Privacy Notice

LAST REVIEWED AND UPDATED SEPTEMBER, 2023

1. Overview

This Privacy Notice (“Privacy Notice”) is prepared by Vind Technologies AS (“Vind”, “we”, “our” or “us”) to ensure that you receive the information we are required to provide to you, and which is necessary for you to exercise your rights under the General Data Protection Regulation (the “GDPR”) and the Norwegian data protection legislation (together “data protection legislation”).

The data controller for the processing of your personal data is Vind. This Privacy Notice describes how we process personal data, the purpose of our processing activities, and the legal basis for our processing activities. Furthermore, this Privacy Notice describes the data subjects’ rights in connection with our processing of personal data under applicable data protection legislation. For information regarding our use of cookies, please see Section 5 below.

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2. Our Processing of personal data

The following list includes information about the personal data which we process, and the purposes which the personal data is processed for:

Providing the Vind AI platform. We process personal data about the individuals who have registered for a user account and are using the Vind AI platform, in order to provide the Vind AI platform and thereby fulfil the agreements we have entered into with our customers. For example, Vind uses personal data to provide authentication and authorization when users log into the Vind AI platform, to provide certain platform features and to monitor technical systems and report and debug errors. Personal data processed to provide the Vind AI platform to users include name, email, profile picture, application user ID, IP address.
Improving and developing the Vind AI platform. We process personal data to improve system operation based on usage and to enable product development and enhancements. For example, if we receive a feature request from a user or customer, we will store the request and the contact information of the sender in order to manage the feature request. The personal data processed in this respect include user ID, user activity and customer company name.
Administration of business relationships. We will process the personal data of representatives and contacts of our business partners, in order to administer our business relationships. For example, we will process personal data relating to the aforementioned representatives and contacts in order to respond to their requests and questions regarding our service offerings. We will in this respect process personal data such as name, email address, signature and company name.
Marketing. We may provide registered Vind AI platform users and contact persons of customers with information about the Vind AI platform, new products, campaigns and other business initiatives of Vind. For the purpose of providing such marketing material, we may process personal data such as email address, application user ID and IP address. The marketing recipient may terminate its newsletter subscription at any time by following the “unsubscribe”-information included in the newsletter emails or by contacting us as described below.

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3. The sources we obtain personal data from

We collect the personal data described in Section 2 above from the following sources:

Providing the Vind AI platform. We collect personal data about users of the Vind AI platform when they register for an account, add details to their user profiles within the platform, and use the service.
Improving and developing the Vind AI platform. The personal data we process for the purpose of improving and developing the Vind AI platform are collected through user activity in the platform or via feedback, requests and other communication with users or customer representatives.
Administration of business relationships. The personal data we process regarding the representatives and contacts of our business partners are primarily obtained from these contacts and representatives, but may also be collected from publicly available sources.
Marketing. The personal data we process for marketing purposes are obtained from the marketing recipients when they register for an account in the Vind AI platform or by Vind’s contact with the customer’s contact person(s).

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4. Our Legal bases for Processing personal data

We will rely on the following legal bases for our processing of the above described personal data:

Providing the Vind AI platform. Vind processes personal data about individuals who have signed up for and use the Vind AI platform for purposes connected to our legitimate interests. If an individual has signed up and is using the Vind AI platform pursuant to a contract between Vind and the company to which the individual is affiliated (e.g. where the individual is employed), we will process his/her personal data based on our legitimate interests in performing the relevant contract. However, if a representative from a customer has mediated access to the Vind AI platform to an individual outside the customer organization, we will process his/her personal data based on our legitimate interests in promoting our services towards such individuals, as well as our interest in providing our customers with this opportunity. We also process certain personal data regarding users in furtherance of our legitimate interests in providing certain platform features, such as authentication and authorization when users log into the Vind AI platform, in order to deliver a secure and high quality service.
Improving and developing the Vind AI platform. We process personal data for improvement and development purposes in furtherance of our legitimate interest in enhancing our offerings.
Administration of business relationships. We process personal data about the representatives and contacts of our business partners in order to administer and fulfil any contractual obligations with them (e.g. registering a purchase), or, when not necessary to perform a contract, in furtherance of our legitimate interest in establishing and administering the business relationship we have with these persons (for example, in connection with responding to inquiries from potential customers).
Marketing. We will only process personal data for marketing purposes and, specifically, for the purpose of providing newsletters, if the recipient has consented to the relevant processing of personal data.

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5. Our use of cookies

Cookies are small pieces of text used to store information on the user’s web browser. They are widely used to store and receive information to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The cookies we use allow us to collect information such as browser type, anonymous traffic data and IP address, and enable us to, for example, see how users navigate in the Vind AI platform.

While the cookies that we use may change from time to time as we improve and update our services, we use them for the following purposes:

Necessary cookies: These cookies are required for the operation of our platform and website. They ensure basic functionalities and security features, anonymously.
Analytical or performance cookies: We use cookies to better understand how our services are used to improve them further. These cookies allow us to measure and improve the performance of our platform.
Functional cookies: These are used to recognize you when you return to our platform. This enables us to, inter alia, personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Marketing cookies: These cookies record your visit to our platform, the places you have visited and the links you have followed. We will use this information to make our platform, and the advertising displayed on it more relevant to your interests.

You can find more information about the individual cookies we use, and the purposes for which we use them, in the tables below.

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Cookies for website (vind.ai)

Cookie	Category	Description	Provider
_ga*	Analytical or performance	Google Analytics is a service for creating detailed statistics of user behavior on the website. The cookies are used to differentiate users, store campaign-related information for and from the user and to link data from multiple page views.	Google
google_maps	Functional cookies	Google Maps enables the embedding of maps directly into websites to enhance the website. This requires processing the user's IP-address and metadata. Cookies or cookie-like technologies can be stored and read. These can contain personal data and technical data like user ID, consent, settings of the map viewer and security tokens. This data can be used to collect visited websites, detailed statistics about user behavior, and it can be used to improve the services of Google. This data may be linked by Google to the data of users logged in on the websites of Google (e.g. google.com and youtube.com). Google provides personal information to their affiliates and other trusted businesses or persons to process it for them, based on Google's instructions and in compliance with Google's privacy policy.	Google

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Cookies for application (app.vind.ai)

Cookie	Category	Description	Provider
intercom-session-[app_id]	Functional cookies	Anonymous visitor identifier cookie used for the 3rd party Intercom integration	Intercom
intercom-device-id-[app_id]	Functional cookies	Anonymous visitor identifier cookie used for the 3rd party Intercom integration. Used for the messaging service	Intercom
auth0.{id}.is.authenticated	Necessary	Login information used for the 3rd party Auth0 integration	Auth0
_legacy_auth0.{id}.is.authenticated	Necessary	Login information used for the 3rd party Auth0 integration	Auth0
mp_{id}_mixpanel	Analytical or performance	Used to identify individual users. This tool is used to measure site performance and usage patterns. Unique strings replace the * in the cookie name	Mixpanel
intercom.intercom-state	Functional cookies	Remembers whether the user has minimized or closed chat-box or pop-up messages on the website	Intercom
intercom.viewed-tooltips	Functional cookies	Remembers whether the user has viewed a tooltip within the intercom app	Intercom
intercom.intercom-expanded-mode	Functional cookies	Remembers whether the intercom app is in expanded mode or not	Intercom
mapbox.eventData:{id}	Necessary cookies	Is used to store an anonymous user ID in local storage to track number of unique users per account	Mapbox
mapbox.eventData.uuid:{id}	Necessary cookies	Is used to store an anonymous user ID in local storage to track number of unique users per account	Mapbox
@@auth0spajs@@::*	Necessary cookies	Is used for keeping track for login information	Auth0
browser-tabs-lock-key-auth0.lock.getTokenSilently	Necessary cookies	Is used for keeping track for login information	Auth0
ably-transport-preference	Necessary cookies	Keeps track of ablys preferred transport preference	Ably
__mpq_{id}_ev	Analytical or performance	Used for tracking user analytics in MixPanel	Mixpanel
vind:*	Functional cookies	We store several user preferences and choices based on your actions in the Vind plattform. This is done to remember what you have done so that we can provide a better feature. E.g. what was the last project you visited in your previous session.	Vind
__mp_opt_in_out_{id}	Analytical or performance	This cookie is associated with Mixpanel. It collects information about: the pages you visit and how long you spend on each page what you click on while you're using Vind. Mixpanel toggles tracking according to 'Do Not Track' (DNT) settings in web browsers. This means you can control whether information is collected about you via your browser settings	Mixpanel
__mpq_{id}_pp	Analytical or performance	This cookie is associated with Mixpanel. It collects information about: the pages you visit and how long you spend on each page what you click on while you're using Vind. Mixpanel toggles tracking according to 'Do Not Track' (DNT) settings in web browsers. This means you can control whether information is collected about you via your browser settings	Mixpanel
intercom.lastTooltipsReceivedAt	Analytical or performance	This cookie is used by the 3rd party tool intercom	Intercom

Please note that if cookies are disabled, some or all of our services may become unavailable or not function as intended.

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6. Transfer and disclosure of personal data to third parties

We use external service providers to assist with IT services and other administrative services, such as hosting, email delivery, data analysis and other services. Our service providers act as data processors on our behalf. We have entered into data processing agreements with our processors which contain obligations for the data processor to implement technical and organizational measures to ensure an appropriate level of security, confidentiality and integrity for the personal data, as well as to only process the relevant personal data in accordance with the data protection legislation and our instructions.

We will only transfer personal data to countries outside the EU/EEA in accordance with applicable data protection legislation, including by using a valid data transfer mechanism, such as Standard Contractual Clauses adopted by the EU Commission (“SCCs”).

We will not disclose your personal data to any other third parties than the third parties described above, unless we are required to do so under applicable law, or if it is necessary to establish, exercise or defend legal claims.

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7. Retention and deletion

We retain all personal data for as long as necessary for the purposes for which they were collected and processed, unless statutes or regulations require us to retain them for a longer time period. After that, they are deleted or anonymized.

For example, the personal data relating to users of the Vind AI platform will be processed for as long as the relevant customer relationship is active and will be deleted, as a general rule, within 1 year after its end.

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8. Your Rights

You have the following rights when we process personal data about you:

Access. You may contact us if you want to obtain confirmation with respect to whether we are processing your personal data, as well as access to and further information regarding our processing of your personal data. You may also request a copy of the personal data we are processing about you.
Correcting personal data (rectification). You may ask us to rectify any errors in your personal data.
Erasure (the right to be forgotten). You may ask us to erase your personal data, which request we will respect and comply with.
Restriction. You may ask us to restrict the processing of your personal data.
Object. You are entitled to object to certain processing activities. You are furthermore, on grounds relating to your particular situation (for example, a specific need for protection of your identity), entitled to object to processing of personal data based on legitimate interests, which we will comply with, unless there exists compelling legitimate grounds for our processing which override your interest, or if our processing is necessary for the establishment, exercise or defence of legal claims.
Data portability. You may ask us to provide you or others with your personal data in a structured, commonly used and machine-readable format.

Please note that the above rights may be subject to further exceptions and limitations in accordance with the data protection legislation.

You may contact us if you wish to exercise any of the above rights. Please note that we may request additional information from you if such information is necessary to confirm your identity.

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9. Security

As a controller, we are responsible for the security and confidentiality of the personal data we process. We are furthermore responsible for implementing appropriate technical and organizational measures to ensure an appropriate level of security for the processing.

We are, for security reasons, not entitled to disclose detailed information on the security measures which we have implemented. However, we have implemented appropriate measures, policies and routines to ensure the security of our processing.

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10. Questions and complaints

If you have additional questions on how we process personal data, or are dissatisfied with our processing, you are welcome to contact us. Please find our contact information below.

You may also lodge a complaint with the relevant supervisory authority. Please click here to access the contact information to the Norwegian Data Protection Authority. The contact details for all EU Supervisory Authorities can be found here. Further details regarding your rights are available in the GDPR, which can be accessed by clicking here.

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11. Changes

We may update the Privacy Notice from time to time. The Privacy Notice will, for example, be updated to comply with any legislative amendments or if we make changes to our processing of personal data.

The most recently updated version of the Privacy Notice will always be available at https://vind.ai/privacy

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12. Contact Information

If you have any questions about this Privacy Notice, including how we process personal data, or would like to submit a request to exercise your rights, please contact us at:

Vind Technologies AS
Universitetsgata 2, 0164 Oslo
privacy@vind.ai
+47 450 511 81
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