FOX SUBSEA Privacy policy 

Updated: 01.03.2023

1. INTRODUCTION

This Privacy Policy («Privacy Policy«) has been prepared by FOX Subsea AS («FOX Subsea«, «we«, or «us«) to ensure that you receive the information we are required to provide to you – and which is necessary for you to exercise your rights under the General Data Protection Regulation (the «GDPR«) and Norwegian data protection legislation (together «data protection legislation«).

This Privacy Policy describes how we process personal data about you, the purpose of our processing activities, and the legal basis for our processing activities. This Privacy Policy also describes your rights in connection with our processing of your personal data under applicable data protection legislation. As a «data controller», FOX Subsea is responsible for processing the personal data we collect in connection with provisioning of our services and products in compliance with the data protection legislation.

 2. GENERALLY ABOUT PERSONAL DATA

Personal data means any information relating to an identified or identifiable natural person (a «data subject«). For example, it may be the name, place of residence, phone number, email address and IP address, or a combination of these, which allows you to track who is behind the data.

All use of personal data is considered as processing of personal information, such as collection, registration, assembly, storage and disclosure or a combination of these.

3. OUR PROCESSING OF PERSONAL DATA

3.1 Processing activities and the purpose of the processing activities
The following list includes information about the personal data which we process, and the purposes which the personal data is processed for:

• Business associates. We process personal data about representatives of our business associates (e.g., customer, partners and suppliers), in order to administer and fulfil the agreements we have entered into and to provide our service to our customers. Such personal data include the representative’s name, telephone number, email address, position, employer and place of work. Furthermore, it may include the data subject’s signatories included in the agreements we have entered.

• Visitor management. We process personal data concerning visitors to the company’s premises for the purpose of visitor management. Such personal data include the name and contact details of the visitors.

• Generation of statistics. We use cookies to generate statistics to improve the functionality and performance of our services and website. However, this information will not be used to analyse user behaviour at an individual level. Please refer to section 10 below for more information about the cookies we use on our website.

• Newsletters. We may process personal data, including name and contact information, for marketing purposes in connection with sending newsletters to our business associates.

• Recruitment. We process the personal data of job applicants primarily to assess the applications we receive and to consider potential candidates for available positions. If you apply for employment with us, we will process the personal data you submit to us, typically your job application, CV, references, diplomas, certificates, photo and contact information. If we contact you because we have an interest in your applying for a job with us, we will process publicly available personal data about you that are relevant for the recruitment process (such as your contact information, information about your qualifications, experience, current and former employers). Normally, we will also collect additional information about you as the employment process proceeds, such as in connection with interviews, tests and contacting your references.

The personal data that we collect, and process are primarily obtained directly from the data subject or generated through the data subjects use of our website (cookies).

Depending on the circumstances, we may also process other categories of personal data, and/or the above listed personal data for other purposes. This may for example be the case if you contact us with questions or comments.

You may at any time request confirmation and/or information regarding the personal data which we process about you, by contacting us as described below.

3.2 Our legal basis for processing personal data
We will rely on the following legal bases for our processing of the personal data described above:

• Business associates. We process personal data about the representatives and contacts of our business associates based on our legitimate interest in administering our customer, supplier, and partner relationships, as well as in storing signed versions of agreements we have entered into.

• Visitor management. We have a legitimate interest in keeping account of the persons that have visited the company’s premises.

• Generation of statistics. Our use of cookies is based on your consent provided through our cookie-banner.

• Newsletters. If your employer has an active customer relationship with FOX Subsea, we may send you certain marketing by e-mails or other electronic communication within the scope of the Marketing Act, unless you have requested for anything else. If your employer does not have an active customer relationship with us, we will only send such marketing if you have given us an explicit and informed consent. You may unsubscribe to newsletters at any time by using the «unsubscribe-button» included in all such e-mails/communication.

• Recruitment. We have a legitimate interest in finding new employees, as well as in assessing job applications we receive.

4. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We use external service providers to assist with IT services and other administrative services. These service providers will act as processors on our behalf. We have entered into data processing agreements with our processors contain obligations for the data processor to implement technical and organizational measures to ensure an appropriate level of security, confidentiality, and integrity for the personal data, as well as to only process the relevant personal data in accordance with the data protection legislation and our instructions.

We will not disclose your personal data to any other third parties than the third parties described above, unless we are required to do so under applicable law, or if it is necessary to establish, exercise or defend legal claims.

If any of our data processors are in countries outside the EU/EEA, we will ensure that the personal data is adequately secured, for example by entering into Standard Contractual Clauses («SCC«) issued by the European Commission.

5. OUR ANALYSIS AND THIRD PARTY TOOLS

FOX Subsea uses analysis tools to collect information about how our services are used. We use Google Analytics, where we measure the number of visitors, which pages are visited, how long a visit lasts and the like.

Statistics on users and traffic are usually used and used in aggregated form, so the statistics do not contain any information that can be linked directly to you as an identified person. IP-addresses are anonymous.

6. RETETNION OF PERSONAL DATA

We will delete or anonymize personal data when they are no longer necessary in relation to the purposes for which they were collected or otherwise processed. For instance, we delete personal data in accordance with the criteria included below:

• Bookkeeping material is kept for 3½ or 5 years in accordance with the Norwegian Bookkeeping Act.

• Personal data collected by FOX Subsea for the purpose of administrating contracts with customers and suppliers/partners (including financial advisors, attorneys etc.), may be stored throughout the companies lifetime if such personal data are included in the contract. The company has a legitimate interest in knowing such history beyond the contractual relationship.

• Personal data stored for the purpose of administrating customer, supplier, and partner relationships, shall be deleted [five (5) years] after the customer/partner/supplier relationship has ended.

• Personal data collected by FOX Subsea for visitor management purposes shall be deleted [three (3) months] after the relevant visit.

7. SECURITY

As a controller, FOX Subsea is responsible for the security and confidentiality of the personal data we process. We are furthermore responsible for implementing appropriate technical and organizational measures to ensure an appropriate level of security of processing.

We are for security reasons not entitled to disclose detailed information on the security measures which we have implemented. However, all of our employees are bound by a duty of confidentiality with respect to the personal data which we process. Furthermore, we have implemented measures, policies, and routines to ensure the security of our processing.

8. YOUR DATA PROTECTION RIGHTS

Under the data protection legislation, you have certain rights we need to make you aware of. You have the following rights in connection with our processing of your personal data:

• Access: You may contact us if you want to obtain confirmation with respect to whether we are processing your personal data, as well as access to and further information regarding our processing of your personal data. You may also request a copy of the personal data we are processing about you.

• Rectification: You may request us to rectify and/or complete inaccurate or incomplete personal data.

• Erasure: You may request that we delete your personal data. We will respect and comply with your request insofar as there are no other legal obligations or overriding legitimate interests requiring further retention, or the personal data is necessary for the establishment, exercise, or defense of legal claims.

• Restriction of processing: You may also request the restriction of our processing of your personal data in accordance with data protection legislation. If the processing has been restricted, such personal data will, except for storage, only be processed with your consent, for the exercise or defense of legal claims, the protection of the rights of another person, or for reasons of important public interest.

• Right to object: You are entitled to object to certain processing activities, including for example processing of your personal data for marketing purposes. You are furthermore, on grounds relating to your particular situation (for example, a specific need for protection of your identity), entitled to object to processing of personal data based on legitimate interests, which we will comply with, unless there exists compelling legitimate grounds for our processing which override your interest, or if our processing is necessary for the establishment, exercise or defense of legal claims.

• Data Portability: If we process your personal data based on consent or based on our performance of a contract, and the processing is carried out by automated means, you may request us to transfer the personal data to you or another controller, in a structured, commonly used, and machine-readable format.

Certain limitations exist in the rights provided by the data protection legislation and the rights available to you will depend on the circumstances of the processing.

You may contact us at any time if you have any questions or complaints regarding our processing of your personal data. You may also file a complaint to the Norwegian Data Protection Authority, or a data protection authority in the EU/EEA Member State of your habitual residence, place of work, or the place of the alleged data protection infringement. The Norwegian Data Protection Authority is responsible for supervising Norwegian organizations’ processing of personal data.

You can obtain the contact details of the Norwegian Data Protection Authority on the following website: www.datatilsynet.no.
You will also find more information on your rights and the data protection legislation on this website.

9. COOKIES

9.1 What are cookies?
Cookies and similar technologies are very small text documents or pieces of code that often contain a unique identification code. When you visit a website or use a mobile application, a computer asks your computer or mobile device for permission to save this file on your computer or mobile device and gain access to information. Information collected through cookies and similar technologies may include the date and time of the visit and how you use a particular website or mobile application.

9.2 What type of cookies do we use?
Necessary cookies. These cookies are necessary for the website to function properly. Some of the following actions can be performed by using these cookies. – Store articles in a shopping cart for online purchases- Save your cookie preferences for this website- Saving language preferences- Log in to our portal. We need to check whether you are logged in.

Performance cookies. These cookies are used to gather statistical information about the use of our website, also called analytics cookies. We use this data for performance and website optimization.

Functional cookies. These cookies enable more functionality for our website visitors. These cookies can be set by our external service providers or our own website. The following functionalities may or may not be activated when you accept this category. – Live chat services- Watch online videos- Social media sharing buttons- Login to our website with social media.

Advertising/tracking cookies. These cookies are set by external advertising partners and are used for profiling and tracking data across multiple websites. If you accept these cookies, we may show our advertisements on other websites based on your user profile and preferences. These cookies also save data about how many visitors have seen or clicked on our advertisements to optimize advertising campaigns.

9.3 How can you switch off or remove cookies?
You can choose to opt out of all but the necessary cookies. In the settings of the browser, you can change the settings to ensure that cookies will be blocked. Most browsers provide you with an explanation on how to do this in the so-called ‘help-function’. However, if you block the cookies, it is possible that you will not be able to enjoy all the technical features our website has to offer, and it may negatively affect your user experience.

9.4 The cookies we use on our website.

Necessary

Performance

 This cookie policy has been created and updated by CookieFirst.com.

10. CHANGES TO THIS PRIVACY POLICY

We may from time-to-time update the Privacy Policy for FOX Subsea’s services, to reflect any changes in our processing activities, applicable data protection legislation or other legislation which may affect our processing of personal data. When we update the Privacy Policy, the updated version will be published on our websites.

11. CONTACT

If you have questions about this Privacy Policy, including how we process personal data, or would like to submit a request to exercise your rights, please contact us at:

Email: post@foxsubsea.no