If you have any questions to this policy, please contact us on firstname.lastname@example.org or +47 23 00 32 40.
1. PURPOSES OF PROCESSING
Njord processes personal data for the following purposes:
• Entering into or performing contracts with customers in relation to the Services
• Administration of customer relationships
• Compliance with legal obligations
• Marketing the Services
2. LEGAL BASIS FOR PROCESSING
Administration of customer relationships has the same legal basis as the previous activities, since this processing is also necessary for the performance of the Services / serves legitimate interests, which are not overridden by the interest of the data subject.
Njord processes some personal data about customers for the sake of complying with legal obligations, such as routines for prevention of money laundering and compliance with the Norwegian Book Keeping Act, which requires certain information to be stored for specific periods.
Marketing of Services is based on a freely given, specific and informed consent from a customer or potential customer, cf. the GDPR article 6 nr. 1 a).
3. COLLECTION OF PERSONAL DATA
We collect personal data primarily directly from our customers. This information may however be supplemented with information available through public registries, such as the Brønnøysund registries and information from other sources, such as for example banks or other relevant financial institutions when this is necessary in order to perform the Services to the customer. We may also collect information from public sources, such as by use of google, from media etc.
4. CATEGORIES OF PERSONAL DATA
Njord processes the types of personal data necessary to fulfil the purposes listed in chapter 1. Depending on the Services we perform, we register the following categories of personal data:
• Name and if relevant, company name, work position and other information relating to the company, hereunder information about shareholders
• Telephone number
• E-mail address
• Personal Identification Number
• Bank account(s)
• VPS account(s)
• KYC ("Know Your Customer": education, experience and knowledge with respect to investments, the origin of money etc.)
• PEP ("Political Exposed Person": information necessary to comply with legal requirements in the Norwegian Money Laundering Act)
• Former investments (information collected from the Brønnøysund registries, aksjeeier.no or other relevant public register).
• Other supplementary information collected from public sources and thereafter analyzed, e.g. (assumed) preferences with respect to asset types, contract period and object size.
• Recorded phone calls (Njord is under a legal obligation to record certain phone calls, cf. the Norwegian Securities Trading Act section 10-17.)
Processing of the above categories of personal data is more or less always necessary for performance of the Services and administration of customer relationships, hereunder compliance with requirements in the Norwegian Money Laundering Act. There might however be some variation depending on the Services performed and the customer in question.
The same information might be processed subsequently for the purpose of compliance with legal obligations and if the customer has consented to it, for marketing purposes, cf. chapter 1 above.
5. RECIPIENTS OF PERSONAL DATA
Njord sometimes share personal data with third parties when such disclosure is necessary for the performance of the Services and/or if instructed to do so by the customer, e.g. when performance of the Services require cooperation with such third party, typically a bank or another financial undertaking.
Suppliers of IT-solutions utilized by Njord for the processing of personal data may have access to personal data for purposes specifically stated in a data processing agreement, e.g. maintenance and support services relating to the IT-system. The data processing agreement commits the supplier to comply with applicable data protection law when performing the relevant services to Njord.
Personal data may be disclosed to national authorities if required under Norwegian law, e.g. for compliance with obligations following the Norwegian Money Laundering Act.
If personal data is to be transferred to a location outside of the EEA which is not providing sufficient guarantees for data protection, Njord will enter into EU standard data protection clauses with the relevant contractor or another legal mechanism, making the transfer legal (according to the GDPR chapter V).
6. DATA SECURITY
Njord is commited to prevent unauthorized access, disclosure or other deviant processing of personal data. We utilize reasonable and appropriate physical, technical, and administrative procedures and measures to safeguard personal data, including principles of data protection by default and by design:
• Transactions are encrypted by use of industry-standard technology.
• Personal data is stored in secure operating environments that are only accessible to Njord employees and sub-contractors on a need-to-know basis.
All our employees are subject to a strict obligation of confidentiality set out in the Norwegian Financial Undertakings Act section 9-6.
Njord has established routines for storage and deletion of personal data in order to make sure information is kept only for the period necessary to fulfill the purpose of processing. Note that although personal data was collected for one purpose, e.g. for the purpose of performing the Services, another purpose might require us to store the same information for a longer period, e.g. legal obligations arising out of the Norwegian Book Keeping Act or the Money Laundering Act. You may also give your consent to further processing of your personal data, e.g. to let us contact you with respect to Services we think may be of interest to you or the company you are representing.
8. DATA SUBJECT'S RIGHTS
You may at any time request a copy of your personal data that we have registered with us and/or request that we correct any inaccuracies in your personal data. If technically feasible, we can transfer personal data you have provided us with directly to another company.
You have the right at any time to opt-out of receiving market communications from us. Please contact us at email@example.com or +47 23 00 32 40. You may as well contact us if you object to processing which is based on the legitimate interests of Njord or another third party.
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