Privacy Policy for Cloudberrie AS

1. INTRODUCTION

Cloudberrie AS ("Cloudberrie") is data controller of the personal data we have registered and are processing in connection with your use of our website services and other services.

This privacy policy gives you information about how and what personal data we process, how we process your personal data, to whom the data is disclosed and what rights you have.

This privacy policy is updated when needed, and the latest version is published here.

This privacy policy was updated on May 6 2022.

2. WHOSE PERSONAL DATA DOES CLOUDBERRIE PROCESS?

Cloudberrie receives, collects, stores, and otherwise processes personal data of customers, potential customers and other users of our services, including also our website and social media services (collectively "Data Subjects").

3. WHAT PERSONAL DATA DOES CLOUDBERRIE PROCESS?

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

Cloudberrie processes a range of personal data about Data Subjects, including:

  • Name and contact information, such as email address, phone number, employer name and address and job title/position

  • Other personal data necessary for maintaining and managing the customer relationship during the whole lifecycle of the relationship, such as billing information, feedback, other message history and marketing preferences etc.

  • Information related to account registration, such as username, email and organization name

  • Other information about subscriptions, such as validity period, last login time, and number of active sessions

  • Electronic identification and behaviour data such as cookie data and IP address. Our cookie policy is described further in clause 9.

Personal data processed by Cloudberrie is mainly collected directly from the Data Subjects, or through our customers having a direct relationship with the Data Subject (such as employment). In addition, the personal data may also be collected automatically when the Data Subject uses products developed on our software and other services e.g., when using our online services (including social media) and visiting our website.

We do not collect or process sensitive personal data (personal data of special categories).

4. WHAT DOES CLOUDBERRIE USE THE PERSONAL DATA FOR?

We process personal data of Data Subjects to offer services and to maintain our relationship with our customers. In this context, personal data may be processed for the following purposes:

  • Registration and delivery of our products

  • Subscription and providing of our services

  • Product and service development

  • Invoicing, recalls, warranties, customer service, feedback, and related communications

  • Management and administration of our relationship with our customers, including information purposes

  • Provision of information and materials related to our products and services, for example by newsletters and direct marketing

  • Identifying potential customers who are using our services for the purposes of targeting relevant marketing to such persons

  • Registrations for our events and webinars

  • Market and customer analysis and surveys

  • Contacting the Data Subject and to provide information on the services

  • Complying and fulfilling our legal duties and obligations such as tax law, accounting, and product liability related obligations

  • Ensuring security of our products and services and preventing abuses

  • Ensuring security of our IT environments and protection of data

  • Presenting legal claims and/or responding to and defending against legal claims

We process personal data on the following legal bases cf. the GDPR article 6 (1):

  • When it is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.

  • When the Data Subject has given consent to the processing of his or her personal data for one or more of the specific purposes.

  • When it is necessary for compliance with a legal obligation to which we are subject (such as corporate and accounting).

  • When it is necessary for the purposes of our legitimate interest to inform you about our products and services, to deliver, develop and maintain our products and provide and develop our services, ask you for feedback, or provide you other relevant marketing information about our products and services and to maintain the customer relationship. In this respect, processing of personal data is related to the customer relationship. Where we rely on legitimate interests as a legal basis for processing personal data, we have considered whether or not those interests are overridden by the rights and freedoms of the Data Subjects and have concluded that they are not.

5. WHO DOES CLOUDBERRIE SHARE THE PERSONAL DATA WITH?

For the purposes stated in this Privacy Policy, personal data is disclosed, when necessary, to authorities, and accessed by our third-party service providers and contractors (such as our IT vendors, resellers, and service companies and marketing agencies conducting marketing on our behalf etc.). In such case, the personal data will only be disclosed for purposes defined above. We do not sell or otherwise disclose personal data to third parties for such third parties’ own purposes.

We use data processors that assist us in different processes. List of the processors and other recipients can be provided upon request.

In addition, we may share the personal data in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business and in connection with other similar arrangements.

6. DOES CLOUDBERRIE TRANSFER PERSONAL DATA TO COUNTRIES OUTSIDE THE EU/EEA?

Personal data may be transferred regularly outside the EU or the EEA to our service providers. In case personal data is transferred outside EU/EEA, such transfers are either made to a country that is deemed to provide a sufficient level of privacy protection by the European Commission or by using a valid transfer basis such as the EU Standard Contractual Clauses. If necessary, we will implement appropriate safeguards to ensure that the personal data has the same level of protection as in the EU/EEA.

7. HOW LONG DOES CLOUDBERRIE STORE THE PERSONAL DATA?

Personal data collected in connection with our services shall be retained as long as needed for the purposes defined in this Privacy Policy unless such data is replaced through regular updates or otherwise.

Personal data may be, in whole or partly, retained for longer or shorter period if required by applicable law (such as for accounting, tax law and product liability related obligations) or if there is some other justified reason for us to retain or delete the personal data. In such a case, once the reason to retain the personal data ceases to exist, the Data Subject’s personal data shall be erased without delay.

We evaluate the necessity and accuracy of the personal data on a regular basis and endeavour to ensure that the incorrect and unnecessary personal data are corrected or deleted.

8. HOW DOES CLOUDBERRIE PROTECT THE PERSONAL DATA?

Securing the integrity and confidentiality of personal data is important to Cloudberrie. We have taken adequate technical and organizational measures in order to keep personal data safe and to secure it against unauthorized access, loss, misuse or alteration by third parties, such as by encryption, access controls and firewalls.

Nevertheless, considering the cyber threats in modern day online environment, we cannot give full guarantees that our security measures will prevent illegally and maliciously operating third parties from obtaining access to personal data or absolute security of the personal data during its transmission or storage on our systems.

In case of any data breaches, we will notify the Data Protection Authority and the affected Data Subjects to the extent required under the GDPR.

9. USE OF COOKIES

A cookie is a small file downloaded to your computer. It enables our website to identify your computer as you view different pages on our website.

Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.

The cookies we are using are gathered through various service providers. Third party cookie providers will also be able to gather and use data gather by their cookies. We have no direct control over the information that is collected by these third-party cookies. For further information about cookie usage by third party provider, please check the provider’s cookie and privacy policies.

When you visit our website for the first time, our cookie banner will provide you with options for accepting or rejecting cookies. By accepting, you give a consent to the use of cookies. You can control and disable use of cookies by adjusting the settings on your browser. You can, for example, disable use of cookies, allow use of all cookies or only use of first party cookies. Furthermore, you can set the browser to delete cookies after each browser session or delete them manually. Please note that disabling use of cookies may downgrade or break certain elements of the site’s functionality and certain functions may not work in the usual way.

We may use cookies to collect:

  • User’s IP-address

  • Visited pages and time spent on page (analytics and performance)

  • Browser type and info about operating system of a device

  • Referral website and exit website after the session

  • Information provided by you (subscription or contact form)

  • Social media sharing information

  • Openings and clicks of marketing emails

We use different types of cookies in order to collect the aforementioned. In some special cases we also use cookies provided by trusted third parties. The following section details what kind of first- and third-party cookies you might encounter through this site.

Strictly necessary cookies These cookies are essential for our websites and services to perform their basic functions. Without these cookies, some parts of our site and services just won’t work as they should.

Functional cookies In order to provide you with better experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page that is affected by your preferences.

Performance and analytics cookies Performance cookies collect information on how you interact with our websites and how our website performs. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you. Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. All information these cookies collect are anonymous.

Targeting (marketing) cookies We use cookies or similar technologies from third party analytics providers, which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites, or other products.

In addition, we use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work, social media sites will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies. Some of these cookies may be set when a page is loaded, or when you take a particular action like clicking a social media sharing button.

We may also obtain information from our email newsletters or other communications we send to you, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters’ effectiveness and helps us ensure that we’re delivering information that you find interesting.

10. YOUR RIGHTS

Under applicable data protection laws, Data Subjects have numerous rights related to the personal data. You may have the right to:

  • Access the processed personal data.

  • Obtain the rectification of inaccurate personal data.

  • Obtain the erasure of personal data. However, please note that certain personal data is strictly necessary in order to achieve the purposes defined in this Privacy Policy and may also be required to be retained by applicable laws. Thus, you may not delete such personal data.

  • Obtain restriction of processing.

  • Receive the personal data, which you have provided to Cloudberrie, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Cloudberrie.

  • Object to the processing of your data where Cloudberrie is relying on its legitimate interests as the legal ground for processing. For example, you may object to your personal data being used for marketing purposes at any time.

  • Ask Cloudberrie to restrict processing personal data for a period if data is inaccurate or there is a dispute about whether or not your interests override Cloudberrie’s legitimate grounds for processing data

  • The right to withdraw any consent given by you.

Data Subject may exercise the aforementioned rights by sending a written request to dataprotection@cloudberrie.io.

If you believe that Cloudberrie has not complied with applicable data protection laws when processing your personal data, you can lodge a complaint with a supervisory authority. In Norway, the relevant supervisory authority is Datatilsynet.

11. CONTACT INFORMATION

We are available for questions you might have at dataprotection@cloudberrie.io.