Privacy policy

The Nordic GEM AB as well as branches of The Nordic GEM AB in Denmark, Finland and Norway

Introduction and scope
1. Nordic GEM is committed to safeguarding the privacy of our website visitors and service users. The purpose of this policy is explaining how their personal data will be handled.
2. By using and browsing Nordic GEM’s website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
3. Nordic GEM’s website incorporates privacy controls which affect how we will process your personal data.
How we use your personal data

In this Section the following is set out:

The general categories of personal data that we may process.
In the case of personal data that we did not obtain directly from you, the source and specific categories of that data.
The purposes for which we may process personal data.
The legal bases of the processing.

Nordic GEM may process data about your use of our website and services (“usage data”). Said usage data may include your: IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data shall be processed for the purposes of analysing the use of the website and services. Said processing shall only take place with consent as its legal basis.
Nordic GEM may process your account data. Said data shall include your name and email address and may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. Said processing shall only take place with consent as its legal basis.
Nordic GEM may process information contained in any enquiry you submit to us regarding products and/or services, which may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. Said processing shall only take place with consent as its legal basis.
Nordic GEM may process the information lawfully provided for the purpose of receive updates, whether via email notifications or newsletter. This data may be processed for the purposes of sending you relevant updates. Said processing shall only take place with consent as its legal basis. All update subscriptions will present an option to unsubscribe.
Nordic GEM may process information contained in or relating to any communication that you send to us, which may include the communication content as well as its metadata. Nordic GEM’s website will generate said metadata with each communication made using the website’s contact form. This data may be processed for the purposes of communicating with you and record-keeping. Said processing shall take place with Nordic GEM’s legitimate interest as its legal basis, namely the website’s administration and communications with users for the purpose of running our business.
Nordic GEM may, in addition to the specific purposes for processing set out in this Section, process any personal data necessary to ensure compliance with any applicable legal obligation.
Nordic GEM invites all users to avoid providing any other personal data, whether owned of belonging to others, unless prompted to do so with a legal basis.

Providing your personal data to others
1. Nordic GEM may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as necessary for the purposes set out in this policy.
2. If you are a client, Nordic GEM may disclose your personal data to our insurers and/or professional advisers insofar as necessary for the purpose of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice, or managing legal disputes.
3. Nordic GEM may, in addition to the specific disclosures set out in this Section, disclose your personal data where such disclosure is necessary for compliance with any applicable legal obligation.
International transfers of your personal data
1. All Nordic GEM’s partners and subcontractors are situated exclusively in the EEA.
2. Any international transfer of personal data by Nordic GEM shall only be take place upon express request and consent of its controller, as defined by the General Data Protection Regulation.
Retaining and deleting personal data
1. All personal data shall be processed by Nordic GEM, partners and subcontractors, for all and any purpose for no longer than is necessary.
2. Nordic GEM’s processing of personal data shall adhere to the following:
  1. Name, surname, email address and telephone number shall be retained for 24 months from the date of any services query, at the end of which period it shall be deleted from our systems.
  2. In some cases, it will not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine based on the date of your first email to us.
  3. Notwithstanding the other provisions of this Section, Nordic GEM shall retain your personal data where any such retention is necessary for compliance with any applicable legal obligation.
Amendments
1. Nordic GEM may update this policy from time to time by publishing a new version on its website.
2. Users should check this page occasionally to keep track of any changes to this policy.
3. Nordic GEM may notify users of changes to this policy by email or through our website.
Your rights
1. The General Data Protection Regulations (2016) holds several rights reserved to data subjects to ensure the protection of their rights and personal data. Users should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
2. The principal rights under GDPR are:
  1. The right to access.
  2. The right to rectification.
  3. The right to erasure.
  4. The right to restrict processing.
  5. The right to object to processing.
  6. The right to data portability.
  7. The right to complain to a supervisory authority.
  8. The right to withdraw consent.
3. Data subjects have the right to receive confirmation as to whether their personal data is being processed and, if so, to be granted access to the personal data, together with certain additional information. Said additional information might include details of the purposes of the processing, the categories of personal data concerned, and/or the recipients of the personal data. Always provided that no rights or freedoms of other individuals or groups are affected, Nordic GEM shall supply users a copy of their processed personal data. The first of such request shall be provided free of charge. Any additional requests by the same data subject may be granted with a reasonable fee.
4. Data subjects have the right to have any inaccurate personal data about them rectified and, considering the purposes of the processing, to have any incomplete personal data amended.
5. In some circumstances, data subjects have the right to the erasure of their personal data without. Those circumstances include: the processing of the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; the consent forming the legal basis for the processing has been withdrawn; and the personal data has been unlawfully processed. Any request by data subjects concerning the erasure of any personal data might be limited in any situation where the processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6. Data subjects have the right to restrict the processing of your personal data when: they contest the accuracy of the personal data; the processing is unlawful, but there is an opposition to the erasure; Nordic GEM no longer requires the personal data for the purposes of our processing, but the data subject requires the personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, Nordic GEM may continue to store your personal data. And process it in such a fashion only: with the express consent of the data subject; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7. Data subjects have the right to object to our processing of their personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. Upon such an objection, Nordic GEM shall cease processing the personal data, unless compelling legitimate grounds for the processing which override your interests, rights and freedoms have been discovered and can be proved, or the processing is for the establishment, exercise or defence of legal claims.
8. Data subjects have the right to object to the processing of their personal data for direct marketing purposes (including profiling for direct marketing purposes). Upon such an objection, Nordic GEM shall cease to process your personal data for this purpose and delete your data if requested to do so.
9. Data subjects have the right to object to the processing of their personal data for scientific or historical research, or statistical purposes on grounds relating to their situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10. To the extent that the legal basis for the processing of a data subject’s personal data is consent, and such processing is carried out by automated means, data subjects shall have the right to receive their personal data from Nordic GEM in a structured, commonly used and machine-readable format. The exercise of this right shall however be limited in every situation where it would adversely affect the rights and freedoms of others.
11. Should a data subject consider that Nordic GEM’s processing of their personal data infringes any data protection law or provision, they have a legal right to lodge a complaint with the competent supervisory authority responsible for data protection.
12. To the extent that the legal basis for the processing of a data subject’s personal data is consent, data subjects have the right to withdraw that consent at any time.
13. You may exercise any of your rights in relation to your personal data by written notice to us. Or by emailing our data controller on contact@thenordicgem.com.
Third party websites
1. Nordic GEM’s websites may include hyperlinks to, and details of, third party websites. However, Nordic GEM has no control over, and shall not be held responsible for, the privacy policies and practices of third parties.
Personal data of children
1. Nordic GEM’s website and services are targeted at individuals over the age of 18.
2. Should a data subject have reason to believe that Nordic GEM is currently processing the personal data of a person under 18 years of age, Nordic GEM kindly invites the data subject to please contact us so we that we might investigate and take appropriate action against said data.
Acting as a data controller and processor
1. In respect to the personal data, Nordic GEM shall act as data controller and processor, with segregated responsibilities and rights of access assigned to specific individuals within our organisation.
About cookies
1. Cookies are files containing an identifier sent by a web server to a web browser and therein stored. Each time the browser requests a page from the server, the identifier is sent back to the server.
2. Cookies may be either “persistent” or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user beforehand; a session cookie, will expire at the end of the user session, as the web browser is closed.
3. Cookies do not typically contain any personal data, but information stored by Nordic GEM about a user may be linked to the information stored in and obtained from cookies.
Cookies that we use
1. We use cookies for the following purposes:
  1. Analysis – we use cookies to help us to analyse the use and performance of our website and services.
  2. Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
Cookies used by our service providers
1. Nordic GEM’s service providers use cookies, and those cookies may be stored on your computer when you visit our website.
2. Nordic GEM employs Google Analytics to analyse the use of its website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to Nordic GEM’s website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
Managing cookies
1. Most browsers allow users to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Users can however obtain up-to-date information about blocking and deleting cookies via these links:
2. Blocking all cookies may have a negative impact upon the usability of many websites.
3. Should a user opt to block cookies, they may not be able to use all the features on our website.
Our details
1. This website is owned and operated by The Nordic GEM AB.
2. The Nordic GEM AB is a legal entity registered in Sweden.
3. You may contact us either:
  1. By post, using the postal address given on our contact us page.
  2. Via our contact form on our website.
  3. By telephone, on the contact number published on our website.
  4. By email, using the address published on our website.
Queries, requests and complaints relating to your data or our policy
1. You may contact our data controller for further queries on this policy, complaints and request on information held via our postal address as per Section 15.3.1.

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