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Privacy Policy

Stratema AS

1. INTRODUCTION
Stratema is committed to protecting and respecting your privacy during your relationship with us. 

This Privacy Policy explains how Stratema processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of its website and digital services: What Personal Data and Special Categories of Personal Data we collect from you and about you, how it will be used, and your individual rights. We will only Process your Data as permitted by applicable law.

2. DEFINITIONS THAT WILL HELP YOU UNDERSTAND THIS PRIVACY POLICY
 

Defined Term

Meaning

 

Data

Any Personal Data, and where relevant, any Special Categories of Personal Data.

Personal Data

Any information relating to an identified or identifiable natural person; an identifiable person is one who can either be directly identified from the data or indirectly identified, e.g. if that information can be connected with other information.

 

Data Subject

 

An identified or identifiable natural person whom the data is about.

Processing

Any handling of a Data Subject’s Personal Data including (but not limited to) the collection, storage, organising, disclosure, use and destruction of that Data.

 

Special Categories of Personal Data

Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; Data concerning health or sex life and sexual orientation and; genetic data or biometric data.

 

GDPR

 

The General Data Protection Regulation, which regulates the processing by an individual, a company or an organisation of personal data relating to individuals in the EU/EEC, cf. the Personal Data Act section 1.



3. WHAT DATA DO WE PROCESS ABOUT YOU?

The purpose of the processing

Type of Personal Data

How is Personal Data obtained?

Introductory analysis

Your personal details and contact details – name, company, power of attorney, position, work tasks, telephone number, and/or email address.

By assessing documents from the Brønnøysund Register Centre; official documents, annual accounts, company websites and open information sources.

Providing news letters

Name, company, phone number and/or email address.

Stratema’s Website.

Giving advices and other consulting services

 

Your personal details and contact details – name, company, power of attorney, position, work tasks, telephone number, and/or email address.

Regular correspondence and rcontact as part of our client agreements.

Adjusting the website settings

Geographical location and IP address

Cookies on the website.

Recruitment

Your personal details and contact details – name, company, telephone number, email address, and personal details provided via your CV and job application

Job applications.


We do not Process Special Categories of your personal data.

We do not currently use automated decision making (when an electronic system uses personal data to make a decision without human intervention). 

4. HOW LONG DO WE PROCESS YOUR DATA?
 
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.  Where we determine that there is no longer any need or requirement to retain your Data, we will no longer Process that Data and your Data will be deleted in accordance with our Privacy Policy and applicable laws.  If you want to receive more information about our data processing practices, we can be reached at the contact details set out in this Privacy Policy’s Section 9.


5. WHAT LEGAL BASIS DO WE HAVE FOR OUR PROCESSING?

Introductory analyses

Processing is necessary for the legitimate interests of Stratema, cf. GDPR article 6.1 (f). The legitimate interest is to find new business projects, get new customers and expand commercial activities. In our view, this does not represent a risk for your rights and freedoms. We have made individual assessments of the processing in relation to the different purposes.

Giving advices and other consulting services  

Under this purpose, there are two sub-purposes:

Strategic advice on business streamlining and the preparation of presentations
Assisting with assessments, advices and procedures concerning transfer of undertakings, mergers and acquisitions

Processing is necessary for the legitimate interests of Stratema, cf. GDPR article 6.1 (f). The legitimate interests are performing consultant advices and processing information that is necessary for the performance of a contract to which a customer is party. This makes our business model possible. We consider this to be in the client’s interest as well, as it maximizes the client’s profit and synergetic effects.

In our view, this does not represent a risk for your rights and freedoms. We have made individual assessments of the processing in relation to the different purposes.

Providing news letters

GDPR article 6.1 (a); i.e. that the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

Cookies

Please see Section 8 in this Privacy Policy.

Recruitment

Processing is necessary for the legitimate interests of Stratema, cf. GDPR article 6.1 (f). The legitimate interest is to get a proper factual basis for making a decision and recruit the best suitable employees.

6. WHO ARE RECIPIENTS (OR CATEGORIES OF RECIPIENTS) OF THE PERSONAL DATA?
 
Your Personal Data may be sent to or may be accessed by the following recipients:
 

Recipient or Category of Recipient

Location

Microsoft Azure

Ireland, Finland, Netherland or Austria

Office365

Ireland, Finland, Netherland or Austria

Sharepoint

Ireland, Finland, Netherland or Austria

OneDrive

Ireland, Finland, Netherland or Austria


In all these instances, we have appropriate contractual and security measures in place to ensure that personal data is protected.
Please contact us if you need any further information, cf. section 9.

7. YOUR RIGHTS IN RELATION TO OUR PROCESSING

You have rights in relation to our Processing of your Data.  These rights are summarised in Annex 1 to this Privacy Policy.  You can exercise your rights at any time by contacting us at the contact details set out in Section 9 below.


8. COOKIES

We use cookies on our website. 

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added. 

Cookies are small text files held on your computer, allowing us to give you the best possible visit to our website. You can delete or block cookies, but his might lead to some parts of our website not working properly. If you continue without changing your settings, we’ll assume that you are happy to receive cookies from this website.

We process personal data on the basis of consent as required by § 2-7b of the Norwegian Electronic Communications Act.


9. CONTACT US

Stratema is the Data Controller. If you have any questions regarding this Privacy Policy, data processing or to exercise your rights, please contact us at dave@stratema.no or +47 92 84 92 84.

If you believe that your data protection rights have been breached by Stratema, please let us know. You also have the right to lodge a complaint with Datatilsynet, the supervisory authority for data protection issues in Norway: Datatilsynet.
We appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.


Last updated September 17th 2018











Annex 1

The rights that are referred to in Section 8 of the Privacy Policy must be interpret in accordance with GDPR, and are:

1. Right of access

You have the right to receive confirmation as to whether your Data is being Processed by us, as well as various other information relating to our use of your Data and copies of that information. You also have the right to request access to your Data which we are Processing.

2. Right to erasure

You have the right to request us to erase your Data. 

We shall comply with your request without delay unless an exception to compliance applies, for example if the Data is required to establish, exercise or defend legal claims.

3. Right to object

You have the right to object to us Processing your Data.  The relevant circumstances where you may invoke this right are where we are Processing your Data based on our legitimate interests. If you ask us to stop Processing your Data, we will stop Processing your Data unless we can demonstrate compelling grounds as to why the Processing should continue in accordance with data protection laws or, if the information is required to establish, exercise or defend legal claims.
 
4. Right to rectification

You have the right to make Stratema correct any inaccurate personal data about you.

5. Right to restriction

You have the right to request that we restrict the Processing of your Data.  

Where any exercise by you of your right to restriction, we will still hold the data but will not process it any further. However, we will process it the purpose of establishing, exercising or defending legal claims.

6. Right to Withdraw Consent

You have the right to withdraw your consent at any time. To do this, you should contact Stratema in accordance with section 9 in this Privacy Policy.

7. Right to data portability

You have the right request that you receive copies of the relevant Data provided by you in structured, standard machine-readable format and, where technically feasible, to request that this information is transmitted directly to another controller.
 

 


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