Privacy Statement

Last Update: April 2022

We are very delighted that you have shown interest in our enterprise. Digtective Holding AS (hereinafter “Digtective”) develops software solutions for website tracking based on Cookieless Server Side Tracking. Digtective provides software as a Service (“SaaS”) to businesses. Digtective operates the website to showcase its products and tell its story. The URL of the website is: https://digtective.com (Digtectives website).

For the purposes of this Privacy Policy and within the meaning of the General Data Protection Regulation (“GDPR”), other data protection laws applicable in Member states of the European Union, and other provisions related to data protection, the Controller in relation to the Digtective website is Digtective.

This Privacy Policy describes the types of personal data collected, how such data is being used as well as what are your rights and choices in relation to your personal data processed when you visit the Digtective website and interact with it. The website is not intended for children, and we do not knowingly collect data relating to children. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they may be accessible through the Digtective website.

1. Personal data we collect and process

The term “personal data” is defined by the GDPR as any information relating to an identified or identifiable natural person (“data subject”). Personal data is any data that allows you to be identified or that can be linked to you.

We collect and process personal data you voluntarily submit to us, as well as information provided automatically by your browser or mobile device when you visit the Digtective website.

Typically, we may collect and process the following categories of data:

• your first and last name;
• your contact information, such as telephone and e-mail address;
• your business information, such as company name and type;
• you’re opt-in to receive our marketing materials, such as promotions and newsletters;
• operating system;
• browser type;
• browser version;
• browser configuration;
• any other relevant information regarding your computer and Internet connection in order to identify the type of your device, to connect you to the website, to exchange data with your (mobile) terminal device, or to ensure the proper use of the website;
• the URL and IP address of the website from which you access the Digtective website or from which you are transferred to our website, including date and time;
• any pages of the Digtective website on which you click during your visit, and any links on our website on which you click, including date and time;
• the entire Uniform Resource Locator (URL) clickstream regarding, through, and from the website, including date and time;
• information collected by cookies or similar technologies (as explained below)
• any other similar data and information that may be used in the event of cyber-attacks on our information technology systems.

2. Cookies

Read about how we use cookies in our Cookie Policy.

3. How we use personal data

Digtective does not draw any conclusions about the visitors to the website. Rather, this information is processed for the following purposes:

• deliver the content of the Digtective website correctly,
• optimize the content of our website as well as its advertisement,
• ensure the long-term viability of our information technology systems and website technology.

To help improve the performance of the website, as well as develop new features and functionality we collect and analyze usage information. Processing personal data for analytics purposes is done in an anonymized form. In doing so we aim to increase data protection and data security to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

4. Our legal bases for the processing of personal data

We collect and process personal data in accordance with the requirements of Articles 6, 13, and 14 of the GDPR, relying on the following legal bases:

• performance of Digtective services, Art. 6(1)(b);
• legitimate interest relating to our services, Art. 6(1)(f);
• your explicit consent to process your data, Art. 6(1)(a);
• our necessity to comply with a legal obligation Art. 6(1)(c).

We may also process the data if it is necessary to protect the vital interests of our users and/or other people or for the performance of an obligation to carry out in the public interest pursuant to Art. 6(1)(d) and (e).

5. Contact possibility via the website

The website of Digtective contains information that enables quick electronic contact with Digtective, as well as direct communication with us, which also includes a general e-mail address. If a data subject contacts Digtective via e-mail or a contact form, the personal data transmitted as the result are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of contacting the data subject.

6. Period of retention of personal data

Your personal data will be stored for as long as this is necessary for achieving the defined purposes of the processing. After the expiration of that period, the corresponding data is routinely erased as long as it is no longer necessary for the initiation or the fulfillment of the contract. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another authorized legislator expires, the personal data are routinely erased in accordance with legal requirements.

7. Third-party disclosure

We use a select number of trusted external service providers for certain technical data analyses and processing and/or storage offerings (e.g., IT and related services). We may also use the assistance of third parties to improve our website as well as certain tools for our marketing. These third-party service providers are carefully selected and meet high data protection and security standards. We contractually obligate them to keep any information we share with them confidential and to process personal data only according to our instructions. The legal basis for such processing would be legitimate interest pursuant to Art. 6(1)(f) GDPR.

In addition to service providers, other categories of third parties may include:

• Vendors/public institutions. To the extent that this is necessary in order to make use of certain services requiring special expertise (such as legal, accounting or auditing services) we may share personal data with vendors of such services or public institutions that offer them (e.g. courts). The legal basis of this data processing is Art. 6(1)(f) GDPR.
• Disclosure in the event of organizational changes. We may disclose personal data to allow a change of ownership of Digtective (including, but not limited to, an acquisition by or a merger with another company, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of services to another provider) and related transfer of all such information to the new owner, in which case any information remains protected in accordance with this Privacy Notice. The legal basis for such processing would be Art. 6(1)(f) GDPR.

Other than in the cases mentioned above, we will only transfer personal data to third parties upon explicit consent in accordance with Art. 6(1)(a) GDPR, or if we are obliged to do so by statutory law or by instruction from a public authority or court.

8. Data security

We are very committed to establishing internal procedures to ensure that your personal information is both accurate and protected from accidental loss, unauthorized access, use, alteration, or disclosure. Digtective has implemented technical and organizational measures to ensure the most complete protection of personal data processed through the website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

9. Rights of the data subject

You may at any time and at no cost request us to provide you with information about your personal data processed by us, correction of any errors in your personal data, termination of processing of your personal data, or erasure of your personal data – subject to mandatory legal provisions or obligations to the contrary.

In particular, if you qualify as the “data subject” under the terms of GDPR, you have the right to:

• request information on personal data processed by us about you as provided by Art. 15;
• in accordance with Art. 16, immediately demand the correction of incorrect data or completion of incomplete personal data stored by us;
• pursuant to Art. 17, request erasure of your personal data stored by us, unless the processing of the data is required for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
• in accordance with Art. 18, request the restriction of the processing of your personal data as far as the accuracy of the data is disputed by you or the processing is unlawful;
• in accordance with Art. 20, receive in a structured, standard, and machine-readable format your personal data processed by us or request transmission to another controller;
• in accordance with Art. 7(3), revoke at any time the consent you previously granted to us. As a result, we will no longer be able to continue the data processing based on this consent;
• in accordance with Art. 77, lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or work or the legal address Digtective for this purpose.
• if your personal data is processed based on legitimate interests in accordance with Art. 6(1)(f), file an objection against the processing of your personal data in accordance with Art. 21, provided that there are reasons based on your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right of objection, which shall be implemented by us without you specifying any particular situation.

If you would like to exercise these rights, please contact us using the details indicated below under contact details. Please include any information that would help us identify you in our databases, such as your full name and email address.

10. Changes to the Privacy Policy

We may need to make changes to this Privacy Policy. Privacy legislation is still evolving, and governmental authorities issue guidelines and updates on a regular basis. We may need to change our Privacy Policy to ensure that we implement such recommendations or if we change the way we sell our products or provide our services. We will notify you of any non-trivial changes to this Privacy Policy via email should this option be available to us.

11. Contact details

To exercise your rights under GDPR, contact us at any time by letter or e-mail at:

Digtective Holding AS
Sankt Olavs Gate 25
0166 Oslo
Norway

Email: post@digtective.com

website: https://digtective.com

Business Register: The Brønnøysund Registre Centre