Privacy Policy for Simcom AS

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Published: a few seconds ago (May 22, 2018)

How to contact us

Simcom AS

Professor Birkelands vei 24C 1081 OSLO
NORWAY
Organization ID911562499
Email privacy@simcom.no
Phone n/a

What does our Privacy Policy cover?

When

Our privacy policy is:

  • effective as of:
    22.05.2018

What and where

Our policy applies to:

  • our app:
    SimCom Flow

Who is responsible for processing your personal data?

Responsibility

We decide why and how your personal data are processed.
We are responsible for processing your personal data.

From whom and how do we collect your personal data?

From whom we collect

We collect your personal data:

  • directly from you:
    Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.

How we collect

We collect your personal data:

  • electronically by

    • storing information on your terminal equipment, or
    • accessing information stored on your terminal equipment, or
    • reading information emitted by your terminal equipment.
      Via use of the SimCom Flow app and cookies from thirdparties, as the Service provided in the SimCom Flow app does not use “cookies” itself. However, the SimCom Flow app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies, in addition to know when a cookie is being sent to your device. If you choose to refuse our cookies, you might not be able to use some parts of our Service.

Voluntary and/or obligatory to provide personal data

When you provide us with your personal data, your provision is:

  • permitted and obligatory.
    You must give us:
    Name, username and telephone number.

Consequence for not providing personal data that are obligatory to give

If you fail to provide us with your personal data and such provision is obligatory, then it can affect you:
You will not be able to use our Service.

Obligatory provision of personal data is:

  • a contractual requirement.

What are our legal grounds for processing your personal data?

Regular and/or "sensitive" personal data

We process your:

  • regular personal data.
    You will not be able to use our Service.

The legal ground for our processing of your regular personal data is:

  • a contract to which you are a party.
    Personal data we process based on this legal ground is:
    All collected and processed information is necessary to provide the Service.

In which situations do we process your personal data?

Whose personal data

We collect personal data:

  • of customers and/or clients.
    All collected and processed information is necessary to provide the Service.

Our role

We are:

  • an enterprise.

Sector

We process your personal data in the:

  • private sector.

Situation

We process your personal data in a situation that concerns:

  • an online activity.
    Handeling of ques and incomming calls.

Do we perform automated decision-making and automated profiling?

No automatic profiling

We do not use your personal data to automatically evaluate aspects of your personality.

No automatic decision-making

We do not use your personal data to automatize decisions about you.

About our processing purposes

Purposes

We process your personal data for the purposes that are described in Section 3.

Our processing purposes are

  • real,
  • present, and
  • legitimate.

New purposes

We do not process your personal data for secondary purposes that are inconsistent with the primary purposes for which your personal data is collected initially,

  • without your prior consent,
  • without a legitimate interest, and
  • without legal ground.

Information about new purposes

We inform you before we process your personal data for secondary purposes

  • if we in the first instance collect your personal data initially for a primary purpose, and
  • if our secondary purpose is inconsistent with the primary purpose.

How long do we keep your personal data?

  • Storage limitation

    We limit the duration we store your personal data to what is necessary for our processing purposes.

  • Storage review

    We continuously review the necessity of our continued storage of your personal data:
    We do frequently delete data that are not necessary for continous availability of our Service.

  • Storage periods

    We delete your personal data within a specified time-limit:
    We delete your personal data when you terminate your account.

Storage required by law

If the further retention of your personal data is necessary for the purposes that are specified by law, we can further retain your personal data.

Do we share your personal data?

Disclosure to recipients

We disclose your personal data to recipients.

The recipients are:
We provide a feature in our SimCom Flow app that implies that other users at your company will be able to see your presence status, in addition to your name and telephone number.

The legal grounds on which we base the disclosure of your personal data to the recipients are:

  • your consent.

Information about future disclosures

If we in the future disclose your personal data to a recipient, then we inform you of

  • the time of the disclosure, and
  • the names of the recipients.

Do we transfer your personal data outside the EU or EEA?

No transfers countries outside the EU and EEA

We do not transfer your personal data

  • to countries outside the EU and EEA, or
  • to an international organization.

Are your personal data secure?

Security

We secure your personal data

  • with appropriate technical measures,
  • with appropriate organisational measures,
  • with an appropriate level of security,
  • against unauthorised processing,
  • against unlawful processing,
  • against accidental or unlawful loss,
  • against accidental or unlawful destruction, and
  • against accidental or unlawful damage.
    We provide a feature in our SimCom Flow app that implies that other users at your company will be able to see your presence status, in addition to your name and telephone number.

What are your rights?

We fulfil your rights that concern the protection of your personal data.

Right to access

You have the right to access your personal data.

If you request that we confirm whether or not we process your personal data, then you have a right that obliges us to confirm that we

  • process your personal data, or
  • do not process your personal data.

Your right to obtain confirmation from us that we process (or do not process) your personal data

  • does not include data that is anonymous.
  • includes the personal data that concern you.
  • does not include personal data that does not concern you.
  • includes pseudonymous data that can be clearly linked to you.

We must give you access to your personal data if

  • you request that we confirm whether or not we process your personal data, and
  • we process your personal data, and
  • you request to access your personal data.

We must provide you with a copy of your personal data if

  • you request that we confirm whether or not we process your personal data , and
  • we process your personal data, and
  • you request a copy of your personal data.

If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs.

You have the right to the information about our safeguards for the transfer of your personal data to a country that is outside the EU and the EEA if

  • you request that we confirm whether or not we process your personal data , and
  • we transfer your personal data to a country that is outside the EU and the EEA.

Right to rectification

You have the right to the rectification of your personal data.

Your right to obtain rectification of personal data that are inaccurate

  • does not include data that is anonymous.
  • includes only the personal data that concern you.
  • includes pseudonymous data that can be clearly linked to you.

We must rectify your personal data if

  • we process your personal data, and
  • your personal data are inaccurate, and
  • you request to obtain the rectification of your personal data.

We must complete your personal data if

  • we process your personal data, and
  • your personal data are incomplete, and
  • you request to obtain the completion of your personal data.

You have the right to provide us with a supplementary statement.

We must communicate the rectification of your personal data to recipients of your personal data (if any).

We do not communicate the rectification of your personal data to recipients of your personal data if the communication to the recipient

  • is impossible, or
  • involves a disproportionate effort.

Right to erasure

You have the right to the erasure of your personal data.

We must erase your personal data without undue delay if

  • you request to obtain the erasure of your personal data, and
  • we process your personal data, and
  • your personal data are not necessary to the purposes for our processing of your personal data.

We must erase your personal data without undue delay if

  • you request to obtain the erasure of your personal data, and
  • we process your personal data, and
  • you withdraw your consent on which we base the processing of your personal data, and
  • another legal ground does not exist for our processing of your personal data.

We must erase your personal data without undue delay if

  • you request to obtain the erasure of your personal data, and
  • we process your personal data, and
  • our processing of your personal data is necessary for the performance of a task that we carry out in the public interest, or
  • our processing of your personal data is necessary in the exercise of an official authority that is vested in us, and
  • our processing is necessary for the purposes of the legitimate interests that we pursue, or
  • our processing is necessary for the purposes of the legitimate interests that a third party pursues, and
  • you object to our processing of your personal data, and
  • our processing of your personal data have a legitimate ground that does not override your objection.

We must erase your personal data without undue delay if

  • you request to obtain the erasure of your personal data, and
  • we process your personal data, and
  • you object to our processing of your personal data for the purposes of direct marketing to you, and
  • our processing of your personal data have a legitimate ground that does not override your objection.

We must erase your personal data without undue delay if

  • you request to obtain the erasure of your personal data, and
  • our processing of your personal data are unlawful.

We must erase your personal data without undue delay if

  • you request to obtain the erasure of your personal data, and
  • the personal data needs to be erased in order to comply with a legal obligation in Union or Member State law.

We must erase your personal data without undue delay if

  • you request to obtain the erasure of your personal data, and
  • your personal data is collected in relation to the offer of information society services.

We must communicate the erasure of your personal data to the recipients to which we disclose the personal data (if any).

We do not communicate the erasure of your personal data to recipients of your personal data if the communication to the recipient

  • is impossible, or
  • involves a disproportionate effort.

Right to restriction

You have the right to obtain from us the restriction of our processing of your personal data.

Your right to obtain restriction of our processing of your personal data

  • does not include data that is anonymous.
  • includes only the personal data that concern you.
  • includes pseudonymous data that can be clearly linked to you.

We must restrict the processing of your personal data for a period to verify the accuracy of your personal data if

  • you request to obtain the restriction of the processing of your personal data, and
  • you contest the accuracy of your personal data.

We must restrict the processing of your personal data if

  • you request to obtain the restriction of the processing of your personal data, and
  • the processing of your personal data are unlawful, and
  • you oppose the erasure of your personal data.

We must restrict the processing of your personal data if

  • you request to obtain the restriction of the processing of your personal data, and
  • we do not need your personal data for the purposes of our processing, and
  • you require your personal data to establish a legal claim, or
  • you require your personal data to exercise a legal claim, or
  • you require your personal data to defend against a legal claim.

We must restrict the processing of your personal data if

  • you request to obtain the restriction of the processing of your personal data, and
  • you object to our processing of your personal data that are necessary for the performance of a task that we carry out in the public interest, or
  • you object to our processing of your personal data that are necessary in the exercise of an official authority that is vested in us, and
  • you object to our processing of your personal data that are necessary for the purposes of the legitimate interests that we pursue, and
  • you wait to verify that our processing of your personal data have a legitimate ground that does not override your objection.

We must communicate the restriction of processing of your personal data to recipients of your personal data (if any).

We do not communicate the restriction of processing of your personal data to recipients of your personal data if the communication to the recipient

  • is impossible, or
  • involves a disproportionate effort.

If we restrict our processing of your personal data, then we can

  • store your personal data,
  • process your personal data on the basis of your consent,
  • process your personal data to establish a legal claim,
  • process your personal data to exercise a legal claim,
  • process your personal data to defend ourselves against a legal claim,
  • process your personal data to protect the rights of a person,
  • process your personal data for the reasons of a public interest of the Union or of a Member State.

If you obtain a restriction of our processing of your personal data, then we must inform you before a lift of the restriction.

Right to object to direct marketing

If we process your personal data for direct marketing purposes, including profiling to the extent that it is related to such direct marketing, then you have the the right to object to our processing of your personal data for such purposes.

Your right to object to our processing of your personal data for direct marketing purposes

  • is a right you have at any time.
  • does not include data that is anonymous.
  • includes the personal data that concern you.
  • does not include personal data that does not concern you.
  • includes pseudonymous data that can be clearly linked to you.

If you object to our processing of your personal data for direct marketing purposes, then we must omit our processing of your personal data for such purposes.

If we process your personal data for direct marketing purposes, including profiling to the extent that it is related to such direct marketing, then

  • we must explicitly bring this right to your attention at the latest at the time of the first communication with you, and
  • we must present this right clearly and separately from any other information.

Right to receive and transmit personal data

You have the right to

  • receive your personal data that you have provided to us, and
  • transmit your personal data (that you have provided to us) from us to another organization without hindrance from us.

These two rights are rights you have if

  • you request to receive your personal data, and
  • we process your personal data by automated means, and
  • we base the processing of your personal data on your consent, or
  • our processing of your personal data are necessary for the performance of a contract to which you are a party, or
  • our processing of your personal data are necessary for the steps that you request before the entry into a contract, and
  • your personal data are provided to us by you, and
  • the transmission of your personal data does not adversely affect the rights and the freedoms of other persons.

You have the right to receive your personal data in a structured, commonly used and machine-readable format.

Your right to receive your personal data

  • does not include data that is anonymous.
  • includes the personal data that concern you.
  • does not include personal data that does not concern you.
  • includes pseudonymous data that can be clearly linked to you.

Your right to receive your personal data

  • includes your personal data that you have provided to us.
  • does not include your personal data that we have received from other sources than you.
  • includes any of your personal data that you actively and knowingly have provided to us.
  • includes your personal data that we observe from your activities.
  • does not include your personal data created by us (by using the personal data you have provided to us or by using the personal data that we observe) such as the outcome of an assessment of you.

Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. This may be the case if a transmission of your personal data to another organization also involves the transmission of the personal data of other (non-consenting) individuals.

Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.

How can you exercise your rights?

Communication about rights

We invite you to communicate with us about the exercise of your rights concerning the protection of your personal data.

Written requests

We only accept written requests since we cannot deal with verbal requests immediately without first

  • analysing the content of the request, and
  • identifying you.

Describe right to exercise

Your request should contain a detailed, accurate description of which right you want to exercise.

Identification document

You must provide us with a copy of an identification document to confirm your identity, for example,

  • an ID card or
  • a passport.

The document should contain:

  • an identification number,
  • country of issue,
  • period of validity,
  • your name,
  • your address, and
  • your date of birth.

Any other data contained in the copy of the identification document such as a photo or any personal characteristics, may be masked out.

We will not accept other means of assuring your identity.

If you wish to propose alternatives, we will assess them on a case-by-case basis.

Our use of the information on your identification document

  • is limited to verify your identity, and
  • will not be stored for longer than needed for this purpose.

Where send request

You can send your request that concerns the protection of your personal data to:

Answer to request

You receive our answer to your request that concerns the protection of your personal data at:

  • your email address.

Person to handle request

We have a person who is responsible for handling of your request that concerns the protection of your personal data.

Policy for handling request

We have policies that ensure that your requests concerning the protection of your personal data are

  • recognized, and
  • handled within the time-limits of the law.

Time to respond to request

We inform you of our handling of your request that we exercise your rights (regarding the protection of your personal) within:

  • a month of the reception of your request.

Do you have a right to complain?

Complain to a supervisory authority

You can lodge a complaint to a supervisory authority

  • at your habitual residence in the EU and the EEA.
  • at the place of your work in the EU and the EEA.
  • at the place of the alleged infringement in the EU and the EEA.

The Supervisory Authority should within a reasonable period inform you of

  • the progress of the complaint, and
  • the outcome of the complaint.

Mandate an organization to complain

You can mandate that an organization lodges a complaint on your behalf with a Supervisory Authority.

The Supervisory Authority should within a reasonable period inform you of

  • the progress of the complaint, and
  • the outcome of the complaint.

Judicial remedy

You can seek a judicial remedy in the EU and the EEA against

  • a controller,
  • a processor, and
  • a Supervisory Authority.

Mandate an organization to exercise your right

You can mandate that an organization exercises your right

  • to a judicial remedy on your behalf.
  • to a compensation for a damage as a result of a breach of the law on the protection of the personal data on your behalf.

Can you choose your privacy settings?

Privacy settings

You can choose why and how we process your personal data at: www.simcom.no

Options

You can choose to:

  • withdraw the consent to the processing of your personal data.
  • access your personal data.
  • edit your personal data.
  • delete your personal data.
  • restrict the processing of your personal data.
  • transmit your personal data.
  • control the actions that we can perform on your personal data.
  • control which personal data that we can process.
  • choose the recipient of your personal data.
  • control the location of our processing of your personal data.

Where

We enable you to choose why and how we process your personal data via our:

  • webform at:
    In the SimCom Flow app.

Will you be informed about our privacy policy changes?

New Privacy Policy

If we change our privacy policy, then we publish a new version of it.

Publication of prior Privacy Policies

You can read the prior versions of our privacy policy at:
simcom.no

Publication of changes to Privacy Policy

You can find further information about the changes to our policy:

  • at our website.

Explanation of words and expressions in this Privacy Policy

Unless otherwise defined this Privacy Policy, all terms used in this Privacy Policy will have the meanings given to them below:

  • Personal data

    Personal data means any information relating to an identified or identifiable natural person (data subject).

    An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as:

    • a name
    • an identification number
    • location data
    • an online identifier
    • the physical identity of a natural person
    • the physiological identity of a natural person
    • the genetic identity of a natural person
    • the mental identity of a natural person
    • the identity of a natural person
    • the economic identity of a natural person
    • the cultural identity of a natural person
    • the social identity of a natural person

  • Processing

    Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as

    • collection
    • recording
    • organisation
    • structuring
    • storage
    • adaptation
    • alteration
    • retrieval
    • consultation
    • use
    • erasure or destruction
    • etc.

  • Processing Purpose

    Processing Purpose means the reason why you process personal data.

  • Third Party

    Third Party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

  • Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.