Privacy Policy

1  Introduction

This privacy notice (“Privacy Notice“) describes how SmartCraft ASA (“SmartCraft“, “we“, or “us“) processes personal data about business associates, candidates for recruitment, recipients of newsletters, visitors of our website and the use of our calculation application and what rights you have in connection with our processing pursuant to the General Data Protection Regulation (the “GDPR“) and national data protection legislation (together “data protection legislation“). “Personal data” means any information relating to an identified or identifiable natural person (a “data subject “).

2  SmartCraft’s responsibility as a controller

SmartCraft processes personal data as a data controller, i.e. we determine the purposes and means of the processing of personal data.

3  Our processing of personal data

3.1  Processing activities and the purpose of the processing activities

The following list includes information about the personal data which we process, and the purposes which the personal data is processed for:

• Business associates. We will process the personal data of representatives and contacts of our business partners, in order to administer our business relationships. We will in this respect process the name, occupation, contact information and place of work of the aforementioned representatives and contacts.
• Candidates for recruitment. We process personal data as part of our recruitment routines. Such personal data may include name, e-mail, address, phone number, photographs, date of birth, CV and application data.
• Recipients of our newsletter. We process personal data in order to provide our newsletter. The only personal data processed is the data subject’s email address.
• Visitors of our website. We use cookies to provide, develop and evaluate services in our digital channels, as well as to provide our visitors with customized communication and marketing.
• Users of the SmartCraft Calculation application. We process personal data that you are required to register in the system. Includes name, e-mail, job title/role and language. We collect data that includes the following points:
  • Which pages are most visited, how long users spend on the pages, and the number of times users have logged into the system.
  • When the user last logged into the system and whether they open/click on emails.
  • Which devices, device types, device versions, operating systems our users use, and which browser/browser version they use.
  • Where in the country users are located and IP addresses.
  • Which buttons and functions users click on.
  • How far users scroll down a page.
  • Which page they last visited and which page they are on.

  Fulfillment of contract: Using your personal data may be necessary to fulfill the agreement you have with us. For example, to communicate with you regarding operational messages, to provide support in cases where you are stuck, to maintain the system, or to respond to inquiries from you.

3.2  The sources we obtain personal data from

Most of the personal data described in above is provided to us by the data subject voluntarily. Personal data may also be obtained through the use of cookies.

3.3  Our legal basis for the processing of personal data

Our processing of personal data is based on the following bases for processing:

• Consent. For example, the use of cookies and subscription of newsletters are based on your explicit consent.
• Legitimate interests. When we process personal data about business associates and candidates for recruitment, we do so based on our legitimate interests, which in our assessment overrides your interests or fundamental rights and freedoms.

SmartCraft Calculation application:

Legitimate interests: We may use your personal data for purposes that are in our legitimate interest. For example, it is in our legitimate interest to perform analyses and improve the system and services and the content on our websites, to send you notifications about software updates or information about SmartCraft Software AS products and services, or to use your personal data for administrative or legal purposes or to detect fraud/hacking.

In cases where we process your personal data based on our legitimate interest without you having an available opt-out mechanism, e.g., in emails we send you, you can enforce your right to object to this by sending an email to electro@smartcraft.com.

4  Do we transfer or disclose data to third parties?

We use the following service providers in connection with the processing of personal data:

• Various suppliers. We may use various suppliers related to accounting, IT and professional services, which processes personal data on our behalf as a data processor. We always conclude data processing agreements with suppliers to ensure that we are in compliance with statutory requirements when we disclose personal data, for example that the data are stored in a secure manner, and that these are not used for any other purposes. We store all personal data on data servers within the EU/EEA.
• Third parties connected to SmartCraft calculation application. We use several third-party providers to perform services such as maintaining the quality system, improving the system, communication and security. We only share your personal data when necessary.
  • The third parties we use are: Microsoft Azure, Mixpanel (measurement and tracking), Hotjar INC (measurement and tracking), Intercom.io (support, communication, and user storage), Facebook (marketing), Google (marketing), Schibsted (marketing).
• Information to and from other sources: We may receive and send information about you from other sources, including third parties such as financial systems that have such integrations with us.
• Other companies in the SmartCraft Group. We may share data with our subsidiaries in the SmartCraft Group.

We will not disclose your personal data to any other third parties than the third parties described above, unless we are required to do so under applicable law, or if it is necessary in order to establish, exercise or defend legal claims.

5  Data retention

We will delete or anonymize personal data when they are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

6  Your data protection rights

As a data subject, you have the following rights in connection with our processing of your personal data:

• Access. You have the right to know which of your personal data we process.
• Rectification. You may ask us to rectify and/or complete inaccurate or incomplete personal data.
• Erasure (the right to be forgotten). You may request that we delete your personal data, a request which we will respect and comply with.
• Restriction of processing. You may ask us to restrict the processing of your personal data.
• Right to object. You may object to the processing of your personal data.
• Data portability. You may ask us to provide you or others with your personal data in a structured, commonly used and machine-readable format.

Please note that there may be limitations regarding your rights and the rights available to you will depend on the particular circumstances of the processing. You may contact us as described below if you wish to invoke your rights. We may request additional information from you, if such information is necessary to confirm your identity.

7  Security

SmartCraft is responsible for the security and confidentiality of the personal data we process. We are furthermore responsible for implementing technical and organizational measures to ensure an appropriate level of security of processing. All of our employees are subject to a duty of confidentiality with regard to your personal data where it is necessary.

SmartCraft calculation application:

SmartCraft Software AS is committed to protecting your personal data. Although we do what is reasonable to protect the personal data we collect, no security systems are impenetrable. We use a variety of technical and organizational measures and industry standards to protect your personal data and prevent your information from being subjected to theft, misuse, unauthorized access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems with limited access located in controlled facilities. Furthermore, we also ensure that our third-party data center providers have adequate security measures in place. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS).

8  Lodging complaints – The Norwegian Data Protection Authority and other supervisory authorities

You may contact us at any time if you have any questions or complaints regarding our processing of your personal data. You may also file a complaint to the Norwegian Data Protection Authority, which is responsible for supervising Norwegian organizations’ processing of personal data, or the data protection authority in the EU/EEA Member State of your habitual residence.

Below is a list of websites where you can find more information and obtain contact details of some of the different data protection authorities that may be relevant to you:

• Norway: datatilsynet.no
• Sweden: imy.se
• Denmark: datatilsynet.dk
• Finland: tietosuoja.fi

9  Changes

We may, from time to time, update this Privacy Notice for example due to changes in our processing activities, applicable data protection legislation or other legislation which may affect our processing of personal data. An updated version of this Privacy Notice will be published on our website if any revisions to the Privacy Notice is made.

10  Contact information

If you have any questions about this Privacy Notice, including how we process personal data, or would like to submit a request to exercise your rights, please contact us at:

SmartCraft ASA
Hvervenmoveien 45, 3511 Hønefoss
gustav.line@smartcraft.com
+47 952 67 104

Last updated: 16 September 2024