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Privacy Policy for NHST Global Publications AS

Revision 25 May 2018

This privacy policy applies to all our end users. We want you to have as much control over your personal data as you possibly can, and over how they are treated. That is why we have prepared a “Privacy Dashboard” page that gives you information about what we are processing about you, contact information, information on the privacy policy, and the possibility of giving and withdrawing consent to the processing of your personal data, and changing other settings related to your privacy.

1. About NHST Global Publications , the Services and registered users

1.1 Who are we?

This privacy policy applies when we, i.e. NHST Global Publications AS, company registration no. 937 593 821, and related publications, IntraFish Media, Upstream, Recharge and TradeWinds ( « NHST Global Publications » ) deal with your personal data. Consequently, this privacy policy explains why NHST Global Publications gathers information about you, how that information is used, and how NHST Global takes your privacy into account. Your data are safe with us and are only used for what is stated in this policy.

NHST Global Publications AS is wholly owned by NHST Media Group AS ( « NHST » ). NHST and its subsidiaries will hereinafter be called « the Group » . You will find information about the Group at www.nhst.com . Since the Group uses the same basic information systems and has common technical platforms and IT department, personal data can be processed by the Group for administrative purposes.

1.2 The Service

The privacy policy explains how NHST Global Publications and NHST Global Publications’ partners gather and use personal data when registering with and using NHST Global Publications’ mobile applications ( « the Apps ») NHST Global Publications’ physical newspapers ( «Newspapers» ), newsletters ( «Newsletters» ), NHST Global Publications’ conference products, of which NHST Global is the organizer ( « the conferences» ), and websites linked to NHST Global Publications ( « the websites» ). Hereinafter together these are called «the Services» . This privacy policy also explains your privacy-related rights towards NHST Global Publications and NHST Global Publications’ partners. The Services are owned and run by NHST Media Group AS. Its registered address is Christian Krohgs gate 16, 0186 Oslo, mailing address P.O. Box 1182, 0107 Oslo, Norway.

1.3 Whose personal data we process

NHST Global Publications has several groups of end users. If you make use NHST Global Publications’ Services, you will belong to one of those groups of end users.

Active subscribers is the group that NHST Global Publications processes the most personal data on, those who have a subscription where they pay for the Services.

If you have cancelled your subscription for one of NHST Global Publications’ services and 12 months have passed since you cancelled it, you are considered a passive user. In that case, NHST Global Publications will basically keep some personal data for a certain period of time, as explained in the points below. After you have been a passive user for up to 1 year, NHST Global Publications will delete all the personal data they still have stored about you, unless otherwise provided by law, or if you have given your active consent to further processing. Point 7 below provides further information on deletion.

You can also be a registered user without having a subscription for NHST Global Publications’ Services. That will be the case if you receive the Newsletters or have trial access to them.

The last group is the unregistered users, those who pop in and out of the Services but ho neither register nor pay for using them. NHST Global Publications processes very little personal data on this group of users.

What personal data are processed and in respect of what users will be explained in more detail below.

2. Why do we process your personal data?

NHST Global processes personal data on you for three overall purposes:

  1. In order to be able to provide you with the Services and personalize them for your purposes.
  2. In order to continue and further develop the Services.
  3. In order to be able to provide, personalize and measure the effect of adverts and other marketing that is show or sent to you as a user of the Services.


More about purpose no. 1:

NHST Global Publications processes your personal data in order to be able to provide you with the Services and fulfil any customer agreements we have with you. This includes for instance giving you access to the Services, allowing you to administer your user and customer relations, delivering newspapers to your address, sending invoices and reminders your email address, and informing you about important matters related to your customer relationship or the Services.

NHST Global Publications also uses data about you to be able to personalize the Services to you as a person, your user habits and your interests, for instance by personalizeing the content that is displayed in the Services to your needs. This is done by making use of so-called profiling. Through profiling we can personalize the content, adverts and marketing of NHST Global Publications’ Services for you.

Data about you is also used to prevent misuse of the Services. Misuse may be attempts at logging onto other people’s accounts, trying to swindle people, “spamming”, hate messages, harassment, and other acts that are forbidden under relevant legislation.

More about Purpose no 2:

NHST Global Publications uses data about you and your use of the Services to make sure you get an optimal and confidential user experience, and to learn more about how we can and should develop the Services further.

More about Purpose no. 3:

NHST Global Publications is partly financed by advertising revenue and is therefore dependent on providing, personalizeing and measuring the effect of adverts and other marketing in The Services. This is done internally at NHST Global within the Group and in collaboration with third parties like Google Ireland Ltd, Linkedin and Facebook, as described in more detail in points 4-6 and in the paragraphs here.

NHST Global Publications uses data about you for direct communication and marketing purposes through traditional channels like emails, text messaging – SMS, letters and telephone calls, unless you have withdrawn from such communication or in other ways have withdrawn your consent, and for sending Push messages in our Apps if such messages are switched on by you.

The data are also used by us and our advertisers, restricted to the Services for profile and segment-based marketing, developing and further developing targeted marketing, programmatic advertising, automatic marketing, and so-called «retargeting».

3. Overview of NHST Global Publications’ processing basis

Any processing of personal data requires a legal basis, also known as a processing basis. This means that before NHST Global Publications starts the process of processing your personal data, we must ensure that we are entitled to carry out that processing (that NHST Global Publications has a legal basis). That basis may come directly from you for instance in the form of voluntary consent or an agreement with us. Here is an explanation of what bases NHST Global Publications uses to process personal data and when they use them.

NHST Global Publications neither can, nor will we, process other personal data about you than what is expressly stated, and neither can nor will we do it in other ways than those described in this policy.

3.1 Legitimate interest

Moreover, NHST Global has a legitimate interest in some forms of processing, such as advertising purposes, marketing purposes etc. Such processing based on a legitimate interest applies to users with a registered profile or a subscription, or passive users (former subscribers) as described in point 1.3).

If you want to read more about the assessment NHST Global Publications has made, the balance test of your privacy weighed against NHST Global Publications’ legitimate interest, the measures implemented to reduce the risk of processing, and the conclusion on legitimate interest, you can read more about it in Appendix 1.

For end users with a user profile your settings on your Dashboard will show that the processing of your data that NHST Global Publications has a legitimate interest in carrying out, are “switched on”.

You have a right to «Opt out», which means that you are allowed reserve yourself against the processing, as described in point 8. This means that you can choose to switch off this processing in the settings on your Dashboard if you do not want NHST Global Publications to carry out the processing. Alternatively, you can always contact NHST Global Publications via the Contact page.

NHST Global Publications does not have any terms and conditions linked to such opting out, but NHST Global Publications makes it clear that the use of the Services may deteriorate for those users who use their right to opt out or withdraw consent.

3.2 Agreement

If you are a registered user or an active user with NHST Global Publications, then NHST Global Publications must be able to process personal data on you in order to be able to fulfil the user agreement with you. It is only the processing that is necessary for meeting NHST Global Publications’ obligations under the agreement that is carried out with this processing basis.

What processing is necessary to fulfil the agreement will depend on the user agreement between you and NHST Global Publications. The user agreement will either be “Subscription terms and conditions” or “Terms for registered users”. The agreement will vary somewhat for end users, based on what kind of subscription is agreed. Your user agreement will be available and you should read it before you accept the agreement. The user agreement will also be accessible on your profile page, “My Page” on the websites.

One example of processing based on an agreement: If you have a subscription with NHST Global Publications for delivery of a newspaper to your door, NHST Global Publications has to know the address the paper is to be delivered to. Another example is that NHST Global Publications has to process personal data in order to have the correct invoice sent out and make sure it is paid.

3.2.1 Newsletters and notices

NHST Global Publications also has newsletters and notices from our commentators and newsrooms which you as a registered user can choose to sign up for. You will not receive these things unless you actively sign up for them. You can control the sign-up or, if you want, you can cancel it freely yourself on «My Page» or via the newsletter itself.

You are free to use the Services without giving us your consent to process your personal data. The Services may lose some functionality and user friendliness without certain consents. Another example is that we have to have consent to be able to send you good offers when you are no longer considered to be an active user.

Consent can also be regulated by you in your settings on the Dashboard, where you will get the opportunity to give consent, see what consents you have given before, and withdraw consents if you change your mind.

3.3.1 Cookies

NHST Global Publications uses information that we gather from our own and third parties’ cookies, tracking pixels and other tracking technology integrated into the Services. This processing applies to all groups of end users of the relevant Services.

When you access and start using the Websites or the Newsletters or when you download and start using the Apps, or use the Services in some other way, you are consenting to NHST Global Publications, the Group and NHST Global Publications’ partners processing data about you as described in this privacy policy.

If your browser allows information files, so-called cookies, this is considered as your having given us consent to using cookies as stated in this privacy policy. Please also see our Cookie Policy . However, we wish to inform you that certain parts of the Services’ functionality depend on such consent and that your access to and experience as a user of the Services could therefore be affected.

3.4 Legislation

NHST Global Publications is required by law to carry out certain processing of personal data, such as for instance any personal data that NHST Global Publications has to process in order to comply with its accounting and book-keeping obligations.

4. The data that are processed

Data that is processed about everyone using the Services:

  • Information that is available on your device and its internet connections, such as for example the name of the maker of your mobile phone/PC, operating system and browser version, e-mail client, and information on the connection with the Services, such as IP-addresses, network ID, cookies and unique identification files.
  • Statistics on your use of the Services, such as for instance how often various button or links are pressed, purchases that are completed, what pages are visited, when and for how long they are visited, Cross-device»-tracking for logged-in users, etc.
  • Statistics on interaction over adverts, newsletters and surveys displayed in the Services.
  • The location of the unit you use, if such information is shared by the unit.
  • The information given in the above points is basically not connected with your identity, but is treated as anonymized or pseudonymized data about one of NHST Global Publications’ users. You can limit such storage by surfing in so-called «Private Mode»/«Incognito Mode» or by using the «Do Not Track»-function in your browser.

If you register as a customer or user of the Services, any data stored will be linked to our customer relationship or your user, as mentioned in the above points.

If you register as a customer or user of the Services we will also process the information you yourself have given us in connection with your customer or user relationship, such as:

  • Name*
  • Address*
  • Mobile number*
  • Email address*
  • Gender
  • Employer
  • Information about your customer relationship, such as the type of subscription you have and what newsletters you may receive, payment data and history.
  • Information on where you learned about NHST Global Publications AS offerings
  • Your interests, if you have informed us about those
  • Data to which you have given us access or which are lying openly accessible on social media such as Facebook, Twitter, Linkedin etc.

    * = required in order to complete your registration.

5. Where is the information gathered from

NHST Global Publications processes personal data on you which you yourself have given to us or through your use of the Services, to which NHST Global Publications gets access from the unit on which you use the Services and which NHST Global Publications collects from third parties as described in this privacy policy.


6. Our relationship with third parties

6.1 Who helps NHST Global Publications in processing your personal data?

In order to be able to provide you with the Services NHST Global Publications uses several services delivered by third parties. This means that some of these third parties process data on you on our behalf. Third parties who process personal data on behalf of NHST Global Publications are called data processors, in Appendix 2 you will find an up-to-date overview of such data processors.

NHST Global Publications has data processor agreements with third parties that process personal data on our behalf in accordance with current legal requirements.

6.2 To whom does NHST Global Publications pass on personal data?

NHST Global Publications uses a number of services provided by third parties who use information on our users without linking such information to you as an individual. NHST Global Publications’ implementation of such services is done in such a way that this does not mean that personal data about you is processed or transferred by NHST Global Publications. Those NHST Global Publications gives personal data to are not to be able to use your personal data to enrich their own profile sets.

Through our analysis tools NHST Global Publications gets access to anonymized data on your usage patterns for the Services. To make sure that the data are anonymous, we follow Google’s Best practices to avoid sending Personally Identifiable Information (PII) . All the same, you can choose to reserve yourself against the collection and analysis of data through Google Analytics by downloading Google Analytics opt-out browser add-on .

NHST Global uses Google AdX, Google DFP and Google AdWords to supply, personalize and measure the effect of adverts in the Services. We ensure that information used in connection with this is anonymous. For further information on Google’s services, technology and use of data click here . You can also choose to opt out of the collection and use of information for ad targeting by other players here .

NHST Global Publications does not link information from said third party services to you as a person hand has implemented these on account of your privacy. If you have a separate user account with said service providers and are logged in on such user accounts when using the Services, these service suppliers can, in certain cases, link information about your use of the Services to your user account with them. The service provider is responsible for the processing in such cases and their terms and conditions apply. You can change the user settings linked to Google here . Google has also explained how you as the end user can remove unwanted ads on Block off certain ads .

NHST Global Publications hereby informs you that active interaction with such services, for instance by clicking on ads and links may lead you to websites/applications/services owned by others, not NHST Global Publications. In such cases other terms and conditions apply, not those of NHST Global Publications.

7. Deleting and filing your personal data

Your personal data will only be stored for as long as we have a legal basis for it in compliance with this privacy policy and current legislation as such. When there are no longer any legal basis for processing, the data will be deleted, encrypted or anonymized.

NHST Global Publications automatically deletes all personal data stored on you after the customer relationship has ceased, when we no longer have legal basis to process your data, We will keep your data  further only if you have given your consent  for us to do so. Special legal requirements such as accounting obligations and similar demand that certain data are stored longer. Such data will not be used for any other purposes, and during the period leading up to the deletion of such information there will be limited access to such data, and they will be secured by appropriate technical and organizational means.

8. Your rights

You can at any time withdraw the consent you have given under this privacy policy or in some other way to NHST Global Publications. We make it just as easy for you to withdraw your consent as it is for you to give it. Your privacy settings are managed on your My Settings page in the Privacy Dashboard.

Such withdrawal can also be done by cancelling any customer relationships you have with us where you ask us to have your user account deleted. To delete anonymized information on your use of the Service, you also have to delete cookies on the unit/your browser. Withdrawal of consent does not affect the legality of the processing built on consent until the consent is withdrawn.

You can also withdraw your consent by contacting NHST Global Publications AS via the Contact page . NHST Global Publications’ Privacy Officer is Hege Hansen.

You can also get in touch with NHST Global Publications in the same way if you want to look into which of your personal data NHST Global Publications has stored, and if you want to have these personal data transferred to you or to have the data deleted or corrected.

Likewise, you can contact NHST Global Publications if you want to limit NHST Global Publications’ processing of your personal data or if you want to protest against NHST Global Publications’ treatment/processing of your personal data. You are also entitled to complain against our treatment to the Data Protection Agency, which is the supervisory authority, if you believe our treatment is in violation of the legislation.

NHST Global Publications makes use of automated decision-making, including profiling, limited to such purposes as those stated in points 2 – 4 above.

You can choose for yourself to remove our access to your unit’s location data by switching off the location tools on the unit, or by refusing sharing of such data through your unit’s settings.

If NHST Global Publications brings this privacy policy up to date, or changes it, NHST Global Publications will inform you about the changes. Please see the overview of previous versions of this privacy policy.

9. Safety and security

NHST Global has technical and organizational safety measures, including procedures for internal control and information security in accordance with the current privacy rules in Norway.

It is safe to use the Services. NHST Global Publications handles personal data in an encrypted and safe manner for instance by using HTTPS communication for transferring data on you safely and securely.

NHST Global Publications will not sell, replace or disclose your personal data to third parties other than that which is stated in this privacy policy.

Appendix 1. Legitimate interest

NHST Global Publications has conducted an independent evaluation with a balance test and concluded that NHST Global Publications has a legitimate interest to process some personal data.

Legitimate interest

NHST Global Publications has a legitimate interest for digital advertising delivered through the NHST Global Publications Services (Apps, Newspapers, Newsletters, Conferences, and Websites) via an advertising management system that uses cookies for profile data about end users. These are used to i) customize advertising based on interest and location, ii) manage advertisement frequency, iii) measure efficiency, iv) report impressions to advertisers/media agencies. The purpose is that NHST Global Publications may deliver efficient and competitive advertising products in a digital advertising economy and subsequently deliver independent journalism and quality content.

When you subscribe to a payable product, including signing up for a trial subscription, NHST Global Publications has a legitimate interest to market our products and services to you in channels like email and telephone, as well as send you notifications on editorial content that we think you will be interested in reading.

NHST Global Publications will also use data from your user profile and navigation to suggest personalised content and offers when you use the Services based on legitimate interest.

Further, NHST Global Publications has legitimate interest to use personal data to improve our Services by using various analytics and test tools, for instance so-called A/B testing. The purpose for this is to improve the user-experience for all our user groups on our Services.

The personal data

The information processed is normal personalia, data about subscriptions and products, behavioural data from navigation and reading patterns or data given directly by the user. NHST Global Publications and its related titles are not processing sensitive data, ref GDPR art. 9 or 10, and NHST Global Publications are not processing personal id numbers or credit card information.

Risk Mitigation

NHST Global Publications has taken steps to reduce the risk in connection with all data processing. This means that all data that potentially are shared with third-parties are pseudonymized and contain few data points, only cookie-ids and if relevant the name of the segment that the user belongs to. The systems are well secured, both in technical and organizational terms. Data that are processed by third-party suppliers or partners will not be used to enrich any third-party user-profiles for re-targeting or other advertising purposes. NHST Global Publications also offer the possibility to opt-out of all processing based on legitimate interest.

Conclusion

Based on the information stated here, NHST Global Publications and its related titles has conducted a balance test and concluded that NHST Global Publications and its related titles has a legitimate interest to process personal data for the purposes stated here. Your privacy settings are managed on your My Settings page in the Privacy Dashboard, and you are free to opt out of any processing at all times.

Appendix 2. Overview of data processors

Evry ASA - www.evry.no
AirBusiness - www.airbusiness.com
ComScore - www.comscore.com
Redpill-Linpro AS - www.redpill-linpro.no
Etouches - www.etouches.com
HotJar – www.hotjar.com
HubSpot – www.hubspot.com
Io Analytics – t.onthe.io/media
Leadfeeder - www.leadfeeder.com
Madgex - www.madgex.com
MailChimp – www.mailchimp.com
Capana – www.capana.dk
NHST Media Group – www.nhst.no
Cefalo – www.cefalo.no
Visiolink – www.visiolink.dk
Google – www.google.com
WisePops – www.wisepopos.com
Zapier – www.zapier.com