Privacy notice relating to Newsec Transaction Application

What is the scope and purpose of this Notice?

Your privacy is important to us. We have therefore adopted this privacy notice ("Notice") describing how Newsec AS ("Newsec", "we", "us", etc.) collect, use, share, transfer and store your personal data when you use our transaction application (the "Service"). Newsec is the data controller for the personal data and is responsible for ensuring that the processing is performed in accordance with the GDPR and other applicable legislation. You find our contact information at the bottom of this text.

This Notice provides information on what personal data that is collected about you, why the personal data is collected, how the collected personal data is used and your rights as a data subject. The purpose is to protect your rights as data subject, ensure equal and secure treatment of your personal data and inform you about your rights.

All processing of personal data takes place in accordance with current data protection legislation, including the General Data Protection Regulation 2016/679 ("GDPR").

What is personal data and processing of personal data?

The term "personal data" as used in this Notice includes any type of information that, either on its own or together with any other information, can be connected to a living individual, and any other data that qualifies as personal data in accordance with the laws applicable to Newsec. Processing of personal data means personal data that in any form is kept, stored, collected, transferred, disclosed or otherwise handled.

How we collect and handle your personal data

You should feel safe with how we process your personal data. It is therefore important to us that you understand how we collect, process and share your data. The information we collect about you is mainly provided by you when you create a user profile and agree to the general terms and conditions for using the Service.

What personal data do we process and what is the purpose, legal basis and retention time for such processing?

Newsec only processes and stores personal data that we have legal basis for and clear purposes. The general type of data we process, the general purpose and legal basis for the processing and the retention time are described in Appendix 1. These mainly relate to processing of personal data that is necessary to provide you with access to the Service and managing your user account.

With whom do we share your personal data?

Data processors acting on behalf of Newsec

We may share your personal data with data processors, such as collaboration partners, other associations within our sphere, suppliers with whom we cooperate as well as our IT suppliers. Personal data may be shared only to the extent that is necessary. We have entered into written agreements with these parties, pursuant to which they undertake to only process your personal data in accordance with our instructions and with applicable data protection legislation and not to use your personal data for purposes other than those specified in this Notice.

Other recipients

The categories of recipients mentioned in this Section 5.2 will process personal data in the capacity as data controllers, i.e. these recipients will determine the purposes and means of the processing without Newsec’s involvement.

Appropriate safeguards for transfers of personal data outside the EU/EEA

Should Newsec transfer or disclose your personal data to a recipient in a country outside of the EU/EEA (third country), we will ensure that appropriate safeguards have been taken (such as the EU Commission's standard contract clauses, including other supplementary safeguards as necessary in each case) to protect the personal data.

You are, if so, entitled to request to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your personal data during a transfer to a third country.

If you would like to know more about the processing of your personal data and whether your personal data is transferred to a third country, please contact us on the contact details as set out below.

How we protect your personal data and your rights

You, as a data subject, have certain rights relating to how Newsec process your personal data. Your rights include:

Register extract. You have the right to request confirmation of whether or not we are processing personal data about you. If we do so, you have the right to obtain information on which data we process about you through a register extract.
Correction. If a personal data is incorrect or incomplete, you have the right to request that it be corrected.
Withdraw consent. If we process your personal data with consent as the legal basis for the processing, you have the right to withdraw consent at any time with future effect.
Oppose direct marketing. You have the right to object to personal data being processed for direct marketing (as relevant). This is done most easily by unsubscribing from send outs following the instructions provided in each send out.
Question legitimate interest. You have the right to oppose processing based on a legitimate interest if there are reasons in your specific case against the processing. However, if you object to the processing but there are legitimate reasons that outweigh your interest, we may continue the processing.
Delete personal data. You have the right to request and in certain circumstances have your personal data deleted. An exception is if we have a legal basis for keeping the data.
Data portability. In some cases, you have the right to receive a copy in a structured format of the information you have provided about yourself, for transfer to another data controller.
Limitation of processing. You may ask us to restrict the processing of your personal data to only comprise storage of your personal data under certain circumstances, such as when the processing is unlawful, but you do not want your personal data erased. If the processing of your personal data has been restricted we may only, besides storing the data, process your personal data with your consent, in order to establish, exercise or defend legal claims or to defend rights of others.

How to exercise a right

If you wish to exercise any of your above rights, please contact us at dataprotection@newsec.com. Please note that Newsec may contact you and ask you to confirm your identity to ensure that Newsec does not disclose your personal data to any unauthorized person. Newsec may ask you to specify your request before Newsec performs any actions. When your identity is confirmed, Newsec will handle your request in accordance with applicable law.

What should you do if you have any complaints?

You can always contact us at dataprotection@newsec.com if you have any questions regarding our processing of your personal data.

You always have the right to lodge a complaint with the relevant data supervisory. Following is a list of the relevant data supervisory authorities where Newsec operates, the Norwegian Data Protection Authority / Datatilsynet (www.datatilsynet.no).

Updates to this Notice

In order to ensure that Newsec complies with applicable law, this Notice may be changed by us at any time. Newsec will publish any changes made on our website.

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Latest update on November 2022.

Appendix 1

Purposes of the processing, personal data, legal basis and storage period[1]

To provide you with access to the Service
In order for you to be able to set up a user account and access the Service, including the content and information provided by Newsec in the Service, we will process your personal data.

Manage and administrate your user account
We will process your data for the overall management and administration of your user account, including in situations where we need to solve potential problems related to user accounts, e.g., to reset your password and other user credentials, or to suspend or otherwise limit your access to the Service.

Manage and protect IT systems and the Service
We process your personal data to the extent necessary for us to protect our IT systems (including the Service) through logging, troubleshooting, backup, change and problem management in IT systems and in connection with potential IT incidents. We also process your personal data to ensure that no unauthorised individuals are given access to the Service.

Fulfil legal obligations
We process your personal data to fulfil our legal obligations, according to statutory laws, judgements, or official decisions. Such requirements can e.g. refer to the processing of your personal data in connection with us administering our IT systems to protect your personal data in accordance with applicable data protection legislation.

Establishment, exercise, or defence of legal claims
For the purposes of establishing, exercising, and defending legal claims we may process your personal data.

[1]CQ comment to Newsec: Newsec to review, confirm and/or adjust the storage periods set out for each purpose in Appendix 1, as relevant.

[2]CQ comment to Newsec: For how long is data stored for this purpose?