1. Introduction
These guidelines describe how Clue Norge AS processes your personal data when using the Clue Online dictionary service and associated websites, app for Android and iOS (‘the service’).
‘Personal data’ is defined as any information relating to an identified or identifiable natural person, cf. Article 4 (1) of the Regulation (EU) 2016/679 of the European Parliament and of the Council (‘GDPR’). An identifiable natural person is a person who can be identified directly or indirectly, especially by means of an identifier, for example a name, an identification number, location details or an online identifier.
‘Processing of personal data’ means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, cf. Article 4 (2) of GDPR.
Clue Norge AS is the Data Controller, and as such determines the purpose and means of the processing of personal data, cf. Article 4 (7) of GDPR.
Contact details for Clue Norge AS:
Postal address: Akersgata 43, N-0158 Oslo
Office address: Akersgata 43, N-0158 Oslo
Telephone: +47 23 10 33 70
E-mail: info@clue.no
Internet: www.clue.no
2. Collection and use of personal data
We process your personal data in order to fulfil the agreement with you regarding use of the service, cf. Article 6 (1) (b) of GDPR. The detailed terms and conditions for using the service are stated in the subscription terms that you accepted when entering into the agreement.
When you register as a user of the service, you provide information that we store for further use, including name, company name, organisation number, e-mail address, and one-way encrypted password.
We store information that arises from your use of the service, such as your most frequent search terms etc. If the service is used in a palmtop device, we store a unique identifier for the device you use.
We use this information to provide you with the service, to calculate payment and to improve the service. The e-mail address you give when you register is used to confirm that it is active in order that we can contact you, and to prevent the same person from registering more than one user account in the service.
3. Right to access, correction and deletion, etc.
You are entitled at any time to access your personal data that we process.
If we process incorrect personal data on you, you have the right to have the data corrected. Similarly, you have the right to have incomplete personal data completed.
You have the right to have your personal data deleted. However, it should be noted that deleting personal data will mean that we can no longer provide the service to you. Even if you require your personal data to be deleted, we may continue to process your personal data to the extent permitted by law.
You also have the right to receive your personal data in a structured, commonly used and machine-readable format and to transfer the personal data to another controller.
If you wish to exercise any of the above rights, please contact us. Our contact details are given in section 1 above.
4. Sharing of information with third parties
We only share your personal data with third parties in the following cases:
a) When you have given us consent to share the data with the relevant third party. For example, on Facebook, Twitter or Google (as further described in Section 7 below), or in other cases where you have given us consent.
b) We share your payment data with our finance partners who deal with payments, and when we hire third parties to perform services for us in connection with operation of the service. In such cases, we will still be responsible for your personal data and ensure that data will be processed in accordance with these guidelines and applicable laws.
c) When required by law or by a statutory legal order. We will never sell your personal data to third parties or give third parties access to your personal data for their own purposes beyond what is described above.
5. Communication
We will only use your contact details to communicate with you about circumstances that are relevant to the service and your use therein. For example, to issue receipt of payment, details of amendments to the terms of use for the service and other communication that relates to the service. We will not use your contact details to send you information about services from third parties. We send a newsletter to our users, and you can ask us to stop sending this to you at any given time.
6. Log files
Your usage of the service is logged in our servers’ log files. These log files contain the IP address of the unit that used the service, together with the date/time of the use and details of what resource was requested. If you are logged in, the log file will also contain a reference to your user profile. The log files are used to create anonymous user statistics, which in turn are used to calculate charges to the content providers and to analyse the use of the service.
7. Use of information capsules (‘cookies’)
Information capsules (cookies) are small text files that are placed on your computer or other communication device when you visit a website. When you visit our website, we will in some cases send one or more cookies to the device you are using. We use these cookies to provide login to the website, to remember user choices, and to examine user trends. We use the following cookies: session variables and Typekit for fonts. We use both temporary cookies and cookies that are also stored after the browser is closed. You can delete cookies on your browser at any time and prevent new cookies from being stored, but this may reduce the functionality of the site and can lead to you no longer being able to use the service.
8. Integration with third parties
Google Analytics: We use Google Analytics from Google (Google Inc, USA) to create anonymous user statistics and remarketing. If you do not want to use Google Analytics, you can block it by installing a plug-in to your browser. Plug-ins for the most common web browsers are listed here: http://tools.google.com/dlpage/gaoptout.
Facebook: If you use the “share” function, you can post entries directly to your Facebook account from Clue Online. Information on how Facebook uses your personal data is given in Facebook’s guidelines on data protection.
Twitter: If you use the “share” function, you can post entries directly to your Twitter account (provided by Twitter Inc, USA). This may entail sharing personal data. Information on how Twitter uses your data is given in Twitter’s guidelines on data protection.
Facebook and Twitter have their own guidelines on data protection, and Clue Norge AS is not responsible for Facebook or Twitter’s use of your personal data if you choose to use the “share” function as described above.
9. Security
We store your personal data on secure servers with access restrictions. Only a limited number of persons have physical access to this equipment and only those who need it have access to your personal data. Your personal data will not be transferred to countries outside the EEA area, unless you have given your consent to this.
10. Storing personal data
We store your personal data as long as you are using the service and it is necessary for the purposes described in these guidelines, cf. section 2 above. Personal data that it is no longer necessary to store will be deleted or anonymised in a secure and permanent manner. In cases where we have an obligation to store personal data for a longer period than we may need, the access to personal data will be blocked.
11. Misuse of the service
Where it is suspected that the service is being misused, we can combine data obtained in accordance with these guidelines with other information in order to establish whether the service has indeed been misused, the scope of the misuse and the identity of the person concerned.
12. We comply with laws and regulations
We will always process your personal data in the manner described in these guidelines and always in accordance with applicable laws. In Norway, this primarily relates to the Personal Data Act of 2018, which incorporates GDPR into Norwegian law.
13. Right of appeal
If you believe that our processing of your personal data is illegal, you can appeal to the Norwegian Data Protection Authority. The contact details for the Authority can be found on their website, www.datatilsynet.no.
14. Guideline amendments
The service is subject to ongoing improvements and future changes can affect the way we process your personal data. These guidelines will be updated in order to reflect such changes, amendments to laws and regulations, and other changes in the way we handle personal data. The current version of the guidelines is available at the foot of the home page of www.clue.no.
