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Privacy policy FOR ‘Infront Excel Add-In’

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you use the Infront Excel Add-In (the product) as extension of your existing Infront Investment Manager subscription. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy. As this product is used in conjunction with your Infront Investment Manager subscription, it does not collect other information as the connected product does.

Effective date: 25 April 2023

Data recording within the product

Who is the responsible party for the recording of data?

The data is processed by the operator of the product, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter during the usage of the product.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your use of the product. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you use the product.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the correct access to the services you have ordered within the product. The information you requested by the usage of the product will be stored within your profile of the Investment Manager.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

2. General information and mandatory information

Data protection

The operators of the product and take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use the product, a variety of information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller for this product is:

Infront AS

Munkedamsveien 45

0250 Oslo

Norway

Phone: +47 23 31 00 00

E-mail: support@infront.co

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this product

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. The consent can be revoked at any time. If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfilment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Designation of a data protection officer

We have appointed a data protection officer, who can be reached at privacy@infront.co.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Data Protection Authority

The Norwegian Data Protection Authority (DPA) is Infront’s lead supervisory authority. You may direct questions or complaints to our lead supervisory authority by sending them an email postkasse@datatilsynet.no or writing to the following address:

The Norwegian Data Protection Authority (DPA)

PO Box 8177 Dep.

0152 Oslo

Norway

Right to data portability

You have the right to have data that we process automatically based on your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source, and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.

If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.

If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.

If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, all information which is sent during the use of this product is protected by SSL or a TLS encryption program.

3. Recording of data by using the product

Log files

The provider of product automatically collects and stores information in so-called server log files, which the product communicates to us automatically e.g., during the login process. The information comprises:

The username / realm ID
The type and version of browser used
The used Operating System
Referrer URL
The hostname of the accessing computer
The time of the server inquiry
The IP address
The client/application ID
The authentication method used (openID/SAML)

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the product has a legitimate interest in the technically error free depiction and the optimization of the product. In order to achieve this, log files must be recorded.

4. Changes to this policy

We reserve the right to make changes to our security and data protection measures and this policy where necessary due to technical development or changes in legal or regulatory regulations. In these cases, we will also update this policy accordingly. Therefore, we ask that you observe the respective current version of this data privacy policy.