Privacy Policy

Huddly is the “controller” concerning the processing of your personal information under this Privacy Policy. This means Huddly is responsible for determining the purposes and means for processing your personal data as described in this Privacy Policy and also for complying with the data protection legislation. This Privacy Policy explains what personal data we process in the role as a controller, how we process it, for what purposes and on what legal grounds. The Privacy Policy also explains what rights you have and can enforce in relation to our processing of your personal data. Our contact details can be found at the bottom of this Privacy Policy.

1. Huddly’s processing of your personal data

When you use our products, services or otherwise interact with us as a customer or potential customer, partner or supplier, including when you visit our website we process your personal data for the restricted purposes as elaborated below.

1.1 Customer support,  feedback and management

If you contact us regarding support for the products you purchase, or if you provide us with feedback or otherwise contact us, we will process your name and contact information, such as your e-mail address, as well as any other information in your communication with us. We will respond to your inquiries or requests by using the contact information you provide us.

We disclose the personal data as described in this section with our third party service providers, to conduct quality assurance testing, provide technical support, and provide other services you have requested.

The legal basis for these processing activities is to fulfil your express request, to perform the contract with you in accordance with the Terms under which you use our services, and our legitimate interests in addressing any inquiries or feedback from our customers.

Further, Huddly may process your personal data for business operation and protection of business interests and security such as information security, logging, conducts of audits and controls, surveys, analysis, statistics, reports and managing of daily operations. The legal basis for this processing is Huddly's legitimate interest in ensuring good management of customers, suppliers and partners or to comply with legal obligations.

1.2 Maintenance and improvement of our products and services

When you use our products and services, we may process your personal data including cookies, your IP addresses, Internet service provider (“ISP”), and other information collected via technology, such as log files. Upon your consent, we may also collect audio and video files. You may find further description below in Section 3 regarding our use of each technology and your choices.

To the extent that the information involves your personal data, the purpose is to provide the services you request and to maintain and improve the quality of your experience when you interact with our products and services. This includes, for instance, to analyze trends, and to better tailor our products and services to our users’ needs.When you participate in one of our surveys, we collect personal data concerning you. Which personal data we collect depend on what survey you participate in. For example, we may collect your name, contact information or other user account information. This is for the purpose of improving the quality of our products and services. It is voluntary to participate in these surveys.

The legal basis of these processing activities is to fulfil your express request related to our products and services, to perform the contract with you according to the Terms under which you use our products or services, or our legitimate interests of improving our products and services.

We may process anonymous data records provided by our third-party services providers, such as Google Analytics. Such anonymous information will not contain your personal data. You may find further description below in Section 4 regarding our use of each technology and your choices. We use this anonymous data to analyze traffic and usage patterns so that we may enhance our products and services.

1.3 Marketing

We may use your personal data, such as name and contact details, to contact you with information that may be of interest to you, hereunder news, special offers and general information about our products, services and events that are corresponding to those you have already purchased or enquired about, unless you have opted not to receive such information. If you receive newsletters or promotional communications from us, you may at any time indicate a preference to stop receiving further communications from us, and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).

We will collect your account name if you interact with us via social media. This is for us to communicate with you and to promote our products and services.

The legal basis for these processing activities is your consent or our legitimate interests in running and improving our business operations.

1.4 Compliance with legal obligations and information relating to legal proceeding

Huddly may may process personal data necessary to comply with legal obligations, for example tax and accounting information and information relating to legal proceedings. The purpose and legal basis for this processing is Huddly's legal obligations or our legitimate interest in the establishment, exercise or defence of legal claims.

1.5 Cookies

We also rely on the use of cookies and similar technologies for the marketing of our offers and services (for further details see section 3). The legal basis for the use of cookies, and the personal data collected thereby, is your consent and our legitimate interest in delivering and improving our services.

2. Huddly’s disclosure of personal data

We do not sell your personal data for marketing purposes to other companies. We may only share your personal data as follows:

• With our third-party service providers, who perform operations or work on our behalf and on our instructions as processors, for the purposes indicated in this Privacy Policy. We will only share your personal data with the service providers to the extent necessary for them to deliver the respective services.

• To establish, exercise or defend legal claims; or

• With public authorities or governments when required by law, regulation, legal process or enforceable governmental request.

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

We may also share aggregated anonymized data with our business partners and group of companies for purposes such as for improving our service, for system administration, statistics, research and analysis.

The potential third-party recipients of personal data are listed below:

3. Transfer of personal data

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). Transfer of personal data to a third country outside of the EEA that does not provide an adequate level protection will only take place if appropriate safeguards are provided, e.g., by ensuring that sufficient guaranties are put in place such as Binding Corporate Rules or EU Standard Contractual Clauses as well as additional measures to ensure that your personal data are adequately protected, as appropriate. . If you have any questions relating to this, please contact us at the contact point provided below.

We may also transfer aggregated anonymous data (not constituting personal data) to third parties (domestic and/or foreign) for the purposes of i) improving or developing our website, products or other services and ii) for the proper functioning of our website, products or other services.

3.1 Cookies and tracking

In this section we clarify what type of information is collected by use of the cookies and similar technologies, whether third parties will have access to data collected by the cookies (and the identity of such third parties) as well as information about the duration of the cookies.

3.2 Cookies

Like many online services, we use cookies to collect information. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. This type of information is collected to make the website more useful to you and to tailor the experience with us to meet your special interests and needs.

Our website uses the following types of cookies for the purposes set out below:

Essential Cookies

These cookies are essential to provide you with services available through our website and to enable you to use some of its features. For example, they allow you to log in to secure areas of our website and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our website to remember choices you make when you use our website, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our website that you can customize. The purpose of these cookies is to provide you with more personal experience and to avoid you having to re-enter your preferences every time you visit our website.

Statistical cookies

These cookies track and provide statistics on the number of visitors at our website, the duration of the visit etc. Please review section 3.3 in this Privacy Policy on Google Analytics.

Targeted and advertising Cookies

These cookies track your browsing habits to enable us to show advertising that is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show adverts, which we think, will be relevant to your interests while you are on third party websites.

You can disable cookies that remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

3.3 Log Files

We gather certain information automatically and store it in log files. For our website, this information includes IP addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the website, track users’ movements around the website, gather demographic information about our user base as a whole, and better tailor our website to our users’ needs.

For other products and services, we collect store information about the environment, settings and other key attributes to be able to resolve issues and understand usage patterns in log files.

3.4 Google Analytics

We use Google Analytics to help analyze how users use our website. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google act as a processor on behalf of Huddly by using the data collected to provide statistics, track and monitor the use of our website.

The statistics may provide us with the following information:

• The number of visitors at our website

• The duration of the visits at our website

• Which web browsers that are used

• The website the user visited before accessing our website

Huddly may use the information from Google Analytics to improve our website.

Further, Huddly has enabled the IP address anonymisation feature (IP masking) in Google Analytics. The anonymisation takes place as early as possible when data is received by Google Analytics, before the information is stored and further processed by Google. The anonymised IP addresses are processed at an aggregate level, ie all data is collected and processed at a group-level; accordingly, the information cannot be used to identify an individual user.

The information collected by Google Analytics is stored on Google servers in the United States. Information received by Google is subject to Google's privacy policy.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Google Analytics use the following cookies:

• ‘ga’ enables the service to distinguish one user from another and lasts for 2 years

• 'gid' is used to distinguish users and expire after 24 hours.

• 'ga_<container-id>' is used to persist session state and lasts for 2 years.

We use the information we get from Google Analytics to improve our website, products and services.

3.5 Device Information

We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers) in order to understand customer environments to improve our products and services.

3.6 Audio and Video files

Upon request from our users, we may also collect audio and video files to help improve our products and services. We will never collect this information without your consent.

3.7 An overview of the cookies and similar technologies we use

Huddly may use the following cookies and similar technologies:

If you do not want cookies or other similar technologies to be stored, you can change the settings in your web browser or device. You can also delete existing cookies and similar technologies. If you choose to delete or not accept cookies, you may experience reduced functionality in the Services.

Each web browser or device has directions on how you handle cookies and related technology through data privacy- and security settings:

• Click here if you use Chrome

• Click here if you use Internet Explorer

• Click here if you use Safari

• Click here if you use Firefox

• Click here if you use Opera

• Click here if you use Microsoft Edge

If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

3.8 Do Not Track Signals

Some web browsers may transmit “do not track” signals to the websites and other online services with which your web browser communicates. We currently do not take action in response to these signals, but we may revise our Privacy Policy.

4. Storage and deletion of your personal data

We delete personal data when there is no longer a need to retain the data for the purposes for which they were collected, see section 1. If the processing of your data is needed for providing you with our products or services based on your acceptance of our terms for delivering such products or services, at the termination/cancellation of our services, we will delete all personal data we have about you within [three years], unless longer retention period is required in order for us to fulfil other legitimate purposes, such as to fulfil bookkeeping or guarantee requirements.

In so far as your processing activities are based on consent, you will be able to withdrawal your consent to these processing activities by contacting us via the contact information provided below or otherwise instructed above. In such case we will delete your data, unless the information is needed for us to fulfil other legitimate purposes. Please note that withdrawal of any consent does not affect the lawfulness of the processing that has taken place based on a consent given prior to the withdrawal.

Please note that certain types of data may be retained for a longer period if such retention is necessary to resolve disputes, enforce Huddly's user agreements or to comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services.

5. Your rights

You have a number of rights in connection with our processing of your personal data. If you have any questions or want to enforce your rights, we encourage you to contact us by using the contact information included in the bottom of this privacy policy.

Below, you can see what rights you have at all times:

• Right to access: You can request access to what personal data we have registered about you by contacting us, to the extent that this right is not restricted by applicable law. We reserve the right to require the person requesting access to verify their identity, to ensure that the personal data is disclosed to the right person. If you believe the data we hold about you are incorrect or outdated, you can request for them to be rectified, cf. below.

• Right to rectification or deletion: You can request for deletion of the personal data we have registered about you by contacting us, to the extent that this right is not restricted by applicable law. Please note that requestion for deletion about certain data categories may result in that the services you have requested no longer are available to you. We will, so far as possible, respond to a request to delete personal data, but we cannot do this if there are compelling reasons not to delete, for example, that we must store the information for documentation purposes.

• Right to withdraw consent: If you have consented to us processing your personal data in order e.g. to receive newsletters, you may withdraw this consent at any time.

• Right to object or restrict a processing activity: Subject to certain conditions, you may have the right to object to, or request that we restrict our processing of your personal data. This may be the case where we process your personal data based on our legitimate interests, for example in relation to marketing.

• Right to lodge a complaint with a supervisory authority: If you disagree with the way Huddly processes your personal data, you can lodge a complaint with the relevant supervisory authority (in Norway: Datatilsynet). We hope that you choose to contact us first, by using the provided e-mail address at the bottom of this Privacy Policy.

• Objection to automated processing: Subject to certain exceptions, you may also have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

• Provision of mandatory data: Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory. If such data is not provided, then we will not be able to manage our contractual relationship or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

6. Information security

We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including reasonable encryption and cyber security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

7. Privacy Policies of third parties

This Privacy Policy only addresses the collection, use and disclosure of personal data by Huddly. Other parties we cooperate with and other websites that may be accessible through this website have their own privacy policies and practices. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. Any links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites, and we are not in any way responsible for the content or the privacy practices employed by other third parties.

8. Changes and amendments to this policy

This Privacy Policy is subject to occasional revision. We invite you to review the latest version of this Privacy Policy.

When we update our Privacy Policy, we will update the “Last Updated” date at the top of this Privacy Policy. We may also notify you of the changes by sending you an email. If you do not agree to any of the modified terms, you must discontinue the use of our service and request to delete your account by sending an email to us, where applicable.

9. Jurisdiction and applicable law

This Privacy Policy shall, save for mandatory local law, be governed by and construed in accordance with the laws of Norway and be subject to the non-exclusive jurisdiction of the courts of Norway.

10. How to contact us

If you have any questions, concerns or comments about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, or to exercise your rights, please contact us by sending an email to the following email address:

Huddly AS

Attn: Privacy privacy@huddly.com

If you have unresolved concerns, you also have the right to complain to data protection authorities.