1. Contact information for Petras Verden AS

Petras Verden AS is the data processor responsible for handling personal information. If you have any questions about the processing, wish to contact us to exercise your rights, or want to make a complaint, you can reach us at:

• Ingeborg Ofstads Veg 118A
• 7091 Trondheim, Norge
• Organisasjonsnummer: xxxx
• Email address: petras.verden@gmail.com

2. Definition of key terms:

Before we begin, it might be useful to define some terms:

• "Personal information" refers to all information and assessments that can be linked to you as an individual. Examples of personal information include your name, address, phone number, email, and social security number.
• "Anonymous information" is information that is not associated with or linked to your personal information. Anonymous information cannot be directly or solely used to identify an individual. It may be personal information where personally identifiable information has been removed.
• "Processing of personal information" involves all forms of handling personal information, such as collection, analysis, registration, and storage. The processing should be carried out in a manner that ensures predictability and proportionality for the individual to the greatest extent possible.
• The "data processor" is the entity that determines the purpose of processing personal information and what information is required. The data processor is responsible for processing personal information lawfully, fairly, and transparently, having a legal basis for processing, processing personal information securely, and ensuring that data subjects can exercise their rights.

3. Petras Verden AS is the data processor

Petras Verden AS is the data processor responsible for handling your personal information.

4. What kind of information do we collect?

4.1 Information you share with us

Petras Verden AS collects personal information from parents when they voluntarily register a user account with us. During the account registration process, we request parents' email addresses. We also ask for information about payment cards or credit cards, which is transmitted from our user interface to the payment provider Stripe. Stripe's ability to use and share information is governed by their terms of use available at https://stripe.com/en-no/legal/end-users and their privacy policy available at https://stripe.com/en-no/privacy. We may also collect personal information from the information you voluntarily provide us when you interact with us. This can occur during registration, correspondence, customer service, or customer surveys.

4.2 Information we collect through automatic data collection technology

Petras Verden AS automatically collects technical information sent from your computer, mobile device, or browser when you visit our application or website. This information includes a unique identifier associated with your device and/or browser, IP address, statistics about your activity on the platform, information about how you arrived at the platform, device and/or browser characteristics, and approximate location data such as the city, county, and country you are in. This information is shared with the service provider Mixpanel. Mixpanel's ability to use and share information is governed by their terms of use available at https://mixpanel.com/terms/ and Mixpanel's privacy policy available at https://mixpanel.com/privacy/. By registering as a user of our platforms and accepting this privacy policy, you agree that we automatically collect this information about you and share it with Mixpanel.

4.3 Information from other sources

When you consent to us processing your personal information, you also agree that we may record other information about you that you have provided to us on previous occasions. Based on publicly available information, we may also supplement your registered information with industry and additional contact information. If you are a customer of ours, we may also add additional contact information to your records, which you have registered with us, for example, through phone calls to customer service. Information necessary for the services you use will also be stored.

5. Paragraph 6f as an alternative to chosen consent via the website. Consent can be withdrawn.

We base our processing on legitimate consent according to Paragraph 6f of the Personal Data Act. If you have previously entered into a customer relationship with us, or if you are a new customer, this constitutes a legitimate reason to send you information. This is considered equivalent to consent in accordance with the Marketing Act as it has been in Norway for many years. You can withdraw this consent for us to process your personal information at any time. If you withdraw your consent, we will remove the information we have about you. Please note that deleting this information from our records may affect the delivery of information within the framework of the customer relationship, as well as ongoing communications.

6. Why do we collect, use and disclose Personal Information?

We may collect, hold, use and disclose your Personal Information to:

• enable you to access and use our application and its features effectively.
• send you important service-related messages, support and administrative notifications, technical updates, and information you have requested.
• keep you informed about marketing promotions, special offers, and other interesting information that may be relevant to you. This may include messages from our business partners that align with your interests.
• fulfill our legal obligations, resolve disputes with users, and enforce agreements with third parties, as required by applicable laws and regulations.
• protect, operate, and improveour application, ensuring a seamless user experience. This includes performing analytics, conducting research, and enhancing our advertising and marketing strategies.
• verify your identity for security and account access purposes.
• manage rewards programs, surveys, or other promotional activities, either sponsored or co-managed by us or our partners.

We may also share your personal information with a trusted third party that holds additional data about you. The purpose of this collaboration is to combine the information and develop anonymized consumer insights. By doing so, we can gain a deeper understanding of your preferences and interests. This valuable knowledge enables us to personalize your experience and enhance the services we provide to you.

The information we collect is never distributed, sold, or leased to third parties for commercial purposes. However, there might be certain situations where we may need to share your information with trusted third parties for specific purposes. This will only be done with your explicit permission or when legal obligations mandate us to disclose such information.

Please be assured that any data sharing with third parties is conducted responsibly and in adherence to relevant privacy regulations. If you have any questions or concerns regarding the use and disclosure of your information, please do not hesitate to contact us. We will provide further clarification and address any inquiries you may have.

7. Consent to email correspondence, direct marketing, and further contact

When you consent to us processing your personal information for the aforementioned purposes, you are agreeing to the following:

• We will process your personal information in accordance with this privacy policy.
• We may send you direct marketing via email about our products.
• We may contact you via email or phone.
• Subscription to newsletters via email that you have chosen to receive. You can opt-out of further emails by following the link located at the bottom of our emails or by contacting us directly.

8. Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorized access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. However, we cannot guarantee the security of your personal information.

9. Retention

We may store and keep your personal information for as long as you remain a registered user of the application. If you wish to close your account, you can contact us, and we will assist you with the process. However, please note that in some cases, we may need to retain certain personal information for a longer period, as permitted or required by relevant laws and regulations. This is to ensure compliance with legal obligations and to meet legitimate and lawful business needs. Even if you request the deletion of your personal information, it may still be retained on backup or archival media for an additional time for legal, tax, or regulatory purposes.

10. Who can the information be shared with?

The provided information will be accessible to a limited number of authorized individuals within the organization who have a legitimate need to access the data for business purposes. This includes employees across various departments, such as marketing, customer support, and other relevant teams involved in providing and improving our services. Access to personal information is strictly controlled and granted only to employees who require it to fulfill their job responsibilities.

11. Information sharing with third parties

At Petras Verden AS, we believe in maintaining the utmost transparency regarding the sharing of your personal information with third-party providers who play an essential role in delivering and enhancing our services. We have carefully selected these trusted partners, and we want to assure you that they are committed to upholding the same level of data privacy and security as outlined in this privacy policy. Below are the third-party providers we may share your information with:

11.1 Payment Processing Provider - Stripe:

When you register as a user and make payments on our platform, we may collect and share certain personal information with our payment processing provider, Stripe, such as payment card and credit card information. Stripe's secure payment gateway facilitates smooth and secure transactions and helps us ensure a seamless user experience. Stripe's use of your personal information is governed by their own terms of use and privacy policy, available at https://stripe.com/en-no/legal/end-users and https://stripe.com/en-no/privacy, respectively.

11.2 Analytics Provider - Mixpanel:

To improve our application's functionality and enhance your user experience, we employ the services of Mixpanel, an analytics provider. Mixpanel collects technical information sent from your device or browser, as outlined in Section 4.2 of this privacy policy. This data helps us gain valuable insights into user behavior and preferences, allowing us to tailor our services to better meet your needs. Mixpanel's use of the collected information is subject to their own terms of use and privacy policy, available at https://mixpanel.com/terms/ and https://mixpanel.com/privacy/, respectively.

12. Your rights

We value your control over the use of your personal information. As a user of the application, you possess various rights related to your information. In line with the European General Data Protection Regulation (GDPR), you are entitled to the following rights:

• The right to access:You have the right to receive clear and transparent information regarding the collection and utilization of their personal data.
• The right to access: As a user, you have the right to request copies of your personal information from Petras Verden AS. Please note that a small fee may apply for this service. There might be instances where we are unable to provide access to all of your Personal Information, and in such cases, we will provide you with a clear explanation. Additionally, to ensure security and privacy, we may need to verify your identity when processing your request for Personal Information.
• The right to rectification: You are entitled to request Petras Verden AS to correct any information that you believe to be inaccurate. Additionally, if you find any information to be incomplete, you have the right to request us to complete it. Your data accuracy and completeness are important to us, and we are committed to ensuring that your personal information is up-to-date and reliable.
• The right to be forgotten/Right to erasure: You have the right to request the erasure of your personal information held by Petras Verden AS, under certain conditions. If you believe that we no longer need to retain your data for the purposes it was collected, or if you withdraw your consent and there is no other legal basis for processing your information, you can request its deletion. However, please note that there may be specific circumstances where we are legally required to retain your data despite your request for erasure.
• The right to data portability: You have the right to request that Petras Verden AS transfer the information we have collected about you to another organization, or directly to you, under certain conditions. We will process your request in accordance with applicable data protection laws and regulations. However, please note that this right is subject to certain legal restrictions and may not apply in all circumstances.
• The right to restrict processing: You have the right to request that Petras Verden AS restrict the processing or supression of your personal information, under certain conditions. We will carefully review your request and, where applicable, take appropriate steps to restrict the processing of your personal information in accordance with applicable data protection laws.
• The right to withdraw consent: You have the right to withdraw previously given consent for the processing of their personal data.
• The right to object:You have the right to object to the Petras Verden AS processing of your personal data. We will review your request and consider whether there are compelling legitimate grounds for us to continue processing your data. If there are no such compelling legitimate grounds, we will cease processing your personal data.
• The right to object to automated processing: You have the right to object to decisions being made with your data solely based on automated decision making or profiling.

These rights can be exercised at any time by contacting us at petras.verden@gmail.com. If you make a request, we have one month to respond to you.

13. Other purposes

If we intend to use the personal information for a purpose other than the one for which it was collected, the duty to inform arises again. In such a case, we must disclose the new purpose and provide relevant information as mentioned above again.

14. Cookies

Cookies are small text files that are placed on your computer when you download a website. The storage and processing of information through these cookies are not allowed unless the user has been informed about it and has given their consent to the processing. The user should be informed of and approve which information is processed, the purpose of the processing, and who processes the information.

We only use cookies to provide you with a better user experience on our pages, so you don't have to enter the same information again every time you visit our site.

15. Email and telephone

We use email and phone as part of our daily work. Relevant information that arises from phone calls and email exchanges that occur as part of customer service is recorded in the customer system.

Our employees also use email for regular communication with internal and external contacts. Each individual is responsible for deleting messages that are no longer relevant and, at least annually, reviewing and deleting unnecessary content in their email inbox. Upon departure, email accounts are deleted, but some relevant emails will typically be transferred to colleagues.

Sensitive personal information should not be sent via email. Please be aware that regular email is unencrypted. Therefore, we encourage you not to send confidential, sensitive, or other classified information via email.

16. Making a complaint

If you believe that we have not fully complied with the Personal Data Act or any other applicable privacy law, or if you have concerns about how we have handled your Personal Information, we encourage you to reach out to us. To make a complaint, please provide your name, email address, and/or telephone number, and clearly outline the details of your concern. We will thoroughly investigate your complaint and provide you with a response within a reasonable timeframe. If, for any reason, you feel that your complaint has not been satisfactorily addressed, we will offer guidance on the next steps you can take.

Your feedback and input are valuable to us, as we are committed to safeguarding your privacy and ensuring the responsible and compliant handling of your personal information. Your confidence in our data protection practices is essential, and we are dedicated to resolving any issues or concerns to the best of our ability.