This privacy notice explains how we process personal data in our business as per the General Data Protection Regulation (GDPR) and other relevant privacy laws applicable to our business.
If you have any questions about this privacy notice, feel free to contact us at:
Company name: Novenco AS
Business address: Karenslyst Allè 11, 0278 Oslo
We take your privacy seriously and we have taken several steps to ensure that we provide you with clear and transparent information on how we process your data, and also inform you about your rights. If you feel that any information is unclear, or missing, please do not hesitate to contact us.
Your data protection rights
- Your rights of access and rectification: You may request access to or a copy of the information we process about you and ask us to rectify any incorrect data.
- Your right to erasure or restriction: In some circumstances, you may ask us to delete and/or restrict our processing of your data, but we cannot delete any data we are required to process.
- Your right to object to processing: In some circumstances, you may ask us to stop processing your data.
- Your right to data portability: In some circumstances, you may ask us to transfer your data to you or to another organisation.
- Also, if you are unhappy about how we process your data, you have a right to complain to a national data authority. We hope, however, that you will contact us first so that we can try to resolve the matter for you in a satisfactory way.
Please contact us if you have any questions about or want to exercise one of your rights. You are entitled to a reply within 30 days.
How we get your personal data
We typically process personal data about:
- Potential customers
- Website visitors
- Job applicants
- Former employees
We process personal data when you:
- buy our products or services
- sign up for our events
- respond to one of our surveys
- provide us with your contact details, e.g. give us your business card
- contact us via phone, text, email, social media or our website
- otherwise use our website
It is voluntary to provide us with personal data, but if you choose not to, we may not be able to provide you with our services. We do not rent, buy or sell personal data from or to others, use automated decisions or profiling in the processing of your personal data or process special category data.
Purpose, lawful basis and retention periods
We only process your personal data when we have a purpose and a lawful basis for doing so. Under the GDPR Article 6-1, the lawful bases we rely on, are:
- Your consent
- We have a contractual obligation (contract)
- We have a legal obligation
- We have a legitimate interest
As a rule, personal data should not be processed and kept for longer than necessary to fulfil the purpose for processing.
Your personal data is only retained for as long as we have a purpose and a lawful basis:
- Until you withdraw your consent (e.g. for email)
- For as long as we have a contractual obligation, and, if applicable, in accordance with accounting and bookkeeping rules and regulations (e.g. for sales)
- For as long as we have a legal obligation; in accordance with accounting and bookkeeping rules and/or other legal requirements and regulations (e.g. for employment)
- For as long as we have a legitimate interest or until you ask us not to process your data in such a way (e.g. marketing to existing customers)
You can always withdraw your consent for any data processing based on consent, and you can also reach out to us at any time if you’d like us to stop processing and/or ask us to delete any of your data.
Details on the processing of your personal data
In this section we describe in detail when and how we process your data, for what purposes and our legal grounds to do so (lawful bases). We also specify the retention periods for the processing.
We process personal data when:
You communicate with us
When you contact us through our website (contact form), e-mail, phone (call, text message), social media and/or give us your business card, we process personal data. Depending on where and how you contact us, this may include your name, contact details, IP address and other information you choose to send to us. We use a customer support system to process personal data on potential and existing customers.
The purpose is to be able to respond to your inquiries and, on some occasions, to keep records in case of complaints or legal claims. The lawful basis is f), where the legitimate interests are to be able to respond to your inquiries and, on some occasions, to keep records in case of complaints or legal claims. We review this data at our annual (internal) GDPR audit day and delete personal data as appropriate. Due to the nature of our business, we can keep this type of personal data up to 5 years, or 10 years if we have a legal obligation in accordance with accounting and bookkeeping rules.
You purchase our products and services
When you purchase products and services from us, we process personal data such as your name, contact details, order and payment details as well as purchase history.
The purpose is to be able to fulfil our obligation to deliver products and services you have purchased and to manage the customer relationship. The lawful bases are b) contract and c) legal obligation related to accounting, tax and other business rules and regulations we are required to abide by.
We process the data for as long as we have a legal obligation as per any applicable rules and regulations we are bound by. E.g. we are required by law to store business records, which could include personal data, for 10 years for accounting, tax and other business purposes. Please contact us if you would like to know what is applicable in your case.
You receive marketing as an existing customer
If we have an existing customer relationship with you as per the Norwegian Marketing Control Act § 15, we can send you marketing via e-mail and text messages. Depending on the medium used to submit such marketing, the personal data we process include your name, email address, IP address and/or phone number. The purpose is to provide you with good customer service and the lawful basis is f), where the legitimate interest is to offer our relevant products and services to provide excellent service to our customers. The lawful basis may also be a), where you have given us your consent to such marketing.
You can easily opt out of the marketing at any time by unsubscribing in any marketing email or text message you receive. We process the data for as long as we have a customer relationship with you, or, if the processing is based on your consent, until you withdraw it. The data will then be deleted at our next GDPR audit day. Please note that it is only personal data related to marketing efforts that will be deleted. We are still required to process data for accountancy, tax and other business purposes if you are our customer.
You apply for a job or work at our company
When applying for a job with us, we process personal data such as your name, contact details, CVs, references, and other relevant information. The purpose is to be able to assess your application. The lawful basis is b) necessary for the performance of a contract.
For employees, we process personal data as mentioned above, in addition to other general employment data (for payroll, insurance, sick leaves etc.). The purpose is to be able to manage the employment relationship. The lawful basis for this is b) contract.
As a rule, employee information is deleted when the employment relationship ends. However, some extraordinary reasons, such as a dismissal or dismissal dispute, may make it necessary to keep employment data for a longer time period. Job applicants can ask us to retain their data for other applications in the future, otherwise the information is deleted when a candidate has been selected, at the latest at our next GDPR audit day.
You attend our events
When you attend our events that are free of charge, we process personal data such as your name, contact details and, sometimes, dietary and/or access requirements. For paid events, we also collect order and payment information. The purpose is to be able to process your registration and attendance, and, if applicable, your payment. The lawful basis is a) consent, or, for paid events, b) contract and c) legal obligation related to accounting, tax and other business rules and regulations we are required to abide by. If we collect any information about dietary and/or access requirements, we also need your consent under GDPR Article 9 (2) (a).
We may also use your data to send you an evaluation of the event you attended, or to invite you to other relevant events we think you might be interested in. The lawful basis is f), where our legitimate interest is to analyse and run our business effectively and to provide you with good customer service. We review this data at our annual GDPR audit day and delete personal data as appropriate, however no later than 10 years following the event.
You respond to our evaluations or surveys
Responding to our evaluations and surveys are voluntary. We process personal data such as your name, contact details and other information you choose to share with us. Some evaluations or surveys may be anonymous, and in such cases, we do not process any personal data.
The purpose is to gather your feedback so that we can continuously improve our products and services, as well as provide you with better customer service in the future. The lawful basis is a) consent. We review this data at our annual GDPR audit day and delete personal data as appropriate, however no later than 3 years after you responded to the survey.
You supply services to or collaborate with us
When you enter into an agreement with us either as a vendor, partner or data processor, we process personal data such as your name, contact details and correspondence. The purpose is to be able to enter into this agreement and to respond to your inquiries and the lawful basis is b) contract. We review this data at our annual GDPR audit day and delete personal data as appropriate, however no later than 10 years after the contract has been terminated. We process other communication data as per the first paragraph in this chapter, please see above.
You use our website
When you use our website, we may process personal data such as IP address and other technical data collected via cookies and analytics tools. The purpose is to run our website and business effectively, promote our products and services and to respond to any inquiries from website visitors. The lawful basis for processing personal data through cookies that are strictly necessary, according to Norwegian laws and regulations. Read more in our Cookie notice. LINK TO COOKIE NOTICE
Whom we share your personal data with
To run our business efficiently and securely, we sometimes will have to share your personal data with other parties such as:
- Public authorities we are obliged to report to
- Our accountant, auditor, lawyer and others helping us in a professional capacity
- Data processors: providers of services that process your personal data on our behalf*
- IT support, if necessary
We require that all such recipients secure data in accordance with good information security. We enter into a data processing agreement/addendum with anyone who processes data on our behalf, as per the requirements in the GDPR Article 28-3.
We use data processors for:
- Email, calendar and digital meetings
- Accounting/bookkeeping and invoicing
- Cloud storage
- Our website
- Business receipts
- Project management, timekeeping, digital notebook and scheduling
- Signing documents electronically
- Surveys and customer satisfaction feedback
To protect our business we don’t publish further details (like names) of our data processors. If you’d like to know more about our processing and whom we share your personal data with, please contact us.
Transfer of personal data outside the EU/EEA
In some cases, your personal data will be transferred outside the EU/EEA, e.g. where we use data processors to manage cloud storage, email services and web hosting.
We only use data processors we trust, that are well known and that we have a data processing agreement/addendum with. We check whether a country outside the EU/EEA offers an adequate level of data protection (has obtained an EU “adequacy decision”) or, if this is not the case, that other necessary safeguards are in place like the EU Standard Contractual Clauses (“SCC”, also called Model Clauses) or Binding Corporate Rules. If you would like to know where your particular data is processed, which safeguards we have for this and what other measures we have taken to protect your data, please contact us.
We take information security seriously and we will always do our utmost to safeguard your personal data in the best possible way. For example, we use strong passwords, data encryption, access control and two-factor authentication to secure our data and prevent unauthorized persons from accessing, altering, deleting, or in any way affecting the data we store, including your personal data.
We only allow others to access and/or process your personal data in accordance with our instructions, and only when strictly necessary (e.g. when we require IT support).
We have implemented a policy for technical and organisational measures and a routine for managing data breaches. If we experience a personal data breach, i.e. a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, and it poses a medium to high risk for the people affected, we will notify the national data authority within 72 hours. If the risk is deemed high for the people affected, we will also notify them directly, if possible.
Please note that this entire document is protected by copyright and you may not copy any text from it.
This privacy notice was last updated: July 2021