VEWD PRIVACY STATEMENT

Vewd Software AS

Last Updated: May 23, 2018

We, Vewd Software AS, aim for full transparency about the personal data we process when you use our services. In this Privacy Statement, we explain, among other things, what information we collect, why we collect it, and how we use the information.

The Privacy Statement applies to both end users of our services and to individuals acting on behalf of our customers and partners.

The Privacy Statement covers the following Vewd products and services:

  • Vewd Core
  • Vewd Browser
  • Vewd Snap
  • Vewd Certify
  • Vewd App Store
  • Advertising

When we post changes to this Privacy Statement, we will include the date when the Privacy Statement was last updated. We encourage you to review the Privacy Statement periodically. In case of bigger changes, we will try to notify you directly as appropriate.

1. What data we collect

Data relating to end users

Some of the information we process may be considered personal data under applicable privacy legislation. This includes:

  • IP-addresses (which we anonymize as soon as we collect them),
  • Location (will be aggregated at a regional level, for example city, town or other large geographical area).
  • User interaction with our products and services by use of Google Analytics. These interactions are anonymized and the exact location removed before processing by Google Analytics
  • Vewd device ID (collected only from third party electronic products where we present a user interface or an app on such device)
  • Email (if you choose to subscribe to our newsletter)
  • Cookies – please see our cookie policy
Customers and partners
  • E-mail
  • Name
  • Telephone number
  • Title
  • Employer information
  • IP-address
  • Cookies – please see section 9 and our cookie policy

2. Why we process personal data and the legal basis for our processing

We only process your data for purposes that are objectively justified by our products and services, and only as stated in this Privacy Statement. We process this data with respect to your right to privacy, including the need to protect personal integrity and private life and to ensure that your personal data is adequately protected against the risk of loss, misuse and unintended alteration.

Unless you are offered the option to provide prior consent to our use of your data, we process your data with legal basis in the Norwegian Personal Data Act Section 1, cf. the EU General Data Protection Regulation (GDPR) Article 6 no. 1 litra (b) (because it is necessary for us to be able to provide our services to you), litra (c) (because it is necessary for compliance with a legal obligation), or litra (f) (because it is necessary for us in order to pursue a legitimate interest and this interest is not overridden by your interest in us not processing the data).

End users

We collect data for the following purposes:

  • Improve, debug, and maintain our products and services
  • Product development and improvement of the user experience
  • Health checks, service updates and access control
  • Provide search functionality using Google search
  • Speed dial links
  • Measure activity with content apps provided through our service
  • Serve ads in the content apps based on your location
  • Fulfill legal requirements
Customers and partners

We collect data to:

  • Administer your access to our certification and developer tools, including to see how you interact with these tools
  • Administer your content/apps access or submission rights
  • Send you service messages
  • Send marketing relevant to your relationship with Vewd
  • Monitor your interaction with marketing content that you have received
  • Fulfill legal requirements

3. How we collect data

Generally, we collect data:

  • When you provide it explicitly to us, for example when you submit a form on our websites
  • When you log on to use those of our service requiring login
  • When you use our products and services, including when you use our services embedded in third party electronic products such as TVs and set-top boxes
  • If third parties share your data with us

When we collect your data at end user level, we associate it with a Vewd Device ID and an IP-address.  The IP-address is anonymized when we receive it.

To collect information automatically, we use cookies, web beacons, our own data-collection tools or various third-party services.

4. Third party websites and services

Some third-party sites may monitor data traffic from our products and services, such as numbers of hits. We do not make available any personally identifiable information to these services.

The user interfaces of Vewd Browser, Vewd Snap and Vewd App Store may seamlessly include and display third party content originating on servers that are not under our direct control (e.g. lists of videos, images, video content, etc.) Such content is retrieved using web technologies, similar to those used within any website; you should be aware that in the process of retrieval, some third parties can collect your IP address, and store cookies on your device.

This Privacy Statement does not cover third-party content, apps or websites you access or use through our products and services. We do not control the privacy and security practices or policies of these third parties and their apps/sites. We encourage you to read the privacy statements which apply to the third-party content, apps and websites you use.

Here is a list of third parties that we use:

Service Name Purpose Privacy policy
Google Analytics Provide analytics services https://policies.google.com/privacy
Amazon Web Services Web hosting https://aws.amazon.com/privacy
SpotX Advertising https://www.spotx.tv/privacy-policy
HubSpot Marketing and marketing analytics https://legal.hubspot.com/privacy-policy
LinkedIn Marketing https://www.linkedin.com/legal/privacy-policy
Facebook Marketing https://www.facebook.com/policy.php
Twitter Marketing https://twitter.com/en/privacy

5. Information security – how we protect your data

We have implemented organizational and technical procedures and measures that will ensure that your personal data is not compromised, not unintentionally changed, and available when required. Such measures includes for example access restrictions and controls, back up routines, and disaster recovery routines.

We review and update our working procedures regularly to improve your privacy and ensure that our internal policies are followed. We strive to promptly correct any non-conformance with these policies.

6. How we share your data

We may share your data:

  • To government bodies and law enforcement agencies to comply with the law, for example in judicial proceedings, by court order or other legal process;
  • To third parties (including professional advisors) to enforce or defend our legal rights, including our terms of service and/or end user license agreement;
  • To a third-party purchaser or seller (including professional advisors) in connection with a corporate event such as a merger, business acquisition or insolvency situation;
  • To data processors processing the data on our behalf, such as advertising networks, cloud storage providers and providers of analytics services; and
  • As described elsewhere in this statement.

Some of our products and services include third-party technology or code that may use the collected data. We may share anonymized and/or aggregated sets of data with our partners and other trusted third parties.

Your data may be transferred to countries which do not have the same level of data protection laws as those in the EU. If we transfer personal data to processors or other controllers who are not located in the EU or otherwise not approved as safe countries by the EU, such transfer is safeguarded by entry into of the EU’s standard contractual clauses for transfer of personal data to third countries. Processors located in the USA may alternatively be Privacy Shield certified.

7. Retention and deletion

We retain personal data only as long as necessary for processing it in accordance with the purposes described in this statement, or as otherwise necessary to comply with applicable laws. When your data is no longer necessary or relevant for our purposes, or required by applicable laws, we take steps to have it deleted, aggregated or made anonymous.

You can find out if we hold any personal data about you by contacting us. You may be asked to prove your identification so that we can verify who is making the request. If we hold information about you, you can ask us to correct any mistakes and delete any excessive information.

8. Access, correction and deletion of personal data

You have the right to access the personal data we have registered about you. For profile information, if any of the information we have registered about you is incorrect, we encourage you to make changes to your profile. You may also withdraw any consents you have given at any time. Feel free to contact us for assistance.

9. Cookies

We use cookies and other similar technologies to enhance the user experience and make the most effective use of the service. A cookie is a piece of data sent from an online site that is visited and stored locally on the user’s browser. The purpose for using cookies is to maintain data related to device identity, device-level preferences, user accounts, account settings, user preferences as well as to evaluate and compile statistics about user activity. Most browsers accept cookies as default. For Vewd Snap and Vewd App Store you cannot decline cookies as the use of cookies is inherent to the technology. Please see our cookie policy for more information: https://www.vewd.com/cookie-policy.

10. Your right to file a complaint

If you believe that we process your data in violation of your rights, you have the right to complain to the Norwegian Data Inspectorate (NW: “Datatilsynet). You should always contact us directly before sending a complaint to the Norwegian Data Inspectorate, so that we can try to solve or clarify the issue.

11. Controller and contact information

Vewd Software AS, organization number 916 368 011, Fridtjof Nansens Plass 5, 0160 Oslo, Norway is the controller of personal information processed under this Privacy Statement.

If you have any questions about the Privacy Statement or any other questions regarding our privacy practices, please contact us at: privacy@vewd.com.