Vink Norway AS Privacy Policy – Effective date: 22.10.2020

Vink Norway AS, trading as Vink Norway AS, (“us”, “we”, “our”) is committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

This online privacy statement applies to all websites in the Vink family of companies, Vink online applications that run on smart phones, tablets, and other mobile devices (“apps”) as well as your use or access of any of our online services, content. It does not apply to those websites of suppliers and other third parties that have their own online privacy statements. 

Generally we do not collect any personal data about you. However, please read the following carefully to understand our views and practices regarding any personal data that you may share with us (for example by e-mailing us or purchasing our products) and how we will treat it.  If you have any requests concerning your personal information please contact our operations team by email at info@vink.no or telephone on 22 76 60 00.

We may from time to time change this online privacy statement. We recommend that you check the current version available. If we alter this policy, we will amend the “Effective Date” at the top of this page.

For the purpose of the European Union General Data Protection Regulations (the “GDPR”), the data controller is Frank Klabbers situated at Didam, Netherlands.

With the exception of personal data specified in this policy we will collect additional personal information from you, only if you have chosen to provide it to us.

You can access and browse any of our company websites (“our sites”), without disclosing your personal data.  The information we collect from you depends on what activities you are carrying out on our site(s), whether you are logged in or not and whether you are placing an order.  We may collect, process, maintain and store some or all of the following personally identifiable information about you:

• Contact Name (First and family names)
• Company Name
• Postal and / or  physical address
• Payment details (which may include credit card or banking account  information)
• Contact telephone number(s)
• Contact email address(es)

Examples of instances when such information may be collected, processed, maintained or stored are when you:

• Provide the information by completing online forms on our site.  This includes information provided at the time of registering to use our site, purchasing our products, completing the “Contact Us” form.  We may also ask you for information when you report a problem with our site.
• Contact us, we may keep a record of that correspondence.
• Complete surveys that we use for research purposes or to enhance our services. There is however no obligation on your part to respond to them.
• Complete transactions through our site and for the fulfilment of your orders.
• Visit our site(s) and access resources we may collect data with the use of cookies (See below for more on Cookies).

You will be requested by tick box to confirm that any information that you provide is true, accurate and complete, and that you will not deliberately provide any false information nor impersonate any other person or entity, or misrepresent yourself or any other person or entity.

Our websites and apps are not intended for children under 16 years of age. We will not knowingly solicit data online from, or market online to, children under 16 years of age. 

IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers.  This is statistical data about our users' browsing actions and patterns, and does not identify any individual. This information may be stored for a period of up to 13 months.

Cookies

Cookies are text files, used by your computer's browser, that store visitor session data.  Cookies are commonly used on the Internet and do not harm your system.

We currently use cookies to collate general management data which is used to plan enhancements to our services.

We make use of the following cookies, which are set to expire as detailed below:

• PHPSESSID – 1 hour
• STUID – 1 hour
• STVID – 1 year
• form_key – 1 hour
• mage-banners-cache-storage – Session
• mage-cache-sessid             - Session
• mage-cache-storage - Session
• mage-cache-storage-section-invalidation – Session
• mage-messages – 1 year
• mage-translation-file-version - Session
• mage-translation-storage - Session
• private_content_version – 10 years
• section_data_ids – Session

If you do not want to accept cookies you may be able to configure your browser not to accept them.  Please refer to your browser's 'help' facility for further information.  However, you should bear in mind that this may affect our ability to process the transactions you wish to have authorised.  You can enable or disable cookies by modifying the settings in your browser.  You can find out how to do this, and find more information on cookies, at: www.allaboutcookies.org.

Where we store your personal data

Any data that you provide to us is normally stored, processed and maintained in a country within the European Union (EU). While  such data may be transferred to, and stored at, a destination outside the EU, Vink shall ensure that only countries, and / or third party processors that are compliant with the EU regulations are used. It may also be processed by staff operating outside the EU who work for us or our associated service provider(s).  Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.  

By submitting any personal data, you agree to this collection, transfer, storing, maintenance and / or processing.  You will be required to accept this condition in a tick box at the time that you submit the personal data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy (See below for examples of measures that we use to protect personal data).

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.  We request that you do not share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect any personal data you give us, we cannot guarantee the security of your data transmitted from your terminal to our site.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. These include:

• Hashing
• SSL-encryption
• ISO 27001

We also take reasonable steps, such as encrypted passwords and recovering passwords via email without direct passwords details, to verify your identity before granting access to your personal profile.

Use made of the information

We may use information held about you in the following ways:

• To carry out our obligations arising from any contracts entered into between you and us
• To comply with any legal and /or statutory obligation in terms of relevant municipal laws
• To ensure that content from our site is presented in the most effective manner for you and for your computer
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
• To allow you to participate in interactive features of our service(s), when you choose to do so
• To notify you about changes to our service.

If you are an existing customer, we may contact you by email, telephone, printed media or in other manners with information about goods and services similar to those which were the subject of a previous sale to you.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Vink Norway AS is or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us or our group, our customers, or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your rights

You have the right to ask us not to process your personal data for marketing purposes.  We will inform you at the time of collecting your personal data if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes.  You can exercise your right to prevent such processing by checking the relevant boxes on the forms that we use to collect your personal data.  You can also exercise the right at any time by contacting us at DPO@vink.com.              

Subject to the provisions of the European General Data Protection Regulations you also have the right to request that:

• your personal information be deleted from our data bases
• any errors in your personal data be corrected
• we cease processing your personal data
• that we make your personal data available to other parties (right to portability)

Where we have shared your personal information in line with the provisions with this Privacy Policy, we shall take reasonable steps to inform all parties with whom we have shared the information of the request to have the personal information deleted.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

The GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.  Any access request may, at the discretion of the company, be subject to a fee of €5.00 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.

Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to DPO@vink.com.