Valid from 01.07.2018
SIKOM is following the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (‘GDPR’).
2. Processing of personal data and purpose
When a User (any person who uses a Service) installs, runs and uses our Services we collect data about the following;
- Information provided by the User:
SIKOM collects the name, email address and phone number of a User
- Location data:
SIKOM uses a mobile device’s location services which, depending on the device and available services, uses a combination of cellular, Wi-Fi and GPS to determine a location.
- Device information:
SIKOM collects information about the device’s operating system, device identifier, sensors, carrier, language, battery performance, Wi-Fi or other network connections and other data that you permit the App to access on your device including through permissions on your device (e.g. Google Play on Android).
- Processing for the purpose of providing a service from SIKOM
SIKOM is processing personal data about the Users of a Service on behalf of our Customers, for the purpose of operating the Service. For the processing for these purposes, SIKOM is regarded as the processor of the personal data on behalf of the Customers. The Customers are regarded as the controllers of the personal data.
- Processing for the purpose of developing/improving a service from SIKOM
From SIKOM’s agreement with the Customer, SIKOM may process personal data about the Users for SIKOM´s own purposes, provided that SIKOM has obtained a freely given consent from the Users. This consent will be obtained electronically when the Users sign up to use a Service.
SIKOM will process the Users’ personal data for various purposes:
- Customer service/support: we may use a Users contact information, device information and usage data in connection with our customer service.
- Product activation: We use data, including device and application type, location, and unique device, application, network and subscription identifiers to activate software and devices that require activation.
- Developing the user experience: data we collect may help us improve our overall user experience.
- Security: We may use information automatically detected by our measurement tools and technical logs, about usage and technical equipment, to ensure that the Services are always working and for maintaining the necessary quality.
- To improve SIKOM’s services: we may use our Users personal information to create a better understanding of who are our users and how they use our services. This data helps us to improve our services to fit better to our users’ needs.
- Marketing and Event Communication: We use personal data to deliver marketing and event communications to you across various platforms, such as email, direct mail, online social media and via our Sites. We also may send you invitations to trade shows or trainings relating to our Products and Services that occur nearby you, based on your address.
Third parties may also market to you on our behalf based on your use of their third-party services, given that you grant permission through your mobile device’s system settings. Once you give permission, the Third Party may use your mobile device’s GPS, Bluetooth or Wi-Fi connections to serve information about SIKOM. You should consult and review the relevant third-party privacy statement or policy for information on their data processing practices.
If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
3. How data is shared
SIKOM’s policy will be to protect the user’s information both online and off-line. Information retrieved or provided to us by using our apps, web pages or through any other communication platforms is restricted to only those employees, contractors or sub-contractors of SIKOM who have valid reasons to access this information to perform any Service you have requested or authorized.
SIKOM will not share your personal data to any other third party, unless:
- User has granted us a permission to do so
- The Service delivered requires such sharing
- Applicable law requires us to share your personal information
SIKOM may share your personal data in the following circumstances to:
- SIKOM controlled contractors or sub-contractors, located both within and outside of your country, including outside the European Union (in this event we will use appropriate legal frameworks to operate data transfers)
- SIKOM controlled Service providers who perform functions on our behalf, located both within and outside of your country, including outside the European Union (in this event we will use appropriate legal frameworks to operate data transfers) for example, sharing payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud/credit risk prevention and reduction.
- SIKOM controlled agents and representatives, located both within and outside of your country, including outside the European Union (in this event we will use appropriate legal frameworks to operate data transfers) who sell or resell products/provide Services on our behalf.
4. Data Security
SIKOM is committed to protecting the security of your personal data. We use commercially reasonable physical and technical safeguards/security controls to secure your data and implement organizational security policies, procedures and employee training.
SIKOM reserves the right to use third party vendors and cloud hosting services. We require those parties to whom we transfer personal data, to comply with the same data security measures. In some cases, we may need to disclose or transfer your personal data within SIKOM or to third parties in areas outside of your home country. When we do this, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.
5. Data Retention
SIKOM retains personal data for as long as is necessary to provide the services you have requested, and for purposes such as compliance with legal obligations. We are required by Law to retain some types of information for certain periods of time such as financial records; personal data will be deleted or anonymized thereafter.
6. User’s rights regarding personal data
Users have choices about the data we collect. When you are asked to provide personal data that is not required for the purposes of providing you with our Products and Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features, Sites, Products, or Services.
SIKOM aims to keep all personal data we hold accurate and up to date. However, If you believe that the information we hold about you is incorrect or out of date, please contact firstname.lastname@example.org
Cookies at our Sites may be used to collect data anonymously. They are used to, unless otherwise specified, collect user statistics and language settings.
Types of cookies used at our Sites, for example sikom.no or sikomliving.com:
__utma: Is stored for 2 years after the last visit.
__utmb: Is stored for 30 minutes after the last visit.
__utmc: Is stored until the browser is closed.
__utmz: Is stored for 6 months after the last visit.
__utmv: Is stored for 2 years after the last visit.
__ga: Is stored for 2 years after the last visit.
When you visit a website, a cookie may be stored in your browser. When you visit other sites, ads from the site you first visited is retrieved and displayed in available ad spaces. These ads are designed to be relevant to your interests and needs. If no cookie is stored in your browser, another ad, which might not be relevant to you, is displayed instead.
The names of cookies used for Google Remarketing may vary between _drt_, FLC and exchange_uid.
The Facebook Pixel may be used to collect anonymous data about the usage patterns and interests of users. Individual users can not be identified by using this data. The purpose of the Facebook Pixel is to provide users with relevant ads and information on Facebook and on other media outside our Sites.
What data is being processed:
At our Sites, data is processed using the methods described above.
The purpose of data processing:
The purpose of processing this data, (except login information), is not to identify you as a user, but to create a better, more intuitive and more relevant experience or all users.
Who processes the data:
Unprocessed cookie data has no value, as they only store a random identification number. Meaningful data can only be retrieved by connecting these numbers in a database for processing. The owners of our Sites, hereby confirm that this data will only be processed following the strictest standards, and that it will only be used for the purposes described above. Identification of individual user will only be required in situations where this is strictly necessary, as when creating an account, logging in or purchasing a product.
General information about cookies:
Cookies are small files that are stored by your browser on your computer or device. Cookies will not be transferred to other browsers on your device. Cookies usually contain four parameters:
– The name of the cookie
– The unique id of the individual cookie (this is tied to your browser)
– How long the cookie will be stored on your device
– The domains that the cookie is applicable for
Because of the last point here, abusing a cookie is very hard. The cookie is only valuable for the intended domain. Attempting to move it to another domain will also remove the value of the cookie information, as one would not have access to the database.
You can turn off cookies:
You can turn off cookies in your browser. However, it is important to be aware that many websites will not function when cookies are disabled. For example, you will not be able to shop at web stores or log in to social media accounts.
Our Sites are not intended for Children. If we learn that we have received any information directly from a Child under age 13 without their parent’s verified consent, we will use that information only to inform the child (or their parents or legal guardians) that they cannot use the Sites, Products or Services.
7. Access to personal data
You have the right to gain access to the personal data we have collected about you, how we process it, purposes, security measures etc.
Data subject access requests regarding processing of personal data for the purpose of providing a Service must be directed directly to the Customers. The Customers will refer the data subject access request to SIKOM.
Data subject access requests regarding processing of personal data for SIKOM’s own purposes should be directed directly to SIKOM. In this case please send a written request to email@example.com
8. How you can withdraw your consent or update, rectify or delete your personal data
You can withdraw your consent or update, rectify or delete your personal data at any time. Please contact us by e-mail firstname.lastname@example.org
10. Contact Information