Last updated February 20, 2023

This privacy policy for Norarm AS (“Company”, “we”, “us” and “our”) describes how and why we may collect, store, use and/or share (“process”) your information when you use our services (“Services”), for example when you:

• Visit our website at https://norarm.com, or any website of ours that links to this privacy policy
• Contact us in other related ways, including sales, marketing or events

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, you can contact us at contact@norarm.com.

SUMMARY OF KEY POINTS

This summary contains key points from our privacy policy, but you can find more details about each topic by clicking the link after each key point or by using the table of contents below to find the section you are looking for.

What personal data do we process? When you visit, use or navigate our Services, we may process personal data depending on how you interact with Norarm AS and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal data? We do not process sensitive personal data.

Do we receive information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal basis to do so.

In what situations and with which parties do we share personal data? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal data. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to circumvent our security and improperly collect, access, steal or alter your information.

What are your rights? Depending on your geographical location, applicable privacy legislation may mean that you have certain rights regarding your personal data.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data protection request form, or by contacting us. We will consider and act on any request in accordance with applicable privacy laws.

Want to learn more about what Norarm AS does with the information we collect? Review this notice in its entirety.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASIS DO WE USE TO PROCESS YOUR PERSONAL DATA?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE RETAIN YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal data you provide to us

In short: We collect personal data that you provide to us.

We collect personal data that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services, when you participate in activities on the Services, or otherwise when you contact us.

Personal data provided by you. The personal data we collect depends on the context of your interaction with us and the Services, the choices you make, and the products and features you use. The personal data we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Contact preferences
• Contact or authentication data
• Billing addresses
• Job titles

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by PayPal. You can find the link(s) to their privacy policy here: https://www.paypal.com/us/legalhub/privacy-full.

All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data.

Information collected automatically

In short: Some information – such as your IP address and/or browser and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (such as your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily necessary to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and usage data. Log and usage data is service-related, diagnostic, usage and performance information that our servers automatically collect when you access or use our Services, and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, as well as information about your activity in the Services (such as date/time stamps associated with your use, pages and files viewed, searches and other actions you perform, such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device data. We collect device data, such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile operator, operating system and system configuration information.
• Location data. We collect location data, such as information about your device’s position, which may be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current position (based on your IP address). You can opt out of our collection of this information either by refusing access to the information or by disabling your device’s location settings. However, if you choose to opt out, you may not be able to use certain parts of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal data for a variety of reasons, depending on how you interact with our Services, including:

To preserve or protect a person’s vital interests. We may process your information when necessary to preserve or protect a person’s vital interests, for example to prevent harm.

3. WHAT LEGAL BASIS DO WE USE TO PROCESS YOUR PERSONAL DATA?

In short: We only process your personal data when we believe it is necessary and we have a valid legal basis (i.e., legal grounds) to do so under applicable law, for example with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or the United Kingdom, this section applies to you.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases we use to process your personal data. Accordingly, we may rely on the following legal bases to process your personal data:

• We may process your information if you have given us consent (i.e., permission) to use your personal data for a specific purpose. You may withdraw your consent at any time.
• Legal obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as to cooperate with law enforcement or a regulatory authority, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to a person’s safety.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific consent (i.e., express consent) to use your personal data for a specific purpose, or in situations where your consent may be inferred (i.e., implied consent). You may withdraw your consent at any time.

In some exceptional cases, we may have lawful consent under applicable law to process your information without your consent, including for example:

• If the collection is clearly in the interest of an individual and consent cannot be obtained in a timely manner
• For investigation, detection and prevention of fraud
• For business transactions provided that certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process or settle an insurance claim
• To identify injured, ill or deceased persons and communicate with next of kin
• If we have reasonable grounds to believe that an individual has been, is or may be a victim of financial abuse
• If it is reasonable to expect that collection and use with consent would compromise the availability or accuracy of the information, and the collection is reasonable for purposes related to investigating a breach of an agreement or a violation of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or court rules relating to the production of records
• If it was produced by an individual in the course of their employment, business or profession, and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic or literary purposes
• If the information is publicly available and specified in the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal data in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. HOW LONG DO WE RETAIN YOUR INFORMATION?

In short: We retain your information for as long as necessary to fulfill the purposes described in this privacy policy, unless otherwise required by law.

We will only retain your personal data for as long as necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (for example, tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal data is stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We aim to protect your personal data through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal data we process. Despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal data, transmission of personal data to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old, or that you are the parent or guardian of such a minor and consent to the minor’s use of the Services. If we learn that personal data from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18 years of age, please contact us at contact@norarm.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In some regions, such as the European Economic Area (EEA), the United Kingdom and Canada, you have rights that give you greater access to and control over your personal data. You may review, change or terminate your account at any time.

In some regions (such as the EEA, the United Kingdom and Canada), you have certain rights under applicable data protection legislation. These may include the right to (i) request access to and obtain a copy of your personal data, (ii) request rectification or erasure; (iii) restrict the processing of your personal data; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of your personal data. You can make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act on any request in accordance with applicable data protection laws.

If you are located in the EEA or the United Kingdom and believe that we are unlawfully processing your personal data, you also have the right to complain to your local data protection supervisory authority. You can find their contact information here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, you can find the contact details of the data protection authorities here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawal of your consent: If we rely on your consent to process your personal data, which may be express and/or implied consent depending on applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

Please note, however, that this will not affect the lawfulness of the processing before the withdrawal, nor, where applicable law permits, will it affect the processing of your personal data carried out on the basis of lawful processing grounds other than consent.

Opting out of marketing and advertising communications: You can unsubscribe from our marketing and advertising communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this may affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you can email us at contact@norarm.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes, if you are a resident of California, you have specific rights regarding access to your personal data.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal data (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared personal data in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information below.

If you are under 18 years of age, reside in California and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will ensure that the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose, and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal data.

What categories of personal data do we collect?

We have collected the following categories of personal data in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name	YES
B. Personal information as defined in California Customer Records statute	Name, contact information, education, employment, employment history and financial information	YES
C. Protected classification characteristics under California or federal law	Gender and date of birth	NO
D. Commercial information	Transaction information, purchase history, financial details and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history and professional qualifications if you apply for a job with us	NO
J. Education information	Student records and directory information	NO
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal data listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive personal information		NO

We will use and retain collected personal data as needed to provide the Services or for:

• Category A – Unspecified
• Category B – Unspecified
• Category D – Unspecified

We may also collect other personal data outside of these categories through instances where you interact with us in person, online, or by phone or mail in connection with:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy policy.

You may contact us by email at contact@norarm.com, or by referring to the contact details at the bottom of this document.

If you use an authorized agent to exercise your right to opt out, we may decline a request if the authorized agent does not present proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal data to our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy obligations mandated by the CCPA.

We may use your personal data for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

Norarm AS has not disclosed, sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Norarm AS will not sell or share personal information belonging to website visitors, users and other consumers in the future.

Your rights with respect to your personal data

Right to request deletion of the data – Request to delete

You may request deletion of your personal data. If you ask us to delete your personal data, we will respect your request and delete your personal data, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed – Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal data;
• the categories of personal data that we collect;
• the purposes that the collected personal data is used for;
• whether we sell or share personal data to third parties;
• the categories of personal data that we sold, shared or disclosed for a business purpose;
• the categories of third parties to whom the personal data was sold, shared or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling or sharing personal data; and
• the specific pieces of personal data we have collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to non-discrimination for the exercise of a consumer’s privacy rights

We will not discriminate against you if you exercise your privacy rights.

Right to limit use and disclosure of sensitive personal data

We do not process consumers’ sensitive personal data.

Verification process

Upon receiving your request, we must verify your identity to determine that you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided to us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal data provided in your request to verify your identity or your authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification purposes. If, however, we cannot verify your identity from the information already maintained, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal data.
• You may request correction of your personal data if it is incorrect or no longer relevant, or request to restrict the processing of the data.
• You can designate an authorized agent to submit a request under the CCPA on your behalf. We may decline a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out of the future sale or sharing of your personal data to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at contact@norarm.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal data.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

“Consumer” means a natural person who is a resident of the Commonwealth and is acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use and disclose about you will vary depending on how you interact with Norarm AS and our Services. To find out more, please visit the following links:

• Personal data we collect
• How we use your personal data
• When and with whom we share your personal data

Your rights with respect to your personal data:

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you have previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Norarm AS has not sold any personal data to third parties for business or commercial purposes. Norarm AS will not sell personal data belonging to website visitors, users and other consumers in the future.

Exercise your rights under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy policy.

You may contact us by email at contact@norarm.com, by visiting our data subject request form, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may decline a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receipt of your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and the reasoning behind it. If you wish to appeal our decision, you can email us at contact@norarm.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you can email us at contact@norarm.com or by post to:

Norarm AS

Industriveien 16, 1481 Hagan, Norway

___________, Akershus 1481

Norway

15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal data we collect from you, change that information, or delete it. To request to review, update, or delete your personal data, please submit a request form.