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Privacy Policy

At Findmy AS, we protect the privacy of our customers and their employees, as well as others (including “the Data Subjects”). In this document, we provide an overview of when, why, and how we process your personal data. We also inform you about your rights in connection with this. This document has been prepared in accordance with privacy regulations, e.g., the General Data Protection Regulation 2016/679 (“GDPR”) and the Norwegian Personal Data Act with regulations. This privacy policy is dated March 27, 2020. If changes occur regarding the processing of your personal data, it may also lead to changes in the information provided here. We will notify you of these changes.

1. Why do we process your personal data?

Processing of personal data about our customers

a) Administration and management of the customer relationship: personal data about our customers and their employees will primarily be used to administer and manage the customer relationship, including communicating with and following up on the customer, carrying out deliveries and otherwise fulfilling agreements with the customer, invoicing the customer, handling any complaints and disputes, and investigating customer satisfaction. Our legal basis for processing your personal data for this purpose is GDPR Article 6(1)(b) (contract).

b) Fulfillment of our legal obligations: in some cases, we are required by law to process your personal data as a customer of ours. This applies, for example, to rules in the Bookkeeping Act and the Accounting Act. Our legal basis for processing your personal data for this purpose is GDPR Article 6(1)(c) (legal obligation).

c) Product and service improvement: information about the customer’s use of our products may also be used in our work with product improvement and service improvement/maintenance and for statistics associated with this. We consider that we have a legitimate interest in processing your personal data for this purpose under GDPR Article 6(1)(f). In the balancing of interests, we have, among other things, taken into account the nature and scope of your personal data, whether you, based on the information we have given you, can reasonably expect your personal data to be reused in connection with our product and service improvement, as well as our need to use your personal data for this purpose.

d) Product development: our product mainly consists of a database that we work constantly to develop based on positioning/location data of animals that our satellite system has tracked over several years. In some individual cases, our satellite system may also capture the animal owner’s (e.g., customers’) location/address. Our legal basis for processing your personal data for this purpose is GDPR Article 6(1)(f) (legitimate interest). In the balancing of interests, we take into account the same factors as mentioned above.

e) Marketing: we may also use personal data about our customers to send out information about offers and marketing material, as well as to assess when it would be appropriate to send out which type of material to the individual customer in accordance with Section 15 of the Marketing Act. Our legal basis for processing your personal data for this purpose is GDPR Article 6(1)(f) (legitimate interest). In the balancing of interests, we take into account the same factors as mentioned above.

Processing of personal data about others

Personal data about others, such as our suppliers and partners, as well as their employees, will primarily be used to administer and manage our relationship with them, including communicating and fulfilling our agreements with them in accordance with GDPR Article 6(1)(b). In some cases, we will also be required by law to process personal data about others, such as our suppliers, in accordance with GDPR Article 6(1)(c). Where we have no established relationship or where we wish to process personal data for purposes other than to fulfill our agreements or legal obligations, we will assess whether we have a legitimate interest in accordance with GDPR Article 6(1)(f) to do so. In the balancing of interests, we will take into account the same factors as mentioned above.

2. What personal data do we process?

In general, we will only process personal data about our customers and others that is necessary to fulfill the purposes mentioned under point 1 above. Specifically, this may mean that we process the following personal data:

a) Contact information, such as address, phone number, and email address – note that the customer’s address may also be captured by the e-bell satellite system that tracks the movements of customers’ animals;

b) Information about the Data Subjects’ employees, such as name, position and role, employer;

c) Financial information where this is relevant to our relationship with the Data Subjects, such as credit card numbers and other card numbers, account numbers for any payments, payment history, any credit checks as long as permitted by law, any use of financing partners, membership in any bonus schemes or associations that provide discounts;

d) History information, such as what has been bought and sold when, etc., shopping patterns and preferences, any information about customer/supplier history with our competitors, contact, meetings, and correspondence between the Data Subjects and our representatives, any complaints and disputes;

We do not process any sensitive personal data about our customers, etc.

3. How do we collect your personal data?

Directly from the Data Subjects: the source of the information we have about the Data Subjects will normally be the Data Subjects themselves, in that they provide information through electronic registration or personal contact, either when the relationship is established or later. Information about the Data Subjects may also be generated through their activity in connection with the relationship, including, for example, when they order or sell products or communicate with us.

From others than the Data Subjects themselves: in certain cases, we may supplement the Data Subjects’ personal data with information from external sources, e.g., in connection with credit checks or where we obtain supplementary information that is publicly available on the internet. We may also obtain lists of potential customers and information about these from market players who offer this, as long as it is permitted by law.

4. Who has access to your personal data with us?

We will limit access to personal data about the Data Subjects to those persons in Findmy who have a professional need for such access based on the purposes mentioned under point 1 above. We may also share this information with our suppliers and their subcontractors where necessary to fulfill the purposes, and in case of special need or by legal order with our advisors, auditors, lawyers, IT consultants, and others. In all cases, we will ensure that your personal data is processed fully in accordance with the individual purposes for which it is shared and that our suppliers and their subcontractors assume responsibility for maintaining necessary security mechanisms to protect your personal data against loss, damage, or similar in accordance with the requirements set out in privacy regulations. Where our suppliers process personal data on our behalf and are by definition considered data processors, we have entered into data processing agreements that meet the requirements of GDPR Article 28. Where we share/transfer your personal data to our suppliers or partners and these operate in countries outside the EU/EEA area, we will ensure that the transfer to this third country is made in accordance with GDPR Chapter 5, i.e., on the basis of a decision by the EU Commission on an adequate level of protection or on the basis of necessary guarantees such as the EU’s “standard contractual clauses”.

5. How and for how long do we store your personal data?

Personal data about the Data Subjects shall only be stored as long as there is a need for it based on the purposes of the processing. Typically, this means that when our relationship with you is ended, we will delete those of your personal data that we no longer need to process without undue delay. In principle, you can ask us at any time to delete information related to you, unless we must store your personal data for a certain period. We consider that we will have a legitimate interest in storing your contact information and history with us for 2 years after the last contact with you, in the event you wish to establish a new relationship with us, based on your previous experiences as a customer, supplier, or partner at Findmy. We also consider that we will be able to store some of your personal data, and particularly your history, as long as it is necessary to safeguard our interests in connection with possible complaints and disputes with you as a customer or supplier, limited to the Limitation Act’s general deadlines of 3 years with any additional deadlines. In addition, in some individual cases, we will have to store some of your personal data for a period of maximum 5 years, when this is required by law under, among other things, the Bookkeeping Act. Personal data we collect in connection with the use of our product is mainly stored electronically with access restriction and password protection to our CRM system and information stored on the servers. For paper-based personal data that is not anonymized, these are stored in lockable cabinets that only those who need access to them to perform their work tasks have access to. The filing cabinets are placed in archives in offices that are kept locked outside ordinary working hours.

6. How do we secure the processing of your personal data?

We have established routines and measures at various levels to ensure that unauthorized persons do not gain access to your personal data and that all other processing of the data takes place in accordance with current legislation. The measures include, among other things, regular risk assessments, technical systems, and physical procedures to safeguard information security and routines to verify access and correction requests. Further information about these risk assessments and security measures can be obtained by contacting us.

7. What are your rights?

As a Data Subject with us, you should be confident that you have received all necessary information about the way we process your personal data. This document should therefore be available to you at all times, and you will find it at the bottom of our website, when you register information about yourself or place orders, or attached to your agreement with us. For those of you who are in contact with us in other ways, you shall be made aware that this information is available at the same time as when we collect your personal data. If you have further questions regarding our processing of your personal data or if you wish to exercise your rights as mentioned below, you can contact us via post@findmy.no. As a Data Subject, you have the right to:

  • gain access to the personal data we process about you
  • demand that incorrect, unnecessary, deficient, or outdated personal data be corrected or removed
  • object to processing for any direct marketing, as well as be informed about any profiling
  • withdraw any consents to process the personal data you have given us
  • receive the personal data about yourself that you have given us and transfer them to another data controller (data portability)
  • contact us if you have input or questions related to our processing of personal data,
  • complain directly to the Data Protection Authority (Datatilsynet) if you consider that the processing of your personal data is in breach of current legislation

It is important to note that you will be able to exercise your rights as long as we are not obliged by law to or have compelling legitimate interests in continuing the processing. In the assessment of interests, we always take into account whether the processing constitutes a privacy disadvantage for you and whether we have a professional need to continue the processing. For example, your right to be forgotten will be limited where we are required under, among other things, the Bookkeeping Act to store your personal data even if the customer relationship is ended. Your right of access will also be limited where it would violate the rights and freedoms of others. In all cases, we will ensure that you receive a reasoned response from us within 1 month following your inquiry, and at the latest 2 months later if your inquiry is complex and requires us to spend extra time and resources on it.

8. How do we use cookies?

Cookies are alphanumeric identifiers that allow our systems to recognize your browser so that we can provide you with easy and efficient use of the various services we offer on our website. This allows the website to remember your actions or preferences over time, as well as remember your login. We place cookies on our website that are either session-based (meaning they are deleted when you leave our site) or that remain on your computer even after you have left the site. We use:

  • necessary cookies, which are essential for the functionality of our website, i.e., storage of user data for authentication and authorization purposes
  • functional cookies, which help recognize you when you return to our website and remember your preferences, e.g., your language settings
  • analytical cookies, which help count the number of visitors, how long the visit lasts, which browsers are used, and which websites users come from, as well as how our website is used in general. Google Analytics is our data processor for analyzing traffic on our website. You are encouraged to read more about how Google Analytics uses analytical cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

We generally do not use marketing cookies that record your behavior on our website and are used to send you tailored advertisements when you visit other websites. Nor do we allow other third parties to place cookies on our website for their own purposes. According to Section 2-7 b of the Electronic Communications Act, we do not need your consent for our use of necessary/functional cookies. Regarding analytical cookies, you are considered to have consented to such use as long as you have not opted out. Your consent is obtained via your browser settings. This is in accordance with the Norwegian cookie regulations enforced by Nkom. You can read more about the use of cookies here https://www.nkom.no/teknisk/taushetsplikt-og-personvern/elektroniske-spor/informasjonskapsler-cookies. If you do not want us to use such cookies, you can manage your browser settings in the following way https://nettvett.no/slik-administrer-du-informasjonskapsler/.