1 Introduction

In collecting information about you, we are acting as a data controller. In this privacy policy you can read more about why and how we collect and use your data, and about the rights you have over your data.

If you have any questions regarding this privacy policy, or about our collection and usage of your data, you can contact us by email at support@impetus.no, or by postal mail to our address at Strandgaten 32, 4400 Flekkefjord, Norway.

You can read more about us here.

We are not required to have a data protection officer. Any inquiries about our collection or usage of your personal data should be addressed to the contact details above.

2 When do we collect personal data?

In the course of providing contents, products and services to our customers and visitors to our website, we collect or receive information about you in different ways. You provide some data directly, and some data we get by collecting data about your interactions and usages with our website, products, and services. Some of this information may be collected through analytic services provided by third-party partners such as Matomo Analytics and Plausible Analytics. We do not process information outside of the EU/EEA.

We collect information in order to be able to understand, analyse and improve our websites, our products and our services. In some cases, we may require certain information in order to provide certain products and services and to ensure our services and offerings are performing optimally.

The main situations in which we collect information about you are:

• When you use our websites
• When you submit an inquiry to us via our websites, email or social media
• When you purchase a license to our products and services
• When you sign up for our email subscription list

We have listed information about each of these situations below, including:

1. What data we collect from you
2. Why we collect this information
3. Our legal basis for collecting this information
4. What we do with this information
5. How long we keep this information

In addition, we have included a section below detailing your rights as a data subject.

Our aim is that the information included in this privacy policy will provide you with sufficient information about in what situations, how and why we collect information about you. However, if you should have any questions that are not answered through this privacy policy, please feel free to contact us through the contact information listed above.

3 When you use our website

3.1 What do we collect?

When visiting our websites, we may collect information about you, how you interact with our websites, as well as send “cookies”. Cookies are small pieces of text sent by a website and stored on your computer by your web browser. A cookie allows the service or a third-party to recognise you and make your next visit easier and the service more useful to you. When you visit and log on to our websites, we send a cookie file to your computer, allowing your web browser to store your username and password so that our websites may recognise you on your next visit to our websites.

We categorise the cookies we collect for www.impetus.no into (1) necessary cookies, (2) functional cookies, (3) analytical cookies, and (4) other cookies. When visiting this website you will be presented with the option to disable/opt-out of these cookies, with the exception of necessary cookies, which are essential for the website to function properly, hereunder to ensure basic functionalities and security features of the website, but do not store any personal information.

The cookies collected through our website www.impetus.no are:

We use two different website analytics services to record usage and performance data of our websites and web-services:

• Plausible Analytics (for market.impetus.no)
• Matomo Analytics (for www.impetus.no)

Plausible Analytics

Plausible Analytics does not track, collect or store any personal data or personally identifiable information. In using this service, all collected data of traffic on Impetus Market is aggregate and anonymous, and no cookies are sent. Further information about the information collected by Plausible Analytics is available here.

Matomo Analytics

When you visit our site, we will store: the website from which you visited us from, the parts of our site you visit, the date and duration of your visit, your anonymised IP address, information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit, and more. We process this usage data in Matomo Analytics for statistical purposes, to improve our site and to recognise and stop any misuse.

We use cookies (small data files transferred onto computers or devices by sites) for record-keeping purposes and to enhance functionality on our site. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time.

3.2 Why do we collect this information?

Our use of cookies storing your username and password are used in order to optimise and streamline your user experience and usage of our websites and file server. Some cookies are necessary in order to ensure basic functionalities and security settings on our websites.

Other tracking mechanisms are essential for us in order to understand how our visitors find and use our site. We also monitor our website performance, such as what pages our visitors navigate to in order to understand how to improve our service and offerings, as well as measuring marketing efforts and user experience to ensure intended and proper functionality.

If you do not want us to track your website interactions, you may revise your cookie preferences on our website. We will not deny you access to our site or services should you choose to decline the use of such tracking mechanisms, but when declined, there may be cases where the user experience is not optimal.

3.3 Our legal basis for collecting this information

Our legal basis for collecting the cookies considered necessary are based on our legitimate interests, in reference to Article 6-1 (f) of the GDPR, as these cookies are necessary in order to ensure basic functionalities of our websites. The legal basis for collecting the information through other cookies as described in this section is based on consent, in reference to Article 6-1(a) of the GDPR and section 2-7b of the Norwegian act relating to electronic communications, as you are required to consent to our privacy policy and usage of cookies when you first visit our websites.

3.4 What do we do with your information?

We use this information strictly to streamline the user-experience of our websites and our products and services, as well as to analyse it internally in order to better understand how our users use our websites, products and services. We may use portions or aggregated numbers for marketing presentations, but we do not share or sell any information collected, even when anonymised.

3.5 How long do we keep your information?

The information we collect through cookies are stored for a maximum of the durations listed above under 3.1. The information collected through Matomo Analytics will be anonymised and kept for a maximum of 24 months.

4 When you submit an inquiry via our website, email or social media

4.1 What do we collect?

When you submit an inquiry via the contact form on our website, we ask you for your name, your company’s name, your email address and a brief description of your inquiry. If you contact us directly by email, we may ask for the same information. Additionally, we may ask for a minimum set of information in order to reply to technical or sales support questions, or other inquiries.

4.2 Why do we collect this information?

We use the information you provide in order to respond and hopefully to provide you with the information you need, including providing support or fulfilling steps required prior to entering into a contract e.g. as part of pre-sales activity. We also use this information in order to identify the organisation you represent, in order to verify that you are a real person.

4.3 Our legal basis for collecting this information

Our legal basis for processing and collecting your personal data when you contact us via our website or by email, is based on contractual obligations in reference to Article 6-1 (b) of the GDPR, in addition to consent in reference to Article 6-1 (a) of the GDPR.

4.4 What do we do with your information?

Regardless of how you contacted us, we may share your question/problem in our internal email provided by Microsoft Outlook for internal support in providing you with a solution.

4.5 How long do we keep your information?

Information you send to us via our contact form will be automatically deleted after 30 days unless the information has been forwarded in a personal dialogue in Microsoft Outlook.

5 When you purchase a license to our products and services

5.1 What do we collect?

When you purchase a license, you are required to provide your name, email address, phone number, the name of the company you are purchasing on behalf of, and the name of a contact person for the company if that person is not you.

In order to purchase a license for an object on Impetus Market, you are required to create an account on our website, and create a unique username and password for this account.

Some configurations of our software also require special export licenses issued from the Norwegian Department of Foreign Affairs. In order to apply for such a license on your behalf, we may require additional information about your company.

After your license period has ended, we will store information about which period you have been a licensee.

5.2 Why do we collect this information?

We use the contact information regarding yourself and the company you are representing in order to provide the product to which you wish to purchase a license. In order to do this we need to be able to contact you, forward an invoice to you, deliver products and services to you and send you a hardware key for the purchased software, as well as to comply with tax/revenue laws applicable to the purchase of a license. 

In order to be able to continually provide the purchased products and services to you during the license period, we need to retain this information throughout the license period.

After your license period has ended, we are legally required by applicable tax and revenue laws to retain this information for a period of 10 years. In addition to this, we need to maintain control over where any unreturned hardware keys might be located and recollected, as well as to maintain a register of where and by whom these hardware keys have been used.

5.3 Our legal basis for collecting this information

Our legal basis for collecting this information described in this section is based on our legitimate interests pursuant to Article 6-1 (f) of the GDPR, as we have a need to maintain control over both our current and previous licensees for practical, technical and security reasons. This is in turn also necessary for our fulfilment of contractual obligations towards you, pursuant to Article 6-1 (b) of the GDPR, as well as for our compliance with legal obligations (applicable tax and revenue laws), pursuant to Article 6-1 (c) of the GDPR.

5.4 What do we do with your information?

Your name, your company’s name, email address, phone number and other optional or additional information is stored in our CRM. We will not share this information with any third parties, with the sole exception of when we might have contractually agreed with you that any third party shall handle support inquiries related to your purchase/license.

5.5 How long do we keep your information?

The information collected as part of our delivery of software licenses to you is in any case stored for as long as necessary for us to comply with applicable tax/revenue laws, which is currently 10 years. Unless you notify us of a wish to have this information deleted after this mandatory period, we may keep this information for a longer period, to know where unreturned hardware keys are located, and where and by whom returned hardware keys have been used. We will never share this information with any third parties, including after your license period has ended.

6 When you sign up for our email list

6.1 What do we collect?

When you sign up for our email subscription you are required to provide your name and your email address.

6.2 Why do we collect this information?

We collect this information in order to be able to send you emails containing updates and information about the products and services that we offer.

6.3 Our legal basis for collecting this information

Our legal basis for collecting the information described in this section is based on consent, in reference to Article 6-1(a) of the GDPR.

6.4 What do we do with your information?

We store your information on our servers provided by our web server provider, with whom we have a data processing agreement with ensuring the protection of your information in accordance with this privacy policy and the GDPR. We use the information to send you emails through containing information about the products and services that we offer. We use the email list provider Mailgun, which offers additional information on its GDPR compliance here.

6.5 How long do we keep your information?

We keep your information as long as your remain subscribed to our email subscription list, and will not delete the information unless you notify us of your wish to be removed as a subscriber through clicking the unsubscribe link at the bottom of any of the subscription emails sent to you from us. If you notify us of your wish to unsubscribe, the information we have stored about you pursuant to this section will automatically be deleted.

7 Your rights as a data subject

By law, you can ask us what information we hold about you and ask to have it corrected if it is inaccurate.

If we have asked for your consent to process your personal data, you may withdraw that consent at any time, and you can request that your data be erased. Your withdrawal of consent will however not affect the legality of our collection of data before your withdrawal of consent.

If we are processing your personal data for reasons to fulfil a contract, you can ask us to give you a copy of the information you have provided for us in a machine-readable format so that you can transfer it to another provider.

You have the right to ask us to stop using your information for a period of time if you believe our processing is not lawful.

You may not ask to delete, or substantially change information regarding financial transaction data that we are required to retain for 10 years for legal, tax or accounting purposes.

To submit a request regarding personal data by email, please use the contact information provided above.

7.1 Your right to complain

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. We are not required to have a data protection officer, so for any inquiries about our use of your personal data, please use the contact information provided above.

You may also complain directly to Datatilsynet (The Norwegian Data Protection Authority), and you can find further information on how to complain here.

7.2 Legal Requirements

We might need to disclose personal data of users based on requirements by law. This might in turn also result in a need to suspend or block an account to our services. In such an event we will aim to notify the user that is affected by such actions.

Impetus may also retain, preserve, or release information in response to lawful requests by public authorities, including to meet legitimate security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of our license agreements.

7.3 Retention

Impetus will retain and use your information only as long as it is necessary for the purposes set out in this policy, and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this policy.

Specifically, Impetus will retain your information for as long as you have an active account with us, for as long as you remain subscribed to our newsletter, as needed to provide the services to you, and/or in order to maintain a register of where hardware keys are and have been located. The exception to this is data arising from a financial transaction, which we are in any case required by local tax and accounting laws to store for 10 years.

7.4 Our Policy Toward Children

Our services are not intended for users under the age of 13, and we do not knowingly collect or maintain information of such individuals. We encourage parents and guardians to monitor their children’s online activities.

8 Updates to this privacy policy

We regularly review and, if appropriate, update this privacy policy from time to time as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

We will update the version number and date of this document each time it is changed.