
LinkedIn Corporation (“LinkedIn”)
Smir is using a so-called LinkedIn Insight Tag to gather information about visitors to be used for marketing purposes. The LinkedIn Insight Tag creates a unique LinkedIn browser cookie on a visitor’s browser and enables the collection of the following data for that cookie: metadata (such as IP address, timestamp, page events (like page views), and LinkedIn demographic information if there is an active LinkedIn.com member cookie present. For more information see: https://www.linkedin.com/help/linkedin/answer/65521
Google LLC (“Google”)
Smir is using visitor data in order to serve advertisements in the Google network (including AdWords), across the internet. The ads are based on visitor data. Google utilizes cookies in order to be able to serve these ads. Visitors can opt out of Google’s use of cookies by visiting Google’s Ads Settings: http://www.google.com/settings/ads
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
5.5 Blocking cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. You can find out more about blocking cookies in specific browsers at http://aboutcookies.org.
6. COMMUNICATIONS AND PROMOTIONAL MATERIALS
The Company may use your Personal Data in order to communicate necessary information to you in order to fulfill any agreement the Company has concluded with you.
Furthermore, after you have submitted your Personal Data in the newsletter section or the pre-order/order form, we will have the option to contact you with marketing or promotional materials and other information, unless you choose not to receive such materials, by ticking the appropriate checkbox when providing us with your Personal Data in the pre-order/order form. You will also have the option to opt-out or unsubscribe, from receiving marketing or promotional materials at any time, by choosing the “unsubscribe” option in the emails we send you. If you receive any promotional materials by mail, the material will include specific contact information for unsubscribing from this service.
While you have always been able to withdraw previously given consent for our marketing or promotional materials by unsubscribing, you will also be able to request the deletion of your personal data and we’ll make sure your personal data is permanently removed from both our servers as well as from any third party partners.
7. YOUR RIGHTS
You may at any time and free of charge request a transcript of records regarding the Company’s Processed Personal Data regarding yourself. We will then, without undue delay, provide you with an adequate transcript of record.
You may at any time contact the Company in order to have us correct inaccurate or incomplete Personal Data regarding yourself. We will then, without undue delay, correct the information in question.
You may at any time contact the Company in order to withdraw your consent regarding the Company’s right to Process your Personal Data. This will however not affect the lawfulness of the Processing for the time before your consent is withdrawn.
You may at any time request that the Company erase personal data regarding yourself. We will then, without undue delay, permanently remove the Personal Data in question from both our servers as well as from any third party partners if one of the following grounds applies:
the Processed Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise Processed;
you withdraw consent on which the Processing is based and where there is no other legal ground for the Processing (if applicable);
the Processed Personal Data has been unlawfully Processed;
the Processed Personal Data has to be erased for compliance with legal obligations
You may at any time request to obtain from the data controller confirmation as to whether or not personal data concerning you is being processed, where and for what purpose. The Company, as the data controller, shall provide a copy of the personal data, free of charge, in an electronic format.
8. LINKS TO OTHER SITES
Website visitors
Our Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by the Company. Therefore, we strongly advise you to review the privacy policies of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
9. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time and any new version will be published on our website. Thus, we advise you to review this page periodically for any changes. In addition, we will, if you have provided us with your email address, notify you of any material changes by email. The changes are effective immediately after they are posted on this page.
10. COMPLAINTS TO THE DATA PROTECTION AUTHORITY
You have the right to lodge a complaint with the Datatilsynet if you believe that our Processing of Personal Data is in breach with the GDPR.
11. CONTACT INFORMATION
The Company is the data controller of the Personal Data. If you have any questions or suggestions about this Privacy Policy or other potential privacy and data protection issues, do not hesitate to contact us by sending an email to post@smir.no We are just one message away!
Last Updated 12 June 2019
