Privacy policy

PRIVACY NOTICE AND COOKIE POLICY OF SPUSTOVA AS (“Privacy Notice”)

1.    SCOPE, CONTROLLER, DATA PROTECTION OFFICER, DEFINITIONS 

The present Privacy Notice informs about how and what kinds of personal data of the user (in the following "you") are processed by us, Spustova AS, when you visit our websites.

Spustova AS, org. 927 439 999

Bygdøy allé 17, 0262 Oslo
tel: +47 47-50-00-14
email Data Protection Officer: info@spustova.com
email Data Controller: info@spustova.com

is the data controller pursuant to Article 4 no. 7 EU General Data Protection Regulation (GDPR) for the processing of personal data on our websites according to this Data Protection Regulation.

Personal data means any data relating to you personally such as name, address, email addresses, the information about your use of our websites (see under section 2). Processing means any operation performed on personal data such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.

2.    PROCESSING OF PERSONAL DATA VISITING OUR WEBSITE WHEN OR CONTACT BY EMAIL; PURPOSE AND BASIS

2.1    INFORMATORY USE OF OUR WEBSITES
If the websites are used for information only, i.e. if you do not register or transmit information in any way, we only collect the personal data your browser transmits to our server. If you want to look at our websites, we collect the following data:

  • IP address,
  • date and time of the request,
  • time zone difference to Greenwich Mean Time (GMT),
  • content of the request (specific site),
  • access status/HTTP status code,
  • transferred amount of data,
  • website from which the request is sent,
  • browser,
  • operating system and its user interface,
  • language and version of the browser software and
  • your approximate location data which we derive from the above-mentioned data.

Purpose and basis
The purpose of the processing of this data is to show you our websites and to ensure stability and protection. The basis is Article 6 paragraph 1 sentence 1 point (f) GDPR. According to this the processing of personal data for the purposes of our legitimate interests is lawful except where this is overridden by the interests or fundamental rights and freedoms of the data subject.

2.2    CONTACT BY EMAIL OR USE OF THE CONTACT FORM ON OUR WEBSITE
If you contact us by email or use a contact form, we process

  • your advised request,
  • the company you work for,
  • your gender (salutation),
  • your first and last names,
  • your business contact data (email address, address and telephone number, the indication of your customer number is optional).

The purpose of the processing of this data is to answer your questions. We will delete the data collected in this context when storage is no longer necessary or restrict the processing if there is a legal obligation to retain data. The basis for the processing is GDPR art 6 (1)  b) except where there are legal obligations to retain data. In this case the basis for storage is GDPR art 6 (1) (c); according to this the processing is lawful for compliance with a legal obligation.
Furthermore, you have the possibility to receive regular information from us (newsletter, see below section 2.6 point (c)) irrespective of filling in the contact form and the reply to your request.

2.3    COOKIES

A)    In addition to the previously mentioned data, cookies are stored on your PC when you use our websites. Cookies are small text files which are stored on your hard disk assigned to the browser you use and by means of which the person setting the cookie (here: we) receives certain information. Cookies cannot execute any programs or transfer viruses to your computer. Their purpose is to make the websites more user-friendly and effective. The basis is your explicit consent you give when you start visiting our website and which can be revoked at any time pursuant to Article 6 paragraph 1 sentence 1 point (a) GDPR. or Article 6 paragraph 1 sentence 1 point (f) GDPR.

B)     We use the following types of cookies with the scope and function of which are explained below:

  • transient cookies (see aa)
  • persistent cookies (see bb).

AA)    Transient cookies are automatically deleted when you close the browser. These include in particular session cookies. They store a session ID by means of which several requests from your browser can be assigned to one and the same session. This allows your computer to be recognised when you return to our websites. The session cookies are deleted when you log out or close the browser.

BB)    Persistent cookies are automatically deleted after a time defined by us. This time may vary according to the cookies. You can delete the cookies in the security settings of your browser at any time. With this deletion you also withdraw your consent to process the respective cookie.

C)    You can configure your browser settings according to your wishes and for example reject the acceptance of third-party cookies or all cookies. Please note, that in such a case you may not be able to use all functions of our websites.

2.3.1    GOOGLE ANALYTICS

A)     These websites use Google Analytics, a web analytics service provided by Google LLC ("Google").  Google Analytics uses "cookies", text files stored on your computer making it possible to analyse the way you use the websites. As a rule, the information about your use of these websites generated by means of cookies is transmitted to a Google server in the USA and stored there. If IP anonymisation is activated on these websites, your IP address is shortened beforehand by Google in countries in the European Union or other contracting states of the Agreement on the European Economic Area.  Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. On behalf of the website owner, Google will use this information to evaluate your use of the websites, create reports about website activities and provide further services related to website and internet use to the website owner.

B)    The IP address transferred by your browser in the context of Google Analytics will not be combined with other Google data.

C)    You can prevent the storage of cookies by adjusting your browser settings accordingly; however, we point out that if you do so, you might not be able to use all functions of these websites. Furthermore, you can prevent the recording of data about your use of the websites generated by the cookie (incl. your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at:
https://tools.google.com/dlpage/gaoptout?hl=en.

D)    These websites use Google Analytics with the extension "_anonymizeIp()". IP addresses are then processed in a shortened form; reference to a person can thus be excluded. If a reference to a person is possible by means of the data collected for you, this reference is excluded at once and the personal data is deleted immediately.

E)    We use Google Analytics to analyse the use of our websites to be able to improve them regularly. By means of the statistics we can improve our websites and make them more interesting for you, the user. For exceptional cases in which personal data is transmitted to the USA, Google has committed to adhering to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The basis for the use of Google Analytics is Article 6 paragraph 1 sentence 1 point (f) GDPR.

F)    Information about the third party: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Service: http://www.google.com/analytics/terms/gb.html, overview of data privacy: http://www.google.com/intl/de/analytics/learn/privacy.html, and the Privacy Policy: http://www.google.de/intl/en/policies/privacy.

G)    These websites use Google Analytics also for an analysis of the streams of visitors across all devices made via a user ID. You can deactivate the analysis across all devices in your customer account at "My Account", "Personal data".

2.3.2 GOOGLE TAG MANAGER

This website uses Google Tag Manager. This service makes it possible to manage website tags via a surface. Google Tag Manager only implements tags. This means: No cookies are used, and no personal data is collected. Google Tag Manager activates other tags that might collect data. However, Google Tag Manager does not access this data. If you have selected deactivation at domain or cookie level, it will remain valid for all tracking tags, provided that they have been implemented with Google Tag Manager.

2.3.3 DOUBLECLICK

This website uses DoubleClick. Using the Google service DoubleClick enables us to provide the user with relevant advertisements. For this purpose, cookies are used that can identify the user's browser. This makes it possible to trace back which advertisements were shown and which of them the user has clicked on.

2.3.4 GOOGLE ADWORDS AND GOOGLE CONVERSION TRACKING

This website uses Google AdWords. AdWords is an online advertising service offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

Within the scope of Google AdWords, we use a service called conversion tracking. If you click on an ad delivered by Google, a cookie will be set to enable conversion tracking. Cookies are small text files that the internet browser stores on the user's computer. These cookies will expire after 30 days and are not used to identify the user. If the user visits certain pages of this website and the cookie has not yet expired, Google and we will be able to tell that the user has clicked on the ad and proceeded to that page.

Every Google AdWords client gets a different cookie. The cookies cannot be traced back via the websites of AdWords clients. The information collected by using the conversion cookie is used to prepare conversion statistics for AdWords clients who have decided in favour of conversion tracking. The clients are informed about the overall number of users that have clicked on their ad and proceeded to a page that has a conversion tracking tag. However, they do not receive any information that would make it possible to personally identify the user. If you do not wish to be tracked, you can object to this service by deactivating the Google conversion tracking cookie in the user settings of your internet browser. In this case, you will not be considered in the conversion tracking statistics.

Conversion cookies are stored on the basis of section GDPR art 6 (1) (f). The website owner has a legitimate interest in the analysis of user behavior in order to optimize the website and advertising. You will find more information about Google AdWords and Google conversion tracking in Google's data protection regulation: https://www.google.de/policies/privacy/.

You can set your browser to receive a notification if a cookie is set and only accept cookies in individual cases, prevent them in specific cases or in general and activate automatic deletion of cookies when the browser is closed. Deactivating cookies may restrict the functionality of this website.

2.3.5 GOOGLE ANALYTICS REMARKETING

Our websites use the function of Google Analytics Remarketing in connection with the cross-device functions of Google AdWords and Google DoubleClick. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

This function makes it possible to link the advertisement target groups that are created with Google Analytics Remarketing with the cross-device functions of Google AdWords and Google DoubleClick. This makes it possible that interest-related, personalized advertising messages that were adjusted to you on the basis of your past user and browsing behavior on an end device (e.g. mobile phone) will also be displayed on another of your end devices (e.g. tablet or PC).

If you have given corresponding consent, Google will link your web and app browser history to your Google account. Thereby the same personalized advertising messages can be provided on every end device where you log into your Google account.

To support this function, Google Analytics collects Google-authenticated user IDs that will be temporarily linked to our Google Analytics data in order to define or create target groups for cross-device advertising.

You can permanently object to cross-device remarketing/targeting by deactivating personalised advertising in your Google account. For this purpose, just follow this link: https://www.google.com/settings/ads/onweb/.

The data collected will only be linked to your Google account on the basis of your consent given to Google, which you can revoke (GDPR art 6 (1) (a)). In case of data collection processes that will not be linked to your Google account (e.g. because you do not have a Google account or because you have objected to the linking), the data collection is based on GDPR art 6 (1) (f). The legitimate interest is a result of the fact that the website owner has an interest in an anonymized analysis of the website visitors for advertising purposes.

You will find more information and the data protection regulations in Google's privacy note: https://www.google.com/policies/technologies/ads/.

2.3.6 FACEBOOK WEBSITE CUSTOM AUDIENCES

For our website, we use the "website custom audiences" pixel of the Facebook social network, 1601 South California Avenue, Palo Alto, CA 94304, USA. As a result, so-called tracking pixels are integrated into our pages. When you visit our pages, the tracking pixel will create a direct link between your browser and the Facebook server. Thus, Facebook will receive the information from your browser that our website was accessed from your device. If you are a Facebook user, Facebook can therefore associate your visit to our pages with your user account. Please note that we as the provider of this website are not notified of the content of the data transmitted or of the use thereof by Facebook. We can merely specify the segments of Facebook users (based on criteria such as age, interests) on whose pages we would like our ads to be displayed.  We use one of the two Custom Audiences processes without any data records being transmitted to Facebook, especially no email addresses of our users - neither coded nor uncoded. For more information concerning this topic, please see Facebook’s privacy policy at https://www.facebook.com/about/privacy/.

If you want to object to the use of Facebook Website Custom Audiences, please go to https://www.facebook.com/ads/website_custom_audiences/.

Conversion analysis using the Facebook conversion pixel
We use the conversion pixel or visitor action pixel of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA(“Facebook”). This pixel allows Facebook to see whether a Facebook advertisement has been successful, e.g. has led to an online transaction. For this purpose, Facebook gives us statistical data only, without reference to a specific person. This allows us to analyse the efficiency of Facebook advertisements for statistical and market research purposes. Especially if you have a Facebook account, we refer you to their privacy policy at https://www.facebook.com/about/privacy/.

Please go to www.facebook.com/settings?tab=ads, if you want to withdraw your consent to the use of the conversion pixel.

2.3.7 ADOBE TARGET

We use Adobe's Target software. This software helps us to carry out A/B tests or multivariate tests on the website. The software provides a version differing from the original website (e.g. regarding design and contents). By comparing the two versions, it can be determined which version the visitors of our website prefer. You can find more information about the functions of Adobe Target here: https://www.adobe.com/en/marketing/target.html

With Adobe Target no personal data, e.g. the full IP address, is stored and processed by our website. Only information that does not allow any conclusions about individual persons is processed. The usage behavior is described using quantitative methods. Adobe uses "session cookies" and "permanent cookies". "Session cookies" are only stored temporarily, for as long as you are on our website. "Permanent" cookies are used to retain information about visitors who repeatedly access our website.

Here you can find the Adobe Target privacy policy: https://docs.adobe.com/content/help/en/target/using/implement-target/before-implement/privacy/privacy.html

Opt out: https://www.adobe.com/ca/privacy/opt-out.html

2.3.8 LINKEDIN INSIGHT TAG

We use the LinkedIn Insight Tag from LinkedIn Ireland Unlimited Company, Attn: Legal Dept. (Privacy Policy and User Agreement), Wilton Plaza, Wilton Place, Dublin 2, Ireland. This makes it possible to collect data about visits to our website, including the URL, referrer URL, IP address, device and browser characteristics (user agent) and timestamp. This data is encrypted, the IP addresses are shortened and the LinkedIn IDs of those having a LinkedIn user account are removed within seven days in order to pseudonymize the data. The remaining pseudonymized data is deleted within 90 days. Based on this pseudonymized data, we receive reports on the website's target group and the performance of our advertisements.

Besides, LinkedIn offers the possibility of retargeting via the Insight Tag. Based on this data, we are able to provide targeted advertising to you even outside of our website. For further information about data protection at LinkedIn, please refer to the LinkedIn privacy policy: https://www.linkedin.com/legal/privacy-policy.

The basis is your consent according to GDPR art 6 1 (a). To deactivate the Insight Tag on our website ("opt-out") please click here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out?trk=microsites-frontend_legal_cookie-policy.

2.3.9 INFORMATION ABOUT ACCESS TO THIS WEBSITE BY AKAMAI TECHNOLOGIES, INC.

This website uses provision, security and analytics services by Akamai Technologies, Inc. ("Akamai"). These services use cookies, text files, beacons and browser interfaces which generate log files that enable Akamai to (i) to provide the website quickly, reliably and safely, (ii) carry out analyses of the website performance and the resulting user experience, (iii) carry out safety analyses and (iv) prevent unauthorised access to the website and (v) create reports about (i) to (iv) for their customers. The log files that are generated may include personal data (in the form of IP addresses, activities on the website and evaluations of your use of the website). Akamai may disclose this data to third parties if Akamai are obliged to do so for legal reasons or if these third parties process this data on behalf of Akamai. Akamai may transfer the data to their servers, store it and process it. Most of the Akamai servers are located in the USA. Akamai ensure that the transfer of personal data of EU citizens outside the European Economic Area corresponds to the requirements of the relevant data protection laws.  For this, Akamai have implemented legally recognised transfer mechanisms, e.g. the EU-US and Swiss-US Privacy Shield Framework certification and EU standard contractual clauses. Akamai will not use this data to identify or profile natural persons.

You will find more information about the conditions of use for the processing of personal data by Akamai and the Akamai data protection guidelines at https://www.akamai.com/uk/en/privacy-policies/.

4. REGISTRATION AND NEWSLETTER

A)    If you want to use certain services of our websites, for example the download of data, a registration of the following data concerning you is required:

  • indication if you or the company you work for are an existing Spustova customer,
  • gender (for the salutation),
  • first name, last name,
  • company you work for,
  • your business contact data (email address, address and telephone number, the indication of your customer number is optional).

You have to assign a sufficiently secure password for this data.

B)    We use the double-opt-in procedure for registration. That means that we send an email to the indicated email address after entry of your registration data in which we ask you to confirm your registration data. If you do not confirm your registration, your information is blocked and deleted after the statutory storage period has elapsed (in any case up to the end of the period of limitation for any claims). Furthermore, we store your used IP addresses and the times of entering your registration data and the confirmation. The purpose of the procedure is to evidence your registration and to solve a possible misuse of your personal data, if need be. The basis is Article 6 paragraph 1 sentence 1 point (f) GDPR.

C)    Newsletter
On our websites you can register for our newsletter with current information about our company and our services.


Your consent to receive the newsletter is always freely given. You can withdraw your consent at any time. You can use all other functions of our websites irrespective of your consent to receive the newsletter. This also includes the functions in the context of the registration or the contact form.


After your registration for the newsletter, we carry out the double-opt-in procedure as described above under point (b). If you have also registered for the newsletter during your registration, you confirm by means of the double-opt-in procedure your consent to receive the newsletter.
To send you the newsletter we only process your name, your sex (for the salutation) and your email address so that we can address you personally. The basis for the use of this processing of your personal data is Article 6 paragraph 1 sentence 1 point (a) GDPR. You can withdraw your consent to send you the newsletter at any time and unsubscribe from the newsletter. You can state your withdrawal by sending an email to info@spustova.com.

4.2   ON THE SPUSTOVA WEBSHOP

A)    If you want to place an order in our webshop, a requirement necessary to enter into a contract is that you indicate the personal data asked for which we need to process your order. Mandatory information necessary to process the contracts is marked separately; any other information is given freely. The data you indicate is used by us to process your order. The basis is Article 6 paragraph 1 sentence 1 point (b) GDPR. If you are not our customer but the company you work for, we process your business contact data on the basis of Article 6 paragraph 1 sentence 1point (f) GDPR for the purpose of enabling and facilitating the communication with our customers to execute the contract.

B)    We store the address, payment and order data for as long as we have a legal obligation under relevant trade and tax laws. After the end of the periods of limitation we limit processing, i.e. your data is only used to comply with the legal obligations.

4.3    TECHNICAL CHAT
To use our technical chat we process your email address, the company you work for and your technical questions.


We use this data to process your chat requests or to enable answers by other chat participants and to execute our respective web services; the basis is Article 6 paragraph 1 sentence 1 point (f) GDPR. Your data will only be stored for the period it takes to answer your chat.

4.4    Applicant data

A)    We process the following data of people applying for a job using the application form on our websites or any other means:
first name, last name, email address, address, telephone number (if indicated) and the application documents transmitted to us.

B)    Subject to a separately given consent we only process the data to carry out the application process on which the respective application is based. Without this consent the data will not be stored after the end of the application process and the relevant storage periods.

5.    SOCIAL MEDIA

We operate websites for business purposes at different social media portals. At these portals we are provided with statistical evaluations based on the data collection of the social media portals. We thus partly codetermine the purposes of the data collection so that we are also to be considered as controller in addition to the social media operators.

We use these pages to provide information about our company and our products. The interaction with you as an interested party gives us direct insights into how we and our products are perceived in the market and helps us to improve ourselves and our products. Furthermore, these portals offer quick and easy contact possibilities so that you as an interested party can directly address your questions to us and we can answer them immediately.

The processing of this data is necessary for the purposes of our overriding legitimate interests pursuant to Art. 6 paragraph 1 point f) GDPR.

The data processing via the platforms of the social media operators is done according to the general terms and conditions agreed between you and the platform operators as well as their data protection regulations. We only have limited influence on the data processing of the platform operators. If you do not wish to use the social media channels, you can, of course, contact us and find our information via our own website.

If you wish more information about the data processing of the social media portals, please use the following links:

6.   TRANSFER AND COMMUNICATION OF YOUR DATA TO THIRD PARTIES 

We never transfer your data to third parties without your consent.
We partly use the support of third companies for electronic data processing. They are reliable service providers we have selected very carefully so that they process your data according to our order, cf. GDPR art 28. Our service providers are, of course, committed to handle the data carefully and only according to our instructions and the applicable data-protection regulations, in particular neither to use the data for their own purposes nor to transfer them to third parties.


Furthermore, there may be individual cases in which we are legally obliged to forward your data by order from an official authority if this is required for the purpose of law enforcement or danger prevention by police or other authorities. The basis for transmission in such cases is Article 6 paragraph 1 point (C) GDPR.

Finally, there may be cases in which your data is transmitted to companies associated with Spustova AS according to the company law (subsidiaries or affiliates) for one of the purposes mentioned in section 2 due to the work distribution within the Spustova group of companies.

The purpose of this transmission is to structurally fulfil the tasks arising in the course of pursuit of corporate goals within a group of companies within our group of companies according to our work distribution; the basis is Article 6 paragraph 1 sentence 1 point (f) GDPR.


If in this context personal data is processed outside the countries of the European Economic Area ("EEA"), we protect your personal data by transmitting and processing your personal data within our group of companies only according to the standard data protection clauses defined by the EU Commission following article 46 paragraph 2 point (C). The standard data protection clauses can be viewed and downloaded at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_de.

7.   YOUR RIGHTS

7.1    You have the following rights with regard to the personal data concerning you:

  • the right of information if and which of your personal data is processed by us,
  • right to rectification or erasure of your data,
  • right to restriction of processing,
  • right to object processing if the basis for this processing is article 6 paragraph 1 sentence 1 point (f) GDPR and
  • right to data portability.

7.2    You also have the right to file a complaint with the data protection supervisory authorities (in Norway: Datatilsynet) about the processing of your personal data by us.

8.    AMENDMENT OF THIS PRIVACY NOTICE 

We reserve the right to amend this Privacy Notice at any time with future effect. The current version can be accessed on our websites. Please visit our websites regularly and inform yourself about the provisions on data protection in effect.

Date: February 2024