Privacy policy

Privacy policy

At Ouroboros As (”Ouroboros AS”, ”we”, ”us” or ”our”) confidentiality and data protection is a high priority. This privacy policy applies for our processing of personal data, including when you participate in online webinars hosted by Ouroboros AS through Zoom Video Communications, Inc. (“Zoom”) and for other services provided by Ouroboros AS.

The privacy policy sets out the guidelines for Ouroboros AS’ processing of your personal data and provides you with the information you have the right to receive according to applicable data protection law. You must read the privacy policy before submitting your personal data to Steinhausen as data controller.

1. Data controller and contact information
The data controller for your personal data is:
Ouroboros AS
Address: Mogata 16C, 0464 Oslo, Norway
Company registration no.: 915 80 08 82
Telephone: 0047 41 69 27 02

2. Other data controllers
If you participate in a webinar hosted by Ouroboros AS through Zoom’s website and services, Zoom will in some cases become a separate data controller of your personal data for the purpose of e.g. optimizing their services and in order to ensure that their Terms & Conditions are complied with. Zoom’s privacy policy, when acting as a separate data controller, is located on the link. Ouroboros AS is not responsible for Zoom’s processing of personal data in the role as data controller.

In other cases, Zoom is merely a data processor on behalf of Ouroboros AS with the purpose of hosting the webinars (please see section 6 below).

3. Types of personal data
The types of personal data we collect depends on your interaction with us and may comprise of:
Your name
  • Your email address
  • Your telephone number
  • Your address
  • Date of birth
  • Information about your order
  • Username
  • Password
  • Job title
  • You picture
  • You voice
  • The webinar you participated in
  • Correspondences
  • Feedback
  • Answer of surveys
Your personal data may be collected in one or more of the following cases:
  • When you use our website
  • When you participate in webinars through Zoom
  • When you sign up for a webinar or other online services
  • When you sign up for our newsletter
  • When you participate in one of our events or online services
  • When you buy a product or service
  • When you contact us
  • Inquiries to us via email, telephone or letter
  • When you give feedback
4. Use of personal data
The personal data may be collected and used for the following purposes:
  • To complete orders
  • To enter into a contract with you or your employer and to provide the services required pursuant to the contract
  • To sign up and to receive newsletters
  • To participate in events and other online services
  • To create an account at Zoom
  • To manage your registration for webinar or other online services hosted by us
  • Marketing of seminars, materials and similar
  • Sign up for events and seminars
  • Customer service and general communication
  • Compliance with requirements according to applicable law
  • For the establishment, exercise or defense of legal claims
  • Service message send outs
  • Surveys, statistics, development and protection of our services
  • Customer satisfaction survey send outs
  • Invoicing and other payment collection
  • Creating user account
  • Prevent, detect, investigate and control data breaches, fraud and other potentially illegal activities
5. Basis for processing your personal data
Our legal bases for the processing of your personal data for the above purposes are:
  • Fulfilment of contract for the purchase of products or services (Article 6(1)(b) of the GDPR)
  • Fulfilment of contract in order to use Zoom’s services (Article 6(1)(b) of the GDPR)
  • Our legal obligations as data controller (Article 6(1)(c) of the GDPR)
  • Consent to newsletter send out (Article 6(1)(a) of the GDPR)
  • Legitimate interest in being able to share your personal data with other participants if you participate in a webinar or other online services hosted by us (Article 6(1)(f) of the GDPR)
  • Legitimate interest in being able to compile statistics, conduct surveys, improve and develop our services and products (Article 6(1)(f) of the GDPR)
  • Legitimate interest in being able to send out service messages (Article 6(1)(f) of the GDPR)
  • Legitimate interest in being able to send out customer satisfaction surveys (Article 6(1)(f) of the GDPR)
  • Legitimate interest in being able to establish, exercise or defense legal claims (Article 6(1)(f) and Article 9(2)(f) of the GDPR)
  • Legitimate interest in being able to collect and administrate your personal data (Article 6(1)(f) of the GDPR)
6. Disclosure to other data controllers and transfer to data processors
To fulfil the above purposes, we may provide access to your personal data for third parties who, on the basis of a contractual relationship with Ouroboros AS provide relevant services, e.g. IT-providers (e.g. Zoom and Zoom’s subcontractors, Calendly), invoicing providers, and email providers (e.g. Mailchimp and MailChimp’s subcontractors). Such service providers will only process personal data in accordance with our instructions pursuant to the data processor agreements entered into.
Aside from above, it is a general rule that your personal data is not disclosed to a third party without your permission. However, under certain circumstances and in accordance with applicable law, we may need to disclose your personal data to police, lawyers, auditors, courts and public authorities.
If your personal data is transferred to data processors (e.g. Zoom and Zoom’s subcontractors) or data controllers established in countries outside the EU/EEA which does not have an adequate level of protection, such transfer will be based on the EU Commission’s standard contracts or Privacy Shield certification.

7. Deletion of personal data
We will delete your personal data when we no longer need to process them in relation to one or more of the purposes set out above.
If you participated in a webinar, we will as a main rule delete your personal data 3 years after participation. Bookkeeping material will as a main rule be contained in 5 years from closing of the current financial year. Correspondences will as a main rule be kept 5 years from registration, if it is necessary to document orders. Contact information etc. will as a main rule be kept in 2 years from last contact. Consent for marketing will be kept in 2 years from the last time marketing was forwarded or from the time consent was withdrawn.
However, we will at all times make a specific assessment as to how long it is actually necessary and reasonable to store the personal data and data may be processed and stored for a longer period in anonymized form.

8. Confidentiality for webinars
Please be aware that when participating in webinars and other online services hosted by Ouroboros AS, all personal data you may access of other participants must be handle strictly confidential. This involves especially that no personal data of other participants may by shared with third parties and that it is forbidden to record and film the webinars and other online services provided by Ouroboros AS.

9. Security
We and our service providers protect the confidentiality, integrity and accessibility of your personal data. Hence, we and our service providers have implemented security measures to ensure that our internal procedures meet the established security standards and applicable legal requirements.
We and our service providers have internal rules on information security that contains instructions and measures to protect your personal data from being destroyed, lost or altered, against unauthorized disclosure, and unauthorized access to and knowledge of them.

10. Your rights
  • You have the right to access the personal data we process about you
  • You have the right to object to our collection and further processing of your personal data
  • You have the right to have your personal data rectified and deleted, with certain statutory exceptions, including the Bookkeeping Act
  • You have the right to request us to restrict the processing of your personal data
  • Under certain circumstances you may also request to receive a copy of your personal data as well as the transmission of your personal data which you have provided us with to another data controller (data portability)
  • You may, at all times, withdraw any consent you may have given. We will then delete your personal data, unless we can continue the processing on another basis.
11. Questions or complaints
If you have any questions in relation to this privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us:
Ouroboros AS
Address: Mogata 16C, 0464 Oslo, Norway
Tel.: 0047 41 69 27 02

If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to Datatilsynet, Postboks 458 Sentrum, 0105 Oslo, Norway

If you are participating in a webinar and have any technical question, please contact Zoom.

12. Changes to the privacy policy
We reserve the right to make changes to this privacy policy from time to time. When updated, the date at the bottom of the privacy policy will be updated accordingly. The, at all times, applicable privacy policy will be available at our website www.ouroboros.works. In the event of significant changes, you will be notified via email.
 
Approved
Changes
1.0
Jasper Steinhausen April 13, 2020
N/A


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