At Flokk, we take data protection seriously, as stated in the overall Information Security and Privacy policy (ISO 27001). When you visit our website, you can be sure that your data is stored responsibly and that we do not share them with other parties.

This document contains more information about how we process your personal data when you visit our website.

For information about the usage of cookies and how to change your consent please review our cookie policy.

This privacy policy was last updated in 2023.

Controller as defined in the EU General Data Protection Regulation (GDPR)

The Data Controller for this website is Flokk Holding AS, Drammensveien 145, 0277 Oslo, Norway. For additional information about our company, see our Contact Information page.

What personal data do we process?

The type of personal data that we process about you may be:

• Basic personal information such as name, address, telephone number, email and demographic information.
• User and web traffic information such as login ID, username, and IP address.
• Financial information such as invoice-related information.
• Content you have uploaded or provided such as photos, comments, articles and videos.
• Information provided through job applications.

For the purposes mentioned in the section “Why we process personal data”, Flokk does not process sensitive personal data about you.

How is personal data collected?

In general, Flokk collects personal data directly from you or other persons linked to your company If the company you work for purchases Flokk products or services via a Flokk dealer, we may collect information about you from the dealer.

We will also use cookies and other tracking technologies when you use Flokk websites and interact with us via email, in order to optimise your experience of Flokk, our products and our sites. Please see our cookie policy for more information.

In some cases, we may also collect information about you from other sources. These sources may be third-party data aggregators, Flokk’s marketing partners, public sources or third-party social networks.

Why do we process personal data?

This Flokk Privacy Statement applies when Flokk and its subsidiaries process your personal data for various purposes when you interact with us, such as:

Buy and deliver

• Facilitate customer orders, agreements, payments.
• Offer services directly to you, such as e-learning, webinars, reports, etc.
• Provide requested offers on products and services to customers.
• Create and facilitate accounts for users of our services.

Support and improve

• Improve and develop the quality, functionality and user experience of our products, services and Flokk web sites.
• Offer customer support of our products and services.
• Operate user communities to educate and enable interaction between users and Flokk.

Security

• Detect, mitigate and prevent security threats and abuse, and perform maintenance and debugging.

Marketing

• Manage and send marketing preferences and content.
• Create interest profiles to promote relevant products and services (profiling).

This is specified in Article 6(1) of the EU General Data Protection Regulation (GDPR). Our “interest” with regard to Article 6(1) is to operate this website. We simultaneously maintain privacy, accessibility and confidentiality of the information.

What is the legal basis for processing your personal data?

We process data based on several legal grounds.

Agreement with you

We process your personal data based on a legal binding contract with you. This will typically be when you apply for a job in Flokk. Processing your personal data such as CV, application and references is necessary for Flokk to handle jobseekers’ requests before a contract is entered into.

Your consent

Flokk might process your personal data based on consent. We ask for your consent to e.g., send you marketing emails according to marketing legislation. You will always be able to opt out, after you have given your consent.

Legitimate interest

Flokk has a legitimate interest when we process your data for marketing, security, support and improvement purposes, or when you act as customer contact/lead for our existing and potential customers, hereunder in customer support. Your personal data is processed from a business perspective in a manner that we believe does not conflict with your privacy rights or freedoms.

Further Flokk processes data based on legitimate interest if you are signing up for a webinar, downloading reports or other content from our web pages, and using our Flokk communities. The legitimate interest is to provide you with correct content, hold webinars, do marketing, and administrate your requests (see section regarding marketing below).

How is your personal data shared?

Within the Flokk Group

Flokk Holding AS consists of many different subsidiaries, it is important for us that we provide the best possible overall experience for you. In order to maintain an overview and insight, Flokk may share your personal data across companies in the Flokk Group.

Outside of the Flokk Group

Flokk may also share your personal data with external third parties in the following contexts:

Dealers

Flokk may share your personal information with our partners in the event this is legitimate from a business perspective and according to applicable privacy legislation.

Public authorities

The police and other authorities may request access to personal information from Flokk. In these cases, Flokk will only provide the data if there is a court order etc. to do so.

How long is your data stored?

Flokk will only store your personal information as long as required to perform our contractual obligations. When processing your personal data on other legal basis, such as legitimate interest, data is stored as long as necessary to fulfil the purpose of processing.

Hence, your personal data may be subject to different retention policies based on the type of data and the purpose of collecting it. Here are some examples:

• When recruiting, Flokk will delete your personal information such as CV, application and other documents when the recruitment process is closed, maximum 18 months after application deadline.
• Another example is contact information stored for marketing purposes, including leads or prospects. Such personal data will be deleted no later than 36 months after the last registered activity.

For further information regarding deletion, feel free to contact Flokk (see contact information in the last section of this statement).

What are your rights?

Basic rights

You have the right to access your personal data by requesting an overview of the personal data we process about you, and you may have a right to data portability. You also have the right to request that Flokk corrects inaccuracies in your personal data. If you have an account with Flokk for a Flokk Site, this can usually be done through the appropriate "your account" or "your profile" sections on the applicable Flokk Site or service.

Further, you have a right to request deletion of personal data, and to restrict or object to our processing of your personal data according to this Privacy Statement or other service-specific terms.

Please use privacy@flokk.com to file requests as mentioned in this section.

Finally, you also have a right to file a complaint to the data protection authorities with regards to our processing of your personal data.

Marketing and profiling

Legitimate interest when you interact with Flokk e.g by visiting Flokk web pages, downloading content, attending webinars, and as part of using Flokk’s services, Flokk will be processing your personal data based on legitimate interest. The purpose is to provide you with relevant marketing content regarding Flokk’s products and services.

Flokk provides relevant content to you through direct marketing on social media platforms, webpages or in a Flokk service, based on your preferences. The personal data processed are aggregated details about you such as IP address, interests (where you have clicked, etc.), username and device. This is done through technologies like cookies and is called profiling.

Flokk uses email for marketing purposes, however only if you have consented, according to national marketing legislation. If you have consented, you will always have the possibility to opt out as described below, or when you receive an email containing marketing.

Right to opt-out of marketing communications

You have the right to opt out of receiving marketing communications from Flokk and may do so by either:

• Following the instructions for opt-out in the relevant marketing communication
• Changing preferences under the relevant edit account section if you have an account with Flokk
• Contacting us via e-mail at privacy@flokk.com
• Using the widget on our website

You will also always have the option to opt into/out of cookies on a particular web page, through our cookie banner widget.

Please note that even if you opt out from receiving marketing communications, you may still receive administrative communications from Flokk, such as order confirmations and notifications necessary to manage your account or the services provided to Customers.

Changes

We encourage you to review the Statement regularly. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect.

The Privacy Statement is revised at least yearly. Last updated: 2023-05-01

Our Data Protection Manager

John Birger Tronsaune is our Data Protection Officer.

You are welcome to contact Mr Tronsaune if you have any questions about data protection and Flokk.

• Email: privacy@flokk.com

How to contact us

Flokk AS is a wholly owned subsidiary of Flokk Holding AS, a European corporation, with legal entities, business processes, management structures and technical systems across borders.

Flokk contact information:

Flokk AS

• Address: Drammensveien 145, 0277 Oslo, Norway
• Telephone number: +47 22 59 59 00

We value your opinion. If you have any comments or questions about our Privacy Statement or any privacy concerns, including a potential breach of your privacy, please send them to privacy@flokk.com.

All major decisions regarding privacy in Flokk are made at a corporate level by the Data Protection Officer (DPO).

Flokk Holding AS (head office):

• Address: Drammensveien 145, 0277 Oslo, Norway
• Telephone number: +47 22 59 59 00

We will handle your requests or complaints confidentially. Our representative will contact you to address your concerns and outline the options regarding how these may be resolved. We aim to ensure that complaints are resolved in a timely and appropriate manner.

Right to lodge a complaint with a supervisory authority

You are entitled to lodge a complaint with a supervisory authority about how we process your personal data.

The supervisory authority with responsibility for Flokk Holding AS is:

The Norwegian Data Protection Authority

• Visiting address: Tollbugata 3, NO-0152 Oslo
• Postal address: Postboks 8177 Dep., NO-0034 Oslo
• BRN 974 761 467
• Telephone number: +47 22 39 69 00
• Email: postkasse@datatilsynet.no

Privacy policy on the internet

This privacy policy only applies to information shared with and/or collected via our internet activities, and only to people who visit our website.

This privacy policy does not apply to information we collect in other places or via channels other than this website.