WATS PRIVACY POLICY

 1. DATA CONTROLLER 

On behalf of Virinco AS, the CEO is the data controller for the processing of personal data regarding your use of our websites. 

2. WHAT PERSONAL DATA DO WE COLLECT? 

Our websites offer a variety of services that are collectively referred to as the “Service.” We collect information from individuals who visit our websites (“Visitors”), individuals who register to use the Service (“Customers”) and individuals who are added by Customers to use the Service (“Users”). Depending on the legal basis including the purpose of our processing, we may collect personal data from you either as a Visitor, Customer or as a User as described below: 

a) Personal data about you as a Visitor
As you navigate our websites, we may collect information through the use of commonly used information-gathering tools, such as cookies and web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our websites (such as the web pages viewed, and the links clicked). 

Cookie Consent and Your Choices
When you first visit our website, you will be presented with a cookie banner that allows you to manage your cookie preferences. We require your consent before placing non-essential cookies on your device. You may choose to accept all cookies, reject non-essential cookies, or customize your preferences. You can change or withdraw your consent at any time by accessing the cookie settings, typically available via a link in the footer of our website. Essential cookies, which are necessary for the functioning of the site, will be used regardless of your preferences. 

b) Personal data about you as a Customer
When expressing an interest in obtaining additional information about the Service or registering to use the Service, we require you to provide us with the following contact information about you: 

• Full name
• Company name 
• Address 
• Phone number 
• Company Email address 

(“Required Contact Information” and/or “Billing Information”) 

We may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”).  Required Contact Information, Billing Information, and Optional Information are referred to collectively as “Data About Virinco AS Customers.” 

C) Personal data about you as a User
When added as a User to the Service, Customer add the following contact information about you: 

• Username 
• Full name 
• Email address 

3. HOW DO WE COLLECT YOUR PERSONAL DATA? 

We collect personal data from you when you register on our websites, subscribe to a newsletter, fill out a form, contact us regarding our Service, enter information on our websites or is added as a User. 

 4. FOR WHAT PURPOSES DO WE USE YOUR INFORMATION? 

We may use your personal data for the following purposes: 

• To contact you about your interest in our Service 
• To perform the Service requested by you 
• To send you information about us and our partners for marketing purposes, including information about promotions and events 

In addition, we may use aggregated and anonymized data for the following purposes: 

• To share site-visit information with third-party web service providers. For example, we may share a web session identifier with Google to display relevant advertisements on Google Display Network.  
• To use Web Site Navigational Information to operate and improve our websites, and to provide information about us and our Service to third parties. 

 5. THE LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA 

The processing of data mentioned under section 2 b) above is used to fulfil the agreement with you regarding the provision of our Service. The legal basis of this processing is the General Data Protection Regulation (GDPR) Article 6 (1) (b). 

If you have given your consent to the personal data being used for other purposes described in this privacy policy that are not covered by our agreement, such as marketing emails and the use of certain cookies, cfr. sections 2 a) above and 9 below, then the legal basis of this processing is GDPR Article 6 (1) (a). You may withdraw your consent to such use at any time.  

6. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES 

In order to fulfill our obligations as agreed with you, from time to time we need to share your personal data with our agents, business partners or subcontractors who might process data or contact you on our behalf, or to ensure the quality of information provided. We will ensure that all processing of your personal data is carried out in compliance with applicable laws and regulations, as well as with this privacy policy. 

We do not share, sell, transfer or otherwise disclose personal data to any other third parties unless we are legally obliged to do so. 

 7. ERASURE OF PERSONAL DATA 

Data received or collected in connection with our Service is stored in our active user register as long as is necessary to achieve the purpose of the processing. The data is then deleted or anonymized. Data we are obliged to keep according to the Norwegian Accounting Act (in Norwegian: Bokføringsloven) will be stored for up to 5 years, in accordance with the requirements of the law.  

8. INFORMATION SECURITY 

We use robust security measures to protect your personal data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of personal data. When our Service are accessed using Secure Socket Layer (“SSL”) technology, we protect your personal data using both server authentication and data encryption. These technologies help ensure that your personal data is safe, secure, and only available to you and those you have granted access.  

9. COOKIES AND WEB SITE NAVIGATIONAL INFORMATION 

We use commonly used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate our websites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information we may collect and how we may use this information. 

What is a cookie?
A cookie is a small piece of text sent to your browser by a website you visit. It helps the site remember information about your visit, which can make it easier to visit the site again and make the site more useful to you. 

Why do we use cookies?
We use cookies to make your interactions with our websites easy and meaningful. When you visit one of our websites, our servers, or the servers of our third-party technology providers, send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to a promotional offer, opening an account, or filling out a web form (such as a “Contact Me”), you remain anonymous to us. 

What kind of cookies do we use?
There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. 

If you have chosen to identify yourself to us, we use session cookies containing encrypted information to allow us to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your account is placed on your Web browser. These session cookies allow us to uniquely identify you when you are logged into the Service and to process your online transactions and requests. Session cookies are required to use the Service. 

We use persistent cookies that only we can read and use to identify browsers that have previously visited our websites. When you purchase the Service or provide us with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that we place on your Web browser. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate our websites, but you will not be able to successfully use the Service. 

We may use information from session and persistent cookies in combination with Data About Virinco AS Customers to provide you with information about us and the services. 

Web Beacons
Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. We use Web beacons alone or in conjunction with cookies to compile information about your use of our websites and interaction with emails from us. For example, we may place Web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We use Web beacons to operate and improve our websites and email communications.  

We may use information from Web beacons in combination with Data About Virinco AS Customers to provide you with information about us and the Service. 

IP Addresses
When you visit our websites, we collect your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, we use IP addresses to monitor the regions from which you navigate our websites. 

We also collect IP addresses when you log into the Service as part of our “Identity Confirmation” and “IP Range Restrictions” security features. 

Third-party cookies
From time-to-time, we engage third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit our websites. We may also use other third-party cookies to track the performance of our advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after we receive it. This Privacy Policy does not cover the use of third-party cookies. 

Transparent Pixels
A transparent pixel is an image file that is embedded in an email or web page. When the file is loaded into an email or web client the image is uploaded from a Virinco AS associated server. This enables us to register that an email has been opened. A transparent pixel is the same as any image on an email, this is not strictly required to track an email open; the transparent pixel ensures at least one image is included on every email. 

Note: Users not wanting to be tracked by Virinco AS Transparent pixels can choose not to download images. 

 10. PUBLIC FORUMS, REFER A FRIEND, AND CUSTOMER TESTIMONIALS 

We may provide bulletin boards, blogs, or chat rooms on our web sites. For example through our support service provider zendesk.com. 

Any personal data you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. We are not responsible for the personal data you choose to submit in these forums. 

We post a list of Customers and testimonials on our websites that contain information such as Customer names and titles. We obtain the consent of each Customer prior to posting any information on such a list or posting testimonials. 

11. CUSTOMER DATA 

Virinco AS Customers use the Service to host data and information (“Customer Data”). We will not review, share, distribute, or reference any such Customer Data except as provided in the Master Subscription Agreement, or as may be required by law. Customers are responsible for maintaining the security and confidentiality of their Virinco’s websites usernames and passwords.  

12. THIRD-PARTY WEBSITES AND APPLICATIONS 

This Privacy Policy does not apply to third-party websites and applications. When using such websites or applications, please refer to the privacy policy of such third party. 

 13. WHAT ARE YOUR DATA PROTECTION RIGHTS? 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal data. 

If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us. 

In certain circumstances, you have the following data protection rights: 

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your personal data.

• The right of restriction. You have the right to request that we restrict the processing of your personal data.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal data. 

Please note that we may ask you to verify your identity before responding to such requests. 

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA). 

14. INTERNATIONAL TRANSFERS OF PERSONAL DATA 

Some of our service providers and partners are located in countries outside the European Economic Area (EEA), including the United States. This means that, when you use our websites or services, your personal data may be transferred to, or accessed from, countries that may not provide the same level of data protection as your home country. 

When such transfers occur, we ensure that appropriate safeguards are in place to protect your personal data. These safeguards include the use of Standard Contractual Clauses (SCCs) adopted by the European Commission, which provide lawful mechanisms for international data transfers under the General Data Protection Regulation (GDPR). 

We assess the risks involved in each transfer and implement additional technical, contractual, and organizational measures as necessary to ensure your data is protected. 

By using our services or submitting your personal data, you acknowledge that your data may be transferred to third countries, including the United States, and processed in accordance with this Privacy Policy. 

If you would like more information about the safeguards we apply to international data transfers, you may contact us using the contact details provided in Section 17. 

 15. COMMUNICATIONS PREFERENCES 

We offer Customers and Visitors who provide contact information a means to cancel from email newsletters and other information from us. Either unsubscribe from our newsletter service or send an email to virinco@virinco.com. Customers cannot opt out of receiving transactional emails related to their account with Virinco AS or the Service.  

16. CORRECTING AND UPDATING YOUR INFORMATION 

When using our websites, customers may update or change their registration information either by using applicable forms or email virinco@virinco.com. 

 17. CHANGES TO THIS PRIVACY POLICY 

We reserve the right to change this Privacy Policy. We will provide notification of the material changes to this Privacy Policy through our websites at least thirty (30) business days prior to the change taking effect. 

 18. CONTACTING US 

Questions regarding this Privacy Policy or the information practices of our websites should be addressed as follows:  

Virinco AS
email: virinco@virinco.com
Grønland 1, 3045 Drammen, Norway