At FREYR doo, Ivana Hribarja 22, 4207 Cerklje, Slovenia, registration number: 8172838000 (hereinafter referred to as FREYR, “provider”, “web site manager” or “we”) thank you for your trust in us by sharing your personal information with us.
We, FREYR, promise to treat your personal information in accordance with this policy, applicable law and in accordance with your wishes. We use personal information to process your orders, to send you email newsletters that you subscribe to, or to contact you through other means for which you have given us your consent. At the same time, we use your personal information to improve our products and customer experience when shopping with us through any channel.
What is Personal Information?
Personal information is information that directly or indirectly identifies you as an individual, with meaning “indirectly” in combination with other information, e.g. with your name, mailing address, email address, phone number, location information, or other identifiers.
The purposes of processing and the basis for data processing
The provider collects and processes your personal information on the following legal bases:
- Law and contractual relations
- consent of the individual
- legitimate interest
Processing based on law and contractual relationships
Where the provision of personal data is a contractual obligation, an obligation required to conclude and perform a contract with a provider, or a legal obligation, you must provide certain personal information; If you do not provide personal data, you cannot make contract with the provider, nor can the provider perform the services or supply the products under the contract, since he does not have the necessary data to perform the contract.
Processing based on legitimate interest
The provider may also process the data based on the legitimate interest pursued by the provider, except where such interests outweigh the interests or fundamental rights and freedoms of the data subject requesting the protection of personal data. Where a legitimate interest is exercised, the provider shall always carry out an assessment in accordance with the General Data Protection Regulation.
Processing based on your consent
The Provider collects and processes (uses) your personal information, when you consent to it, also for the following purposes:
- ensuring that you access and use your online account with the provider and the provider’s online store, and for technical administration reasons on the provider’s website,
- ensuring that you have access to the specific information available to you on the provider’s website and your online account / profile provided by the provider,
- preparing and submitting a personalized e-magazine if you have subscribed to it,
- sending commercial offers and other content via email, SMS, regular mail or telephone calls, unless otherwise agreed,
- any other purpose for which you specifically agree to cooperate with the provider.
User profiling based on consent
Based on your consent, the provider also performs customized communication, which is carried out through various communication channels (via email, SMS, phone calls, mail, browser notifications, website information, social networks).
In order to offer you the best possible offers and content tailored to your needs, we design, with your consent, your profile for personalized communication.
We may use the following information for this purpose:
- Demographics (gender, date of birth or age, address)
- History of your purchases (products purchased, purchase time, number of purchases)
- Answers in various FREYR questionnaires on FREYR websites
- Behaviour on FREYR websites (viewing individual products or content, adding products to the shopping cart, online transactions)
- Your responses (opening a message, clicking on a link, buying) to the various messages we send you
Based on this profile, it may then depend on what content and offers you receive from us:
- What products and content will be presented to you to be of maximum interest to you
- What kind of offers you will receive (customers with more FREYR purchases or frequency get better deals)
- How often we will send you messages and through which channels of communication
What personal information do we collect?
In case of contact with us using the form on our site we obtain the following information:
- your first and last name
- Phone number and / or e-mail address so we can respond to your query
If you are a buyer of the products we offer in online store, we also collect other personal information about you that in order to prepare invoice and ship the products you have ordered. This personal information is:
- Name and surname;
- Address (street and house number, postal code and city)
- Contact email address;
- Contact telephone
We also collect your personal information in the following ways:
- Subscribe to newsletters – where each user subscribes to newsletters that include newsletters, news on offers, events, promotions and any other news that FREYR wants to share with you;
- Registration – FREYR offers you the option of registering so you don’t have to enter shipping information every time you place an order. It is not necessary to register for a purchase and it is your decision whether to register;
- Prize contests and prize games – various personal information is collected through prize contests and prize games, which may have additional terms as defined here. Please check the terms of participation of each prize contest and prize game before deciding to participate.
How do we use (process) your personal information?
All personal information provided is treated confidentially and used solely for the purpose for which it was provided. FREYR takes all necessary steps to protect your information through appropriate organizational measures, work processes and technological solutions, as well as with its own and external experts. In doing so, FREYR uses the appropriate level of protection and reasonable physical, electronic and administrative measures to protect the information collected from unintentional or unlawful destruction, loss, alteration, unauthorized disclosure of personal information or against unauthorized access to personal data that has been transferred, stored or otherwise treated. Access to your personal information is only allowed to staff, service providers who need this information for business reasons, or those who need it to do their part of service.
If you have ordered a product, we offer on FREYR online store, personal information is collected and processed for the purpose of entering into and executing a purchase contract, invoicing and delivery of the product.
In accordance with our legitimate business interest, which we have as a store, when you confirm your product order, we subscribe you to our newsletter in order to inform you about similar products in our offer. “E-news” is electronic news that contains educational information, news about offers, events, promotions and any other news that FREYR wants to share with you.
You have the choice of subscribing or unsubscribing to the newsletter at the link provided with the electronic order or dispatch report or thru the link contained in each e-mail message we send you.
Freyr will also use your personal information for analysis and research (such analyses and research will be conducted on the basis of pseudonyms and anonymized data where possible), which is necessary for our legitimate interest and for understanding our customers and their desires, for identifying patterns and trends, to improve the user experience, to provide information, content and offerings as per your needs, for general research, statistical and aggregate reporting purposes, for the development of new products and services, for monitoring the performance of existing products and services, for the improvement of our technology, for sending personalized advertising messages and for displaying online ads.
FREYR agrees not to sell, lend or otherwise transmit any information that you provide through the online store or in any other way to third parties, except in cases provided below and unless otherwise provided in the regulations.
FREYR will only disclose your personal information to the third parties listed below, subject to the terms and conditions set out below, and FREYR will ensure that your personal information is processed, protected and transmitted in accordance with applicable regulations.
External service providers (delivery services and others)
We respect the trust you have shown us when you have shared your personal information with us and will not share it with anyone who would like to use it for your own benefit. However, as necessary, we will authorize other companies and individuals to perform certain services that contribute to our services. For example, we may provide personal information to contractors for hosting our database and applications, for data processing services or for submitting the information you have requested, for providing support services, etc. To external service providers we will provide or make information available only to the extent required for a specific purpose. They will not be allowed to use this information for any other purpose. Third-party FREYR providers are contractually bound to respect the confidentiality of your personal information.
Freyr websites offer the ability to use plugins from different social networks. If you choose to interact (by registering on a social network account), your activities on our websites or through our applications may also be made available to those social networks based on the privacy policies that you will agree to when signing up for these social networks. If you do not want to share this information, please unsubscribe from this social media.
We will disclose your personal information to public authorities only when required by national or European Union law. FREYR will e.g. respond to requests from courts, law enforcement and other national authorities, which may include the national authorities of another EU Member State.
Based on a legitimate interest, we use your personal information to detect and prevent fraudulent use or misuse of services or subscriptions to them, and further to ensure the stable operation of our system and services, and for the purposes of implementing information security measures, meeting quality service requirements, and detecting technical system failures and service. Based on a legitimate interest, we also use your personal information for the purposes of potential enforcement, judicial and extrajudicial recovery.
Your rights regarding your personal information
Individuals may request FREYR to access, correct, delete or restrict the processing of your personal information. You also have the right to object to the processing and the right to object to the transferability of your personal data.
Right to be informed
The User always has the right to know or to process personal data concerning you and, if so, access to personal data and the following information:
- Purposes of processing personal data
- The types of personal data concerned
- Users or categories of user to whom personal information has been or will be disclosed
- The estimated period of retention of personal data or, where that is not possible, the criteria to be used to determine that period
- When personal information is not collected with your consent
Right to repair
As a user, you have the right to request correction of inaccurate personal information concerning you and, considering the purposes of the processing, the right to complete incomplete personal information.
Right of erasure
As a user, you have the right to have your personal information deleted when one of the following reasons applies:
- Personal data are no longer needed for the purposes for which they were collected or otherwise processed
- when you withdraw the consent based on which the processing takes place and when there is no other legal basis for the processing
- when you object to the processing and there are no overriding legitimate reasons for processing it
- Personal data were processed illegally
Right to limit processing
You have the right to limit the processing of your personal data when one of the following applies:
- when you dispute the accuracy of information for a period that allows us to verify the accuracy of personal data
- processing is unlawful, and you oppose the deletion of personal data and instead require a restriction on their use
- we no longer need your personal data for processing purposes, but you need them to enforce, execute or defend legal claims
- if you have raised an objection to processing based on the legitimate interests of FREYR until it is verified that our legitimate reasons outweigh your reasons
Where the processing of your personal data has been restricted in accordance with the preceding paragraph, such personal data, with the exception of their storage, shall be processed only with your consent, or for the enforcement, enforcement or defense of legal claims or for the protection of the rights of another natural or legal person.
We are obliged to inform you before the restriction on the processing of your personal data is lifted.
Right to data portability
You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable form, and the right to forward this information to another controller when processing is based on your consent or processing is performed by automated means. At your request, where technically feasible, personal data may be transferred directly to another controller.
Right to object
When we process your information on a legitimate interest for marketing purposes, you may object to it at any time.
Right to file a complaint with the Information Commissioner
If we do not decide on your request within the legal deadline or reject your request, you can file a complaint with the Information Commissioner.
Accessing and correcting your personal information and other rights
As a user of FREYR’s online store and buyer of FREYR products you have the above rights to verify that FREYR processes personal information about you and to access the personal information we hold about you. In this case we will provide them in a machine-readable PDF document. You can always request incorrect personal information about you to be corrected. Unless you believe that there is no longer a justifiable reason for continued use, please let us know in the processing of your personal information, but certain personal information we collect under the Value Added Tax Act may not be deleted. You also have the right to restrict the use of your personal data in cases where you dispute the accuracy of personal data, when you judge that processing is illegal but you do not want data to be deleted and when personal data are no longer needed for the purpose of processing, but you need them to enforce legal claims. If you subscribe to the newsletter, you have the right to object to the processing of your personal information.
If you wish to claim your described rights, please send us your request in writing by email to email@example.com. Your request will be answered within 1 month by the responsible person. In the case of complexity and multiple requests, we may extend the deadline by up to two additional months, which will be notified.
The provider will retain your personal information only for as long as it is necessary to accomplish the purpose for which the personal information was collected and further processed (eg. to ensure that you access and use your online account with the provider and the provider’s online store, for the provider’s fulfilling your orders, verifying your payments, and fulfilling other provider’s obligations and / or your obligations, to ensure that you can access the specific information available to you, to ensure that you can use the benefits of the FREYR Websites, news, etc.). The Provider retains the personal data processed by the Provider based on the law for the period prescribed by the law.
The Provider shall retain the personal data processed by the buyer for the purpose of performing the contractual relationship with the individual for the period necessary for the performance of the contract and for 5 years after its termination, except in cases where a dispute arises between you and the buyer regarding the contract. In such case, the Provider shall keep the data for 5 years after the court or arbitration award or settlement has become final or, in the absence of a court dispute, for 5 years from the date of the peaceful settlement of the dispute.
Any personal data which the Provider processes based on the personal consent of an individual or a legitimate interest shall be permanently stored by the Provider until such consent is revoked by the individual. The provider shall delete such information before cancellation only when the purpose of the processing of personal data has already been achieved or if required by law.
After the retention period has expired, the controller effectively and permanently deletes or anonymises personal data so that it can no longer be linked to a specific individual.
FREYR d.o.o. will also not delete the information it needs to provide proof that it has deleted the person’s information (i.e., audit trail) and to keep records of persons who do not want FREYR d.o.o. contacts in the future.
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Change of privacy rules