Introduction

Launch Technology AS will, in connection with our business, process personal data. We are committed to processing personal data in a secure and lawful manner.

Our processing of personal data as the data controller is based on the business we conduct and the purpose of our business. Information about the personal data we process, the legal basis for the processing, the purpose of the processing, how long we process the personal data, etc., is also included below.

We may also process personal data in other ways than mentioned below, but we will inform the individuals concerned in ways other than through this policy.

1. Data Controller Contact Information

Launch Technology AS is the data controller, i.e., determines why and how personal data will be processed for the processing described below.

Contact Information for the Data Controller:
Launch Technology AS
Schleppegrells gate 22, 0556 Oslo
Phone: +47 977 82 599
Email: support@launched.no
Organization number: 933 575 713

2. Processing of Personal Data

We collect and use personal data for various purposes depending on who you are and how we interact with you.

All processing of personal data will comply with applicable data protection laws, including the Personal Data Act and the General Data Protection Regulation (GDPR).

Personal data refers to any information about an individual that can be identified directly or indirectly (the latter is referred to as the "data subject").

Processing of personal data refers to any activity performed with personal data, such as collection, registration, organization, structuring, storage, adaptation, modification, transmission, or deletion.

2.1 Communication and Contact

We process personal data about those who contact us in order to respond and document the communication, and to reach out to others. This applies to all forms of communication, physical and digital, written and oral, including via email or web forms.

In such cases, we process names, phone numbers, email addresses, and any personal data that may be included in the inquiry, including communication history/logs.

The processing of information is based on our legitimate interest in processing personal data related to the above (see GDPR Article 6 (1) f). We have assessed that our legitimate interest in communicating with the outside world is part of our business, and in documenting the business we conduct, as well as responding to inquiries we receive and registering such contact. We have assessed that this is necessary for us to handle the inquiries we receive, and that the privacy of the data subjects does not outweigh these interests.

Providing personal data is voluntary, but it is necessary to provide the information in order for us to respond to inquiries.

We process the information until we expect that there will be no further follow-up on the contact, usually for two years.

2.2 Email

We use email as a communication tool, which may contain personal data. The processing is based on our legitimate interest in processing personal data through email (see GDPR Article 6 (1) f) to have a work tool and communication solution, and that the privacy of the data subjects does not outweigh these interests. What personal data is processed in emails depends on the purpose of the email and its contents. Emails are deleted when they are no longer necessary, and we have measures in place to ensure regular deletion of emails. Our security systems also have access to emails, but only in automated processing.

2.3 Services

We collect and process personal data related to the use of our services. In such cases, we typically collect and process names, contact information, details of what you have purchased/services received, etc. We may also process personal data related to complaints, claims, or other matters related to our services.

The above is processed to fulfill a contract with you, so you can use our services (GDPR Article 6 (1) b).

The data will be processed for as long as necessary to fulfill the contract, in case of complaints and for accounting purposes. The data will therefore be processed for about five years.

In addition, processing may be done based on our legitimate interest in managing the relationship with customers, ensuring and developing the service, protecting our rights, etc., under GDPR Article 6 (1) f. We have assessed that we have a legitimate interest in processing this type of data, and that our interest outweighs the individual's privacy.

Technical logs, security logs on the websites, and in relation to services for security reasons, service development, and statistics will also be processed. Processing of such data is based on our obligation to comply with data protection laws to ensure personal data security, see GDPR Article 6 (1) c, and our obligation to protect your personal data under the agreement with you, as mentioned above.

2.4 Information and Marketing

If you request information or sign up for a newsletter, we will send you information about our products and services, offerings from partners, newsletters, and other information and marketing materials, and we may contact you through other means, such as by phone. We will process your name, email address, phone number, and other information related to the contact.

We process personal data to inform you about services and products that may be of interest to you and process personal data based on your consent (GDPR Article 6 (1) a). You can withdraw your consent at any time by using any unsubscribe options provided in the communication you receive or by opting out of direct marketing and/or profiling under GDPR Article 21 (2) by contacting us.

We only process personal data that allows us to contact you or send information, such as your name, phone number, and email address. The email address is not used for anything other than contacting you.

The processing continues until you either receive the requested information or withdraw your consent. Afterward, your personal data will be deleted.

2.5 Information Distribution

We may also send out information about our services and products that do not contain marketing. This will be done regardless of whether you have given your consent, and personal data will then be processed based on either fulfilling an agreement with you (GDPR Article 6 (1) b) or our legitimate interest in informing our users and contacts about our services (GDPR Article 6 (1) f). Alternatively, we may process the data based on your consent (GDPR Article 6 (1) a). The purpose of the processing is to keep you updated on the products and services you receive and to follow up on the purchase of products or services. The processing of personal data will continue as long as you receive our services.

If processing is based on consent, you can withdraw your consent at any time by using the link in the newsletter or contacting us to stop receiving the information. However, we encourage you to continue receiving the information, as it may affect your use of the service.

2.6 Existing and Potential Customers, Suppliers, and Partners

We process personal data of contact persons with existing and potential customers (in business relationships), suppliers, and other partners for sales and marketing activities, to manage our relationship with suppliers and others, to prepare, carry out, and document services, and to evaluate the use of services. In these cases, we process names, contact information, company names, and information related to the contact with the company in which the individual works.

The processing of personal data is based on our legitimate interest (GDPR Article 6 (1) f) in managing the relationship with our customers, partners, and suppliers, and that our interest outweighs the individual's privacy.

We also store and disclose data where we have a legal obligation, for example, under accounting and tax laws.

We may retain data as long as necessary, for example, to document matters related to services.

In many cases, it will be necessary for us to obtain personal data to enter into agreements with customers and suppliers, including to document that an agreement has been entered into. If we do not obtain the necessary data, we will not be able to enter into agreements.

It is voluntary for contact persons to provide us with personal data. If we collect personal data from others, it will mainly include contact information (including name, address, phone number, and email address), position, function, and employer, as well as potentially competence and references where relevant. The source of such data will be the contact person's employer, for example, from the employer's website. In some cases, we collect references from others to assess the suitability of suppliers and partners.

We store the data until the relationship with the customer, supplier, or partner ends or until the contact person ceases to be a contact person, with the exceptions mentioned above.

2.7 Recruitment

When recruiting for new positions with us, we will process personal data related to CVs, applications, references, interview notes, reference checks, etc.

We may use job search services to manage submitted applications, and this will be our data processor. If you register with the job search service with your profile, the service will be the data controller, and the service's privacy policy will apply to the processing of personal data in the service. Processing of personal data is based on the consent you have given to the job search service (GDPR Article 6 (1) a), if such consent has been obtained, or the legal bases mentioned below.

The basis for processing personal data during recruitment is that processing is necessary to take steps before a potential employment contract with the job applicant is entered into (GDPR Article 6 (1) b).

If we conduct investigations beyond contacting the persons specified as references, such as checking history through searches, personal data will be processed based on our legitimate interest in ensuring that the right candidate is selected for the position (GDPR Article 6 (1) f). For the latter, we have assessed that our legitimate interest in recruiting new employees outweighs the individual's privacy. We encourage you not to include special categories of personal data, such as health, religion, political views, trade union membership, etc., in your application.

If we process special personal data, it will be processed based on your consent (GDPR Article 9 (2) a). Consent can be withdrawn at any time, and withdrawing consent will not affect the lawfulness of the processing of personal data that occurred before consent was withdrawn.

Personal data will be deleted as soon as the recruitment process is completed, unless you have consented to a longer retention period.

2.8 Events

For participants in events, contact information and the specific event the participant will attend will be recorded and processed to identify the participant as registered and to carry out necessary communication and potentially invoice participation fees. The processing of personal data will be based on fulfilling an agreement with the participant (GDPR Article 6 (1) b), or if the participants represent a company, based on our legitimate interest (GDPR Article 6 (1) f) in holding events as part of our business. In the latter case, we have assessed that our legitimate interest outweighs the individual's privacy.

If food and/or beverages are served, we may collect information about preferences, which may indicate health and/or religion based on preferences. This information will only be processed by us and will be deleted immediately after the event. In such cases, the data will be processed based on consent.

2.9 Social Media

We interact with interested parties and others through social media. For example, we have established a Facebook page, where we are responsible for the processing of personal data related to this in collaboration with Facebook. Personal data will be processed through the Facebook page if you post on the page, comment on posts, or "like"/follow the page. Our purpose for processing personal data through Facebook is to interact with you if you wish to communicate with us or otherwise interact with our Facebook page, see also communication under section 2.1 above.

In this context, your name and link to other information you have posted on Facebook associated with your name/account on Facebook will be processed. In addition, everything you share through posts and comments on our Facebook page, as well as the fact that you have "liked"/follow our page, will be processed. What you share on the Facebook page is up to you and is voluntary.

We ask that you do not share personal data in posts or comments on the page, and especially do not share personal data about others, such as by "tagging" or mentioning people.

We process personal data on social media, such as Facebook, based on our legitimate interest in communicating with the public through the social media and will process personal data in this context (GDPR Article 6 (1) f). We have assessed that this is necessary for us to communicate with the public and handle inquiries we receive, and that the privacy of the data subjects does not outweigh these interests.

The data will be processed as long as postings/comments are available on the social media, and you can delete them at any time.

2.10 Use of Websites

On our websites and services, we use cookies, including to collect information to improve the user experience on websites and services, as well as to provide functionality in the services. We also use the information to provide visitors with recommendations and service customizations that are most relevant to them. This will be provided based on the behavior of visitors, such as based on services used, links clicked on, or information read, and based on the behavior of other users with similar usage patterns. In addition, cookies are used to provide personalized marketing on our websites, in advertising networks, and on social media. As far as practical, we attempt to do this with anonymous data, without associating the information with specific visitors.

A cookie is a text file that is placed in your browser's internal memory or a number/code that can identify your browser or device when you visit or interact with a website (referred to as cookies below for simplicity).

You have the option to prevent us from placing cookies in your browser. Many browsers or devices are set to accept cookies automatically, but you can choose to change the settings so that cookies are not accepted. The downside of disabling cookies in your browser is that the websites will not function optimally. The reason is that the purpose of most of the cookies we use is to ensure the functionality of the services.

We also use other tools than cookies to collect information about your IP address, browser type, operating system, date, and time of visit to the website and services. This information is used to analyze trends to make the website and services more user-friendly.
We use the following cookies on the websites:

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Effective Date: 02-Oct-2024
Last Updated: 02-Oct-2024

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We process personal data in accordance with our legitimate interest (GDPR Article 6 (1) f) in adapting the website to our users, and this interest outweighs the privacy rights of the individual. We protect visitors' privacy by only using the data for statistics. In this statistics, it is not possible to identify individuals. The data will be stored as long as necessary for the purposes mentioned above.

3. Processing Based on Consent

If we process personal data based on your consent, as mentioned above, you can withdraw your consent at any time without affecting the lawfulness of processing based on consent before it was withdrawn. Contact us if you wish to withdraw your consent. Please note that even if you withdraw your consent, we may still process all or parts of the data if there is another basis for the processing.

4. Retention and Storage (Deletion) of Personal Data

We retain personal data for as long as necessary for the purpose for which the personal data was collected and delete the data in accordance with legal requirements. How long we retain personal data depends on how the data was collected and the purpose for which it was collected. When we delete data, this is mentioned above where the individual processing is described, or the retention period is based on the following criteria:

• Whether we have a legal or contractual need to retain the data, such as claims against us
• Whether the data is necessary for our business
• Where the processing is based on consent, when consent is withdrawn.

When we no longer have a legitimate need to process your personal data, it will be deleted or anonymized as soon as possible in accordance with applicable law.

Instead of deleting personal data, it may be appropriate in some cases to anonymize the data. Anonymization means that all identifying or potentially identifying features are removed from datasets that are retained.

For example, personal data processed based on your consent will be deleted if you withdraw your consent. Personal data processed to fulfill a contract with you will be deleted when the contract is fulfilled and all obligations under the contract have been met, such as legal obligations related to accounting, follow-up of the customer relationship related to complaints, etc. Personal data processed as a result of a legal obligation will be deleted as soon as we are no longer required to retain the data.

5. Processing of Personal Data as Part of Services

Customers using our services are the data controllers for the personal data processed through the use of the services. If we process personal data on behalf of the customer, we will be the data processor, and a data processing agreement will be in place between us and the customers to regulate our processing of personal data on behalf of the customers.

The information in this privacy policy also applies to our processing of personal data about our customers' customers when it comes to disclosure and transfer of personal data and security/technical matters. For the deletion of personal data, it depends on when our customer chooses to delete the data. We will never use information or data from our services without being instructed or authorized by our customers.

If we are a data processor, you must contact the data controller to exercise your rights. However, we can assist in referring you to the data controller if we have this information.

If we are the data controller, you can find more information about your rights below, and you can contact us to exercise your rights.

Transfer or Disclosure of Personal Data to Others

We do not transfer personal data to others in cases other than those mentioned in this policy, unless there is a legal basis for doing so. Examples of such a basis would typically include an agreement with or consent from the data subject or a legal obligation that requires us to provide the information. The latter applies to public authorities such as tax collection (if necessary), accountants/auditors, and others we need in our business, such as banking institutions.

We use data processors to collect, store, or otherwise process personal data on our behalf. In such cases, we have agreements in place to safeguard your rights and ensure the security of your personal data at all stages of processing.

If required by law or there is suspicion of a legal violation in connection with the use of our services, personal data we have stored about you may be disclosed to public authorities.

If personal data is subject to transfer to another organization as part of a merger, financing, reorganization, or dissolution transaction involving us or part of our business, we will only do so if the parties involved have entered into an agreement that limits the collection, use, and sharing of the personal data to the purposes related to the transaction, including whether the transaction will proceed or not. Personal data will only be used by the parties involved to carry out and complete the transaction. If another company acquires us or our business or assets, that company will have access to the personal data collected by us and will assume the rights and obligations regarding your personal data described in this privacy policy.

7. Transfer of Personal Data to Recipients in Countries Outside the EEA

It is our goal that all processing of personal data should take place within the EEA, but we may use suppliers or process personal data outside the EEA. In such cases, transfers and processing outside the EEA (third countries) will take place in countries approved by the European Commission or in accordance with a valid legal basis for the transfer of personal data under GDPR Chapter V. If the transfer does not take place to countries approved by the European Commission, the transfer will only occur under the guarantees set out in GDPR Article 46 (2). You can request information on the basis used for the transfer by contacting us.

8. Security for the Processing

We prioritize the security of personal data highly in our business and will implement all necessary technical and organizational measures to protect your personal data.

We handle information in a way that ensures it is accurate, available, and handled according to the level of sensitivity of the data. We also use a range of security technologies and information security procedures to protect personal data from unauthorized access, use, or disclosure. Risk assessments are carried out for the processing of personal data.

We have entered into data processing agreements with all our suppliers who process personal data, where they undertake the same level of security as we have for our processing of personal data.

We limit access to personal data to personnel or third parties who will process the data on our behalf. These parties are subject to confidentiality obligations.

Procedures are in place for handling information security breaches and privacy violations (data breaches), and if a breach occurs that poses a risk to the privacy of the data subjects, we will report the breach to the Data Protection Authority as soon as possible, and no later than 72 hours after the breach was discovered. If the breach poses a high risk to the privacy of the data subjects, we will also notify them.

9. Your Rights When We Process Personal Data About You

Below are your rights regarding the processing of personal data. To exercise your rights, you must contact us, see contact information above, or follow the instructions below where applicable.

We will respond to your request as soon as possible and no later than one month. If it takes longer than one month, we will notify you.

We may ask you to confirm your identity or provide additional information before allowing you to exercise your rights with us. This is to ensure that we only give access to your personal data to you – and not to someone pretending to be you.

Your rights below apply where we are the data controller, see above. If we are a data processor for our customers, and you use services from one of our customers, that customer is responsible for the processing of personal data (data controller). You must then contact the service provider to exercise your rights related to the processing of your personal data. Your rights will generally be as described below.

9.1 Information

You have the right to receive information about the personal data we process about you. Through this policy, we inform you about our processing of personal data. You can also contact us if you would like more information.

If we have disclosed data to others, we have an obligation to inform the recipient of requests for correction and deletion of personal data, see section 10.3 below, or restrictions on processing, see section 10.5 below, unless such notification is impossible or involves a disproportionate effort. We are also required to inform you about such disclosures if you request it.

9.2 Access

You have the right to request access to the personal data that is processed about you. Contact us if you wish to access your data.

If you request it, you will also receive a copy of the personal data we process about you. We may ask you to specify which data you would like a copy of to make it easier for us to provide it. When providing a copy of your personal data, we may ask you to identify yourself to ensure that we do not disclose personal data to unauthorized individuals. The data about you will be transferred in digital format unless you request it in another format.

9.3 Correction and Deletion

You can also ask us to correct inaccurate data we have about you or ask us to delete personal data. We will comply with requests to delete personal data as far as possible, but we may not be able to do so if we still need the data.

9.4 Processing Based on Consent

If we process personal data based on your consent, you can withdraw your consent at any time. The easiest way to do this is to use the method indicated when you gave your consent or contact us.

9.5 Right to Restrict or Object to Processing

You can request that our processing of your personal data be restricted in certain cases, if the conditions for this are met. If processing is restricted, the personal data will only be stored. See more details in GDPR Article 21.

Where our processing is based on legitimate interests, you have the right to object to the processing of your personal data. If you object, we will stop the processing unless there are compelling legitimate grounds to continue the processing.

You can also opt-out of processing of personal data related to you for marketing purposes, including profiling to the extent that it is related to direct marketing, see GDPR Article 22 (2).

9.6 Right to Data Portability

For data you have provided to us that is necessary to fulfill a contract with us and is processed automatically (i.e., not manually by us), you can request that the personal data about you be provided or transferred to another provider in a structured, commonly used, and machine-readable format (data portability).

9.7 Automated Processing, Including Profiling

No automated processing, including profiling, will be performed based on your personal data that has legal effects or significantly affects the data subjects. See GDPR Article 22 (1) and (4).

9.8 Right to Be Notified

If a data breach occurs, i.e., a breach of security for personal data that will result in a high risk to your privacy, we will notify you without undue delay.

10. Complaints

If you believe that our processing of personal data does not comply with what we have described here or that we otherwise violate data protection laws, you can complain to the Data Protection Authority. However, we ask that you first contact us so that we can address any incorrect processing as quickly as possible.

You can find information about your rights and how to contact the Data Protection Authority on the Data Protection Authority's website: www.datatilsynet.no.

11. Changes

If there are changes in our processing of personal data or changes in the regulations regarding the processing of personal data, this may result in changes to the information provided here. If there are changes that directly affect you and have an impact on your privacy, we may contact you if we have your contact information. Otherwise, you will always find an updated version of this privacy policy on our website.