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Last Updated: 20.05.19
Venue / Organization
We shall be open and clear on how we process your personal information. Personal information about you will only be processed for legitimate purposes and will be deleted or anonymized when we no longer have a basis for processing it. You will receive information regarding your privacy rights and how to enforce them. We will continue to develop services and solutions with privacy incorporated in their design.
When you use our software, our website, or other digital services we provide (hereinafter referred to collectively as: “the Services”), we collect, process and store your personal information. It is important for us to safeguard and protect these personal data in the best possible way to maintain their confidentiality. With this PP, we will inform you about how we process your personal information, as well.
It will only be processed for legitimate purposes and will be deleted, pseudonymized or anonymized when our basis for processing and retention is no longer present.
You will receive information about your privacy rights and information on how to exercise those rights. This information will be provided to you in this PP, via e-mail, or on our login pages, etc. You can control and manage our treatment of your data on "My Profile," which is created for you when you, as a customer, guest and/or user, utilize the Services.
Simp and Venue / Organization, are so-called common "Data Controllers" for processing your personal information in accordance with this PP. This means that both are responsible for defining the purposes of the treatment of your data, as well as for complying with applicable privacy laws.
If you have questions related to this PP or the treatment of your personal information through the provision of the Services and our communications with you, please contact Simp AS. Our company and contact information are as follows:
SIMP AS is a Norwegian company registered in the Brønnøysund Register Center with organization number: 816 202 612 NO VAT.
Øvre Ole Bulls Plass 1
5012 Bergen, Norway
Telephone: (+47) 404 81 404
2. The Scope of this PS
This PP applies to our collection, use, and processing of personal information in connection with the Services. We collect, use and process personal information when you use the Services as a customer / user or potential customer / user with us. This includes use of the WiFi service, the websites, any applications, or other services we provide, as well as when communications by phone, email, social media or the like.
In this PP, we explain how we treat personal information, what kind of personal information the processing involves, and what purposes it serves. This outlines, among other things, how we collect, use and possibly disclose or share personal information when you, as a guest, customer and / or user, use the Services and / or communicate with us in the ways described here. It explains what information we process, as well as how and why, and the legal basis for treatment. We also explain when and why personal information may be disclosed or shared with others. We also inform you about the rights you have in connection with the processing and any transfer of your personal information.
This PS shall, when not otherwise specified, be interpreted in accordance with Norwegian law and be subject to Norwegian courts' non-exclusive competence.
3. Our Processing of Personal Data
When ordering and / or using the WiFi service as a customer, guest, user or visitor, or using other services, you may be asked to confirm that you are a customer / guest. We may ask you to provide information such as name, phone number, email address, and, in some cases, other contact and identification information. You may also share with us or give access to similar information via your profile with another service provider.
By using the Services, such as our WiFi service, we record these data about you. This information will form the basis of a customer / user profile for managing your customer / user relationship and for communication with you. When you choose to use the Services by logging in through third parties, names, contact details and other relevant information may be transferred between such third parties and us. The purpose is to simplify your use and login, to safeguard your security, including identifying who is using the Services and providing you with relevant information and marketing, and for analysis purposes (see more below).
We will not knowingly collect or request personal information from children under the age of 15, in addition to the information required to log in and use the service. We will not knowingly allow such persons to consent to the processing of personal data with us. We have therefore asked guests / users who are under the age of 15 to inform us of by ticking a separate field for this when logging on to the Services. If we become aware that we have obtained personal information from a child under the age of 15, this information will be removed immediately. If you believe that we hold, or might hold, information regarding a child under the age of 15, please contact us at email@example.com to have it removed.
The information you provide and which we register is used to improve and simplify the use of the Services, including the next time you use them as a customer, guest, or user. In this context, we will process contact information provided by you, as well as other information necessary to manage the service and the customer / user relationship. This may include information and identification of the device you use (mobile, tablet, PC, etc…). We do this for the sake of safety (including to identify and verify you and your device), ease of use, improved service, and for more customized communications.
If you do not want to provide personal information to us or access to it, we may not provide the Service you request or provide you with the user service and information we and our affiliates offer, in some cases.
The customer and user profile will give you access to My Profile, which includes account administration tools. Here, you can change the way we process your personal information, including deleting or accessing the information we process. You can also get an overview of our treatment and your rights, as well as choose how we and our partners will communicate with you. We describe this in greater detail below.
4. Compilation of Information
We also process your personal information to keep you informed about technical issues with the services, as well as to provide service and relevant tips and marketing, while you as a customer, guest and / or user use the Services, or after your stay / use. This may include sending you information and reminders on SMS or email / text messages (such as technical error information on the services), providing relevant information for your use or your visit, including notification of any good offers or tips that might be of interest.
When you choose to use the Services, depending on your previous use of Services, we may aggregate the information in your customer and user profile to facilitate and target the use of service, management and communication with you. This makes it easier for you to use the Services and helps you get more relevant information. For example, this may include your contact and device information, selected browser language, browser type, and your login information / history. Such a treatment will also enable us and our partners to provide you with more relevant information and service on email and other channels.
6. Personalization of Profile
We can also process your information by compiling the information in your customer / user profile and your visit history using the Services. This will enable us to provide you with even more relevant and targeted service, information, and marketing via email and other channels. This will increase usability and make our communication with you more customized and relevant to your preferences, desires and needs. In this way, we avoid sharing information with you that you are not interested in.
At all times, you will be able to reserve yourself against or protest against our treatment in the form of compiling information stored on your customer and user profile. If desired, you can easily modify or delete all or part of your profile. You will find more information about your rights later in this PP, as well as on My Profile and in our communications with you.
7. Other Treatment
The information, in particular name, address, e-mail address and technical information, may be provided to our affiliates and service providers to safeguard your security, for analysis purposes, and to provide you with the Services and relevant information you require.
If you choose to link the Services with third party services, such as linking to a social network or a specific application, we will process the information necessary to integrate our services with that party's services, marketing, as well as to review and implement measures in case of breach of agreement. We encourage you to review this third-party privacy statement to review how they process your personal information.
In order to fulfill our statutory obligations or to protect and defend ourselves from any legal claims or lawsuits, we may, under certain conditions provide information to local or international authorities or a court. For this purpose, the information we process or parts of it may include name, address, email address, IP address, other personal and technical information.
The information you have provided as a customer, guest and / or user in connection with the use of the Services, or which we have collected in that connection, may, if necessary to protect and defend us against any legal requirements or lawsuits, be stored for a longer period than normally needed. The information will not be stored, however, longer than ten years after the user / customer relationship has ceased.
8. Customer Support, Security, and Technical Maintenance
We provide user / customer support to assist you if you have technical problems or want assistance with logging in or accessing the Services. On our website, you will be able to contact us by phone or email. To provide you with such support, we will process personal information to identify you and assist you as best we can. This may require the processing of personal data such as name, contact information, unit information, etc... To maintain our service level, we may be able to perform analysis and data testing on the Services and our sites when an error occurs or when changes are made to our system. This makes it possible to eliminate technical errors in our systems and ensure that the Services work properly. This work may include the processing of personal data where necessary.
We also prepare reports and statistics by analyzing the information you have provided us such as names, contact details, and the technical information we collect about your use and your devices. The purpose is to improve our service and give you a better user experience the next time you use our services. If we detect irregular activities using the Services, we will take the necessary action. This may include the processing of personal data. The information you have provided to use the Services can be stored for 10 years until we no longer need them to protect and defend ourselves against legal claims / lawsuits etc…
We want to help you make the most of our local knowledge, tips and offers. We will send customized and relevant offers and activities via e-mail / sms, or both during your visit to us / during your use of the Services and afterwards. For this purpose, we will process your email address and phone number, your personalized profile, device information, and attendance history for tips, promotions, and offers.
To improve our communications with you, we perform market analysis. This can be accomplished by linking different data sets that may contain personal information. Personal data in analytical data sets will be anonymised and always deleted after the analysis has been completed.
You will be able to manage your consent to this treatment when you start using the Services or at any time later on My Profile. Here you can delete personal information used for tips and marketing by deleting your profile on My Profile or checking My Profile that you do not want to receive such tips or marketing. In this connection, user cookies will also be deleted (see more about this later in this Privacy Statement).
10. Delivery of Personal Data
We may disclose personal information to our authorized service providers and partners. Otherwise, we may only disclose your personal information in the following cases:
- with third parties, when parts of the Services you use or choose to give us access to include services provided by a third party;
- or with public authorities or agencies when required by law, court order or enforceable decision of the authorities.
We can also share aggregated data with our business partners, suppliers and group companies for various purposes, e.g. to improve our service or for system administration, statistics, research and analysis.
11. Legal Basis
The legal basis for the processing of personal data as described in this section may be to administer a contractual relationship based on your acceptance of our Customer / User Terms when you, as a Customer, Guest and / or User, use the Services. It may also be within our legitimate interests in managing and running our business, where it weighs heavier than your privacy. In that case, we have made a specific interest weighing on your need for protection against both of our interests in the treatment. Furthermore, the basis in certain cases may be based on the fact that it is necessary for us to fulfill our statutory obligations or pursue a legal claim, etc., as described above. If no other legal basis exists, our treatment will be based on your consent. In that case, it will be possible for you to withdraw such consent when you do not want us to process your information further in accordance with the consent that has been given.
12. More about Cookies and Similar Technologies
When you use the Services and visit websites in connection with this use, we collect certain information using cookies. Cookies are small text files that are stored on your device when you visit a site. This PP regulates how we use this information when we link it to personal information.
When you visit a site for the first time, a cookie file is sent to your device. This file can identify your browser. Using cookies helps you to improve the functionality of our website. They are important for reducing download time and improving user experience. We use, among other things, cookies for authentication purposes, so you don't necessarily need to identify yourself each time you use the Services or visit our sites. These cookies are necessary for the service to function satisfactorily. By adjusting the technical settings of your browser, you can prevent cookies from being stored and available on your device. please note that if you disable cookies, you may not be able to use our Services, Sites, or Applications, however.
Note that you can control how your devices can share location information with us and how the browser handles cookies and related technologies by adjusting the privacy and security settings of your devices and applications / applications. See the instructions from your browser provider or device manufacturer or applications to learn how to adjust your settings.
13. Your Rights
The personal data will be stored in accordance with the provisions of the various points in this PP. You can manage at any time, including deleting your profile and your user information on My Profile.
You have the right to protest certain types of treatment or to request a restriction on the treatment that we do. You also have the right to request access, correction, limitation and deletion of any personal data we process and to receive a copy of the personal information we hold about you. If our treatment is based on your consent, you can call back this consent so that the treatment will cease. If we process information because we have a legitimate interest in doing so (as explained above), you also have the right to oppose this. These rights may be limited in certain situations - for example, if we can demonstrate that we are required by law to process information or it is necessary to pursue a legal claim we believe to have.
On My Profile, you can at any time be able to update, correct or delete information you have provided to us and adjust the communication with us. Inquiries regarding the processing of personal data and requests for access and limitation shall be addressed to our contact point stated below.
Exceptionally, if we ask for personal information to comply with regulations or contract / usage terms and obligations, such information is required. If such information is not provided, we will not be able to manage the customer / user / contractual relationship or fulfill the requirements and obligations we are imposed.
14. Data Storage and Security
We have implemented technical and organizational security measures to secure your personal information. We work continuously to ensure that your personal information is protected from loss, destruction, corruption or unauthorized access. We have a security framework that is updated regularly in line with technological developments. Data are stored on our own secure servers in accordance with local regulations. If a customer, guest and / or user does not interact with the Services for a period of 24 months, your and our legitimate interests will be deemed to be no longer relevant and you will be automatically unsubscribed from our communications based on this processing basis. If a customer, guest and / or user does not interact with the Services for a period of 60 months, personal information will be anonymized, encrypted or deleted.
The service and services through third-party integrations such as Facebook, Google, use different types of information for logging in, for example, by phone number or email, where a password is sent. Everyone has their own responsibility for user safety and passwords. A customer, guest and / or user should inform us immediately if one suspects that the Services have been misused. It is important to note that we will never ask for the user's password by phone or email.
15. Transfer of Personal Data
We may transfer aggregated data to our authorized third parties (domestic and / or foreign) to improve or develop our Services or to ensure that the Services and the Equipment otherwise operate satisfactorily. Transfer of personal data to a third country outside the EEA that does not provide adequate protection will not occur.
16. Changes to this Statement
We reserve the right, without notice, to update or modify this PP to account for any change in our Services and business models, as well as any new or other privacy practices or practices. An updated PP will be available on the Services and Websites. We ask you to keep up-to-date with the applicable PP. These changes take effect on the "last updated" date in the revised edition. A customer, guest, and / or user accepts the revised version at any time by continuing to use the Services. If you do not accept the changes, you must stop using the Services or, if necessary, adjust or delete your information on My Profile.
Last updated: 20. februar 2019
Historical: PP 20.05.18