Privacy Policy and Guidelines

1. Overview

This privacy policy has been prepared by Fritzøe Nordic. AS to provide you with information about how, why and on what basis we process your personal data. In addition, the privacy policy describes the rights you as a data subject have under the EU General Data Protection Regulation 2016/679 (GDPR) and the Norwegian data protection legislation (together “Data Protection Legislation”).

This privacy policy applies to our processing of personal data in our role as data controller. It is the data controller who is responsible for safeguarding your rights under the Data Protection Act, including your right to be informed about how your information is being processed.

In addition to being a data controller, we also act, as part of our business, as a data processor. This means that we process personal data on behalf of our customers, who in turn are data controllers for the processing we carry out on their behalf. This privacy statement does not cover our processing as a data processor, as it is the other data controller who is responsible for providing you with this information. If you are aware that we process your personal data on behalf of another data controller, please contact them for further information. Further information on our role as a data processor is set out in section 11 below.

2. Contact us

If you have any questions or would like more information about what personal data we process about you, or would like to exercise one of your rights, you can contact us at:

Fritzøe Nordic AS
Sanden 1, 3260 Larvik
Click here for more contact information

3. What is personal data?

Personal data is any information or assessment that can be linked to a natural person or a small group of people (“data subjects”). Examples of what is considered personal data are name, social security number, address, telephone number and email address. Personal data may also include special categories (previously called “sensitive”) personal data, such as, among other things, information about health, religious beliefs, ethnic origin or information about a person’s sexual relations or orientation.

By processing personal data, we mean the collection, storage, compilation, deletion and any other use of personal data.

4. Whose personal data do we process?

This privacy policy covers our processing of personal data about the following categories of persons:
[Private customers (customer as a natural person)]
[Contact persons for corporate customers]
[Contact persons at suppliers and partners]

5. What personal data do we process?

5.1. Fritzøe Nordic online solutions
In connection with our online solutions, including, for example, making websites, online stores and web applications available on behalf of our customers, we process the following personal data:
[Contact information, such as name, address, zip code, county, country, company name, phone number, and email address]
[User information, such as username, user role, and user URL]

5.2. [Customer service – private customers]
[In connection with providing our services to you as a private customer, including in connection with establishing the customer relationship, we process personal data such as:]
[Information about you and your contact information: such as name, address, telephone number and email address.]
[Your customer history, including which [products]/[services] you have purchased, when you purchased them and associated receipts.]
[What [services]/[subscriptions] we provide to you.]
[Payment information: Your bank and/or credit card information used in connection with your payments to us.]

5.3. Corporate customers and suppliers
If you are our contact person, or another employee we have direct contact with, at one of our corporate customers, suppliers or other partners, we may process personal data such as:
Information about you and your contact information: such as name, telephone number, email address, job title and other information about you and your employment relationship that you have provided to us in connection with our collaboration.

5.4. Visiting our website
When you visit our website, we and certain third parties may collect information about how you use our website by using cookies that are stored on your device. Cookies are a data file that is stored on the device you use to visit our website. Fritzøe Nordic uses cookies, among other things, to:
analyze traffic and use of our websites; further develop and improve our services; generate advertisements for marketing initiatives; and provide features that enable interaction with social media platforms.
By using our website you consent to our use of cookies. However, you can block and delete cookies in your browser. If you would like more information about how to block and allow the use of cookies in your browser, you can read more on nettvett.no's website here (external website).
Google Analytics is a web analytics tool that collects data and compiles statistics so that we can improve and develop our websites. All data collected via Google Analytics on our websites is anonymized before being stored by Google.

Please note that by disabling the use of cookies you may experience that our websites do not function optimally.

5.5. Cookies on our websites
We use the following cookies on our websites:

(i) Google Analytics
Fritzøe Nordic uses cookies made available by Google Analytics which records your IP address when you visit our website. The IP address provides information about how the user navigates online, and gives us information about, for example, how many users have visited our website, how much time the user spends on the website, where the user navigates from and which browser the user uses.
IP addresses are considered personal data because the IP address can be traced back to a specific user device (e.g. phone, tablet or PC), and then to a specific user. Fritzøe Nordic uses Google Analytics' tracking code which anonymizes the IP address before the information is stored and processed by Google Analytics. The stored IP address cannot therefore be used to identify an individual.

5.6. Job seekers and recruitment
In connection with recruitment, we will process the personal data you provide to us in connection with the recruitment process, including your name, contact information, study and work experience, current job title, etc. We will also process the names and contact information regarding any references you provide.

6. What is the purpose of the processing of personal data?

We process the personal data specified in section 5.2 above because it is necessary to establish and administer our customer or supplier relationship, for billing purposes and to be able to deliver our services to you or your employer. Payment and other purchase documentation is also processed for purposes related to, among other things, internal reporting and compliance with our accounting obligations.

We process the personal data specified in sections 5.4 and 5.5 in order to market and customize our services to you or your employer.

We process the personal data specified in section 5.6 in order to assess you as a potential employee with us, and to form a sound basis for decision-making in our recruitment processes.

7. What is the basis for our processing of personal data?

If you are a private customer, we process your contact information, payment information and any other case information about you (as further described above), in order to provide our services to you and your affiliated organization. If you are a contact person or other representative of one of our corporate customers, suppliers or other partners, we will process your information because it is necessary for purposes related to our legitimate interests. This legitimate interest is the establishment and administration of our relationship with the business for which you are the contact person.

Any such personal information about you that is included in purchase or other documentation that requires accounting will be processed on the basis of our obligations under accounting legislation.
We process the personal data described in sections 5.4 and 5.5 for purposes related to Fritzøe Nordic's legitimate interests. These legitimate interests are the marketing of Fritzøe Nordic services. We also process this information for marketing purposes to know what relationship you have with Fritzøe Nordics, as well as to be able to improve our services. We consider that these interests outweigh the consideration for your privacy.

We process the personal data described in section 5.6 for purposes related to Fritzøe Nordic's legitimate interests, which is to recruit and employ relevant candidates in our business.
If we have requested your consent to the processing of personal data, you can withdraw this at any time.

8. Disclosure of personal data and use of data processors

We use various service providers to provide IT and other administrative services to us. We have entered into data processing agreements with these service providers that require the relevant companies to ensure that personal data is stored securely, that it does not come into the hands of unauthorized persons, and that it is not used for purposes other than those we designate.

We will not disclose your personal information to parties other than those mentioned above, unless we are legally required to disclose this information.
Meta – provider of digital services
Google – digital services provider

All Fritzøe Energi websites are currently hosted on dedicated servers in Norway. If information is transferred within the EU/EEA, we will ensure that the EU General Data Protection Regulation and country-specific data protection laws are followed. If we transfer personal data to a third party located outside the EEA, we will ensure that the transfer is in accordance with the EU General Data Protection Regulation. If information is transferred to the USA, we will preferably use "Privacy Shield" certified companies.

9. How long do we keep your personal data?

We will delete or anonymize personal data when it is no longer necessary for the purpose for which it was collected, and in accordance with the following deletion routines:

[The personal data associated with your customer profile, including your name and contact information, will be processed as long as we have an active customer relationship with you or your employer. After the customer relationship ends, the data will be deleted after [1] years.]

[Purchase documentation will, depending on the nature of the documentation, be stored for either 3 ½ or 5 years in accordance with the Norwegian Accounting Act.]
[Information about job applicants who are not hired will be deleted after the recruitment process is complete.]

10. What rights do you have?

If we process your personal data, you have a number of rights under the Data Protection Act that you can exercise against us.

You have the right to access the personal data we process about you, including the right to receive a copy of it. If you believe that the information we have registered about you is incorrect, you have the right to request that it be corrected. You have the right to request that your information be deleted from our systems, which we are required to comply with unless further storage is strictly necessary. If you object to our processing of your information, but do not want it to be deleted for the sake of ongoing processes, you can request that the processing be restricted. In such cases, our processing will be limited to only the necessary storage. Where our processing of your information is based on legitimate interests (see point 7 above), you have the right to object to the processing. If you object, we will stop the relevant processing, unless there are compelling legitimate reasons for continuing the processing. Where our processing of your information is based on your consent or our agreement with you, you have the right to have this information provided to you in a structured, commonly used and machine-readable format, either to yourself or directly to another third party.

We would like to point out that there are exceptions and further conditions for the rights described above, and that not all rights will be relevant to all of our relationships. You can read more about your rights on the website of the Norwegian Data Protection Authority, here.

If you wish to exercise any of your rights against us, please contact us as set out in point 2 above. Please note that we may need to ask you to identify yourself, as we may need to ensure that you are who you say you are.

11. Fritzøe Nordic as data processor

The Norwegian Data Protection Authority is responsible for monitoring the data protection regulations and supervising Norwegian companies' processing of personal data. You can contact us at any time if you have any complaints related to our processing of your personal data. You can also complain to the Norwegian Data Protection Authority or a supervisory authority in the EU/EEA country where you live or work, or where the alleged infringement has taken place.

Contact information for the Norwegian Data Protection Authority can be found on their website, here. The website also contains further information about our obligations under the applicable Data Protection Legislation.

The current version of the Privacy Act is available at Lovdata. The Personal Data Act and GDPR can be found here.

12. The Norwegian Data Protection Authority, complaint options and applicable data protection legislation

Fritzøe Nordic AS delivers SaaS systems to business customers and therefore collects statistics and data that are necessary to operate these systems. In addition, we carry out marketing campaigns for customers on various digital platforms. In connection with this part of our business, we act as a data processor, and it is our customers who are the data controllers. Our processing of personal data on behalf of our customers is entirely subject to the restrictions that follow from our data processing agreements with them, and the instructions that the customers have given us for the processing. The services we offer our customers usually involve the processing of personal data in the form of analysis and reporting of collected data for the data controller. If you are affiliated with one of our customers and would like further information about how we process personal data on their behalf, please contact the relevant data controller.

13. Changes

From time to time, we may revise this Privacy Policy, for example as a result of our processing of personal data changing or as a result of changes in the Data Protection Legislation. When the Privacy Policy changes, an updated version will be published on our website. This Privacy Policy is effective from the date stated at the beginning.

Last updated February 14, 2024.