Soundcircle AS
Privacy Policy and Cookie Policy
May 25, 2018
Background:
Soundcircle AS understands that your privacy is important to you and that you care about
how your information is used and shared online. We respect and value the privacy of
everyone who visits Our Site and will only collect and use information in ways that are
useful to you and in a manner consistent with your rights and Our obligations under the
law.
This Policy applies to Our use of any and all data collected by us in relation to your use of
Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your
acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and
upon signing up for an account. If you do not accept and agree with this Privacy Policy, you
must stop using Our Site immediately.
1.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account”
means an account required to access and/or use
certain areas and features of Our Site;
“Cookie”
means a small text file placed on your computer or
device by Our Site when you visit certain parts of
Our Site and/or when you use certain features of
Our Site. Details of the Cookies used by Our Site are
set out in section 12, below;]
“Our Site”
subdomains;
“Norwegian and EU
means the relevant parts of the Privacy and
Cookie Law”
Electronic Communications
(EC Directive)
Regulations
2003 as amended in 2004, 2011 and
2015; and]
“We/Us/Our”
means Soundcircle AS, a limited company registered
in Norway under organization number 919400331,
whose registered address is Linneaveien 1A, 1450
Nesoddtangen, Norway.
2.
Information About Us
1.
a limited company registered in Norway under organization number
919400331, whose registered address is Linneaveien 1A, 1450 Nesoddtangen,
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Norway.
2.
We are regulated by The Norwegian Data Protection Authority (Datatilsynet).
3.
Scope - What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. It does not extend to any
websites that are linked to from Our Site (whether We provide those links or
whether they are shared by other users). We have no control over how your data is
collected, stored or used by other websites and We advise you to check the privacy
policies of any such websites before providing any data to them.
4.
What Data Do We Collect?
Some data will be collected automatically by Our Site (for further details, please
see section 12 on Our use of Cookies), other data will only be collected if you
voluntarily submit it and consent to Us using it for the purposes set out in section 5,
for example, when signing up for an Account. Depending upon your use of Our Site,
We may collect some or all of the following data:
1.
Name;
2.
date of birth;
3.
gender;
4.
contact information such as email addresses and telephone numbers;
5.
demographic information such as post code, preferences and interests;
6.
financial information such as credit / debit card numbers;
7.
IP address (automatically collected);
8.
debugging information such as web browser type and version, screen size,
and operating system information (automatically collected);
9.
a list of URLs starting with a referring site, your activity on Our Site, and the
site you exit to (automatically collected);
5.
How Do We Use Your Data?
1.
All personal data is stored securely in accordance with the EU General Data
on security see section 6, below.
2.
We use your data to provide the best possible products and services to you.
This includes:
1.
Providing and managing your Account;
2.
Providing and managing your access to Our Site;
3.
Personalizing and tailoring your experience on Our Site;
4.
Supplying Our products and services to you;
5.
Debugging and fixing issues in our services or Our Site;
6.
Personalizing and tailoring Our products and services for you;
7.
Responding to communications from you;
8.
[Supplying you with email newsletters, account alerts, products
updates, and marketing that you have subscribed to
(you may
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unsubscribe or opt-out at any time by emailing
9.
Market research;
10.
Analyzing your use of Our Site and gathering feedback to enable Us to
continually improve Our Site and your user experience;
3.
In some cases, the collection of data may be a statutory or contractual
requirement, and We will be limited in the [products and] services We can
provide you without your consent for Us to be able to use such data.
4.
With your permission and/or where permitted by law, We may also use your
data for marketing purposes which may include contacting you by email,
telephone, or text message with information, news and offers on our
products AND services. We will not, however, send you any unsolicited
marketing or spam and will take all reasonable steps to ensure that We fully
protect your rights and comply with Our obligations under the GDPR and the
Privacy and Electronic Communications (EC Directive) Regulations 2003, as
amended in 2004, 2011 and 2015.
5.
Under GDPR we will ensure that your personal data is processed lawfully,
fairly, and transparently, without adversely affecting your rights. We will
only process your personal data if at least one of the following basis applies:
a)
you have given consent to the processing of your personal data for one
or more specific purposes;
b)
processing is necessary for the performance of a contract to which you
are a party or in order to take steps at the request of you prior to
entering into a contract;
c)
processing is necessary for compliance with a legal obligation to which
we are subject;
d)
processing is necessary to protect the vital interests of you or of
another natural person;
e)
processing is necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in the
controller; and/or
f)
processing is necessary for the purposes of the legitimate interests
pursued by us or by a third party, except where such interests are
overridden by the fundamental rights and freedoms of the data subject
which require protection of personal data, in particular where the data
subject is a child.
6.
How and Where Do We Store Your Data?
1.
We only keep your data for as long as We need to in order to use it as
described above in section 5, and/or for as long as We have your permission
to keep it. In any event, We will conduct an annual review to ascertain
whether we need to keep your data.
2.
Your data will only be stored within the European Economic Area (“the EEA”)
(The EEA consists of all EU member states, plus Norway, Iceland and
Liechtenstein).
3.
Data security is of great importance to Us, and to protect your data We have
put in place suitable physical, electronic and managerial procedures to
safeguard and secure data collected through Our Site.
4.
Notwithstanding the security measures that We take, it is important to
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remember that the transmission of data via the internet may not be
completely secure and that you are advised to take suitable precautions
when transmitting to Us data via the internet.
7.
Do We Share Your Data?
1.
We may contract with third parties to supply products and services to you on
Our behalf. These may include payment processing, delivery of goods,
search engine facilities, advertising and marketing. In some cases, the third
parties may require access to some or all of your data. Where any of your
data is required for such a purpose, We will take all reasonable steps to
ensure that your data will be handled safely, securely, and in accordance
with your rights, Our obligations, and the obligations of the third party
under the law. We currently contract with no other companies.
2.
We may compile statistics about the use of Our Site including data on
traffic, usage patterns, user numbers, sales and other information. All such
data will be anonymized and will not include any personally identifying
information. We may from time to time share such data with third parties
such as prospective investors, affiliates, partners and advertisers. Data will
only be shared and used within the bounds of the law.
3.
In certain circumstances We may be legally required to share certain data
held by Us, which may include your personal information, for example,
where We are involved in legal proceedings, where We are complying with
the requirements of legislation, a court order, or a governmental authority.
We do not require any further consent from you in order to share your data
in such circumstances and will comply as required with any legally binding
request that is made of Us.
8.
What Happens If Our Business Changes Hands?
1.
We may, from time to time, expand or reduce Our business and this may
involve the sale and/or the transfer of control of all or part of Our business.
Data provided by users will, where it is relevant to any part of Our business
so transferred, be transferred along with that part and the new owner or
newly controlling party will, under the terms of this Privacy Policy, be
permitted to use the data for the purposes for which it was originally
collected by Us.
2.
In the event that any of your data is to be transferred in such a manner, you
will be contacted in advance and informed of the changes. When contacted
you will be given the choice to have your data deleted or withheld from the
new owner or controller.
9.
How Can You Control Your Data?
1.
When you submit information via Our Site, you may be given options to
restrict Our use of your data. We aim to give you strong controls on Our use
of your data (including the ability to opt-out of receiving emails from Us
which you may do by unsubscribing using the links provided in Our emails,
Account).
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10.
Your Right to Withhold Information and Your Right to Withdraw
Information After You Have Given it
1.
You may access certain areas of Our Site without providing any data at all.
However, to use all features and functions available on Our Site you may be
required to submit or allow for the collection of certain data.
2.
You may restrict your internet browser’s use of Cookies. For more
information, see section 12.
3.
You may withdraw your consent for Us to use your personal data as set out in
section in 5 at any time by contacting Us using the details set out in section
15, and We will delete Your data from Our systems.
However, you
acknowledge this may limit Our ability to provide the best possible products
and services to you, and in some cases may prevent us from being able to
provide certain products and services to you.
11.
How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us
(where such data is held). Please contact Us for more details at
12.
What Cookies Do We Use and What For?
1.
Our Site may place and access certain first party Cookies on your computer
or device. First party Cookies are those placed directly by Us and are used
only by Us. We use Cookies to facilitate and improve your experience of Our
Site and to provide and improve Our products and services. For more details,
please refer to section
5, above, and to section
12.6 below. We have
carefully chosen these Cookies and have taken steps to ensure that your
privacy is protected and respected at all times.
2.
By using Our Site you may also receive certain third party Cookies on your
computer or device. Third party Cookies are those placed by websites,
services, and/or parties other than Us. We use third party Cookies on Our
Site for gathering analytics and statistics of the use of our site, in order to
provide better products and services. For more details, please refer to
section 5, above, and to section 12.6 below. These Cookies are not integral
to the functioning of Our Site.
3.
All Cookies used by and on Our Site are used in accordance with current
English and EU Cookie Law.
4.
Before Cookies are placed on your computer or device, subject to section
12.5 and section 12.8, you will be shown a banner requesting your consent
to set those Cookies. By giving your consent to the placing of Cookies you
are enabling Us to provide the best possible experience and service to you.
You may, if you wish, deny consent to the placing of Cookies; however
certain features of Our Site may not function fully or as intended.
5.
Certain features of Our Site depend on Cookies to function. Norwegian and
EU Cookie Law deems these Cookies to be “strictly necessary”. These
Cookies are shown below in section 12.6. Your consent will not be sought to
place these Cookies. You may still block these Cookies by changing your
internet browser’s settings as detailed below in section 12.10, but please be
aware that Our Site may not work as intended if you do so. We have taken
great care to ensure that your privacy is not at risk by allowing them.
6.
The following first party Cookies may be placed on your computer or device:
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Name of Cookie
Purpose
Strictly Necessary
rack.session
This cookie keeps track of your session, or in
Yes
other words allows us to know that
you are you and that you have logged
in to our service.
and the following third party Cookies may be placed on your computer or
device:
Name of Cookie
Provider
Purpose
_ga
Google Analytics
Gathering analytics information
_gat_gtag_UA_35549
Google Analytics
Gathering analytics information
40_4
_gid
Google Analytics
Gathering analytics information
7.
Our Site uses analytics services provided by Google Analytics. Website
analytics refers to a set of tools used to collect and analyze usage statistics,
enabling Us to better understand how people use Our Site. This, in turn,
enables Us to improve Our Site and the products and services offered
through it. You do not have to allow Us to use these Cookies, as detailed
below, however whilst Our use of them does not pose any risk to your
privacy or your safe use of Our Site, it does enable Us to continually improve
Our Site, making it a better and more useful experience for you.
8.
The analytics service(s) used by Our Site use(s) Cookies to gather the
required information. Certain of these Cookies may be placed immediately
when you first visit Our Site and it may not be possible for Us to obtain your
prior consent. You may remove these Cookies and prevent future use of
them by following the steps set out below in section 12.10.
9.
The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie
First / Third
Provider
Purpose
Party
_ga
Third
Google Analytics
Gathering analytics information
_gat_gtag_UA_3554
Third
Google Analytics
Gathering analytics information
940_4
_gid
Third
Google Analytics
Gathering analytics information
10.
You can choose to enable or disable Cookies in your internet browser. Most
internet browsers also enable you to choose whether you wish to disable all
cookies or only third party cookies. By default, most internet browsers
accept Cookies but this can be changed. For further details, please consult
the help menu in your internet browser or the documentation that came
with your device.
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11.
You can choose to delete Cookies at any time however you may lose any
information that enables you to access Our Site more quickly and efficiently
including, but not limited to, login and personalization settings.
12.
It is recommended that you keep your internet browser and operating
system up-to-date and that you consult the help and guidance provided by
the developer of your internet browser and manufacturer of your computer
or device if you are unsure about adjusting your privacy settings.
1.
Summary of Your Rights under GDPR
Under the GDPR, you have:
1. the right to request access to, deletion of or correction of, your personal data
held by Us;
2. the right to complain to a supervisory authority;
3. be informed of what data processing is taking place;
4. the right to restrict processing;
5. the right to data portability;
6. object to processing of your personal data;
7. rights with respect to automated decision-making and profiling (see section 14
below).
To enforce any of the foregoing rights or if you have any other questions about Our Site or
this Privacy Policy, please contact Us using the details set out in section 15 below.
14.
Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated
decision-making and those decisions have a legal (or similarly significant
effect) on You, You have the right to challenge to such decisions under
GDPR, requesting human intervention, expressing their own point of view,
and obtaining an explanation of the decision from Us.
14.2 The right described in section
14.1 does not apply in the following
circumstances:
a)
The decision is necessary for the entry into, or performance of, a
contract between the You and Us;
b)
The decision is authorized by law; or
c)
You have given you explicit consent.
3. Where We use your personal data for profiling purposes, the following shall
apply:
a)
Clear information explaining the profiling will be provided, including
its significance and the likely consequences;
b)
Appropriate mathematical or statistical procedures will be used;
c)
Technical and organisational measures necessary to minimise the risk
of errors and to enable such errors to be easily corrected shall be
implemented; and
d)
All personal data processed for profiling purposes shall be secured in
order to prevent discriminatory effects arising out of profiling.
4. We currently make the following automated decisions:
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[insert if appropriate]
14.5 We currently profile your personal data for the following purposes:
[insert if appropriate]
15.
Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email
Linneaveien 1A, 1450 Nesoddtangen, Norway. Please ensure that your query is clear,
particularly if it is a request for information about the data We hold about you (as under
section 11, above).
16.
Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may
be required by law. Any changes will be immediately posted on Our Site and you will be
deemed to have accepted the terms of the Privacy Policy on your first use of Our Site
following the alterations. We recommend that you check this page regularly to keep up-to-
date.
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