MultiNOR Privacy Policy

1. General Information

1.1. Personal Data Controller

1.1.1. The controller of Users' personal data is MultiNOR spółka z ograniczoną odpowiedzialnością spółka komandytowa with its registered office in Gdańsk (80-386), ul. Lęborska 3B, entered into the Register of Entrepreneurs of the National Court Register under KRS number: 0000546209, NIP: 584-273-49-23, REGON: 222044787 (hereinafter referred to as "MultiNOR" or the "Controller").

1.1.2. The Controller operates a business involving the provision of translation services, formal support, and presentation of partner offers via the website available at www.multinor.no (hereinafter referred to as the "Service").

1.2. Controller’s Contact Information

1.2.1. For matters related to the protection of personal data, the User may contact the Controller in the following ways:

  • Email address: rodo@multinor.no
  • Postal address: MultiNOR Sp. z o.o. Sp. k., ul. Lęborska 3B, 80-386 Gdańsk
  • Phone number: +48 58 743 07 53

1.2.2. The Controller has not appointed a Data Protection Officer (DPO). All inquiries regarding the processing of personal data should be directed to the above contact details.

1.3. Scope of the Privacy Policy

1.3.1. This Privacy Policy applies to the website available at www.multinor.no and defines the rules for the processing of personal data of Users using the Service.

1.3.2. The purpose of this Privacy Policy is to inform Users about:

  • The ways and purposes of processing their personal data by MultiNOR.
  • The legal bases for data processing.
  • The rights of Users in relation to the processing of their data.
  • The recipients of personal data.
  • The applied data protection measures.

1.3.3. This Privacy Policy constitutes the fulfillment of the information obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data ("GDPR") and other applicable laws.

1.4. Acceptance of the Privacy Policy

1.4.1. Using the Service is tantamount to accepting the provisions of this Privacy Policy.

1.4.2. If the User does not agree with the provisions of the Privacy Policy, they should stop using the Service.

1.5. Changes to the Privacy Policy

1.5.1. MultiNOR reserves the right to make changes to this Privacy Policy at any time for important reasons, such as:

  • Changes in applicable laws.
  • Introduction of new services or functionalities in the Service.
  • Changes in the methods and purposes of personal data processing.

1.5.2. MultiNOR will inform Users of any changes to the Privacy Policy through:

  • Publication of the new content of the Privacy Policy on the Service website.
  • In the case of significant changes – sending information to the email address provided by the User (if the User has consented to such communication).

1.5.3. Changes to the Privacy Policy take effect on the day they are published on the Service website unless a different date is specified.

1.5.4. Use of the Service after the changes to the Privacy Policy come into force constitutes acceptance of those changes by the User.

 

2. Scope of Processed Personal Data

2.1. Data Collected During Registration

2.1.1. During registration on the Service, MultiNOR collects the following personal data:

  • Email address
  • Phone number (for verification and authentication)
  • User Account password (stored in encrypted form)

2.1.2. In the case of registration via a Google account:

  • MultiNOR receives from Google the basic User data necessary to create an Account, such as:
    - Email address
    - First and last name (if shared)
  • The User is required to provide a phone number for verification via SMS code.

2.1.3. The phone number is used for:

  • User identity verification during registration and login (two-factor authentication).
  • Contacting the User regarding the provision of services, if necessary.

2.2. Data Collected During the Use of Services

2.2.1. While using the services provided by MultiNOR, the following data may be collected:

  • Home or correspondence address
  • PESEL number or other identification number
  • Data from documents submitted for translation or formal support (e.g. information on health status, financial situation, family situation, marital status, owned assets)
  • Data regarding orders, transactions, payments, and order history
  • Communication data with the User (e.g. emails, phone calls, chat messages)

2.3. Data Collected Automatically

2.3.1. While using the Service, the following data may be collected automatically:

  • The IP address of the User’s device
  • Type of web browser and operating system
  • Data regarding activity on the Service (e.g. visited pages, time spent on the website)
  • Cookies and other tracking technologies (see details in the Cookie Policy)

2.3.2. Data collected automatically is used for statistical, analytical, and security purposes, and to ensure the proper functioning of the Service.

 

3. Purposes and Legal Bases for Data Processing

3.1. Provision of Services

3.1.1. Users' personal data is processed for the purpose of:

  • Conclusion and performance of the service agreement offered by MultiNOR through the Service.
  • Registration and maintenance of the User Account, including:
    - Identity verification via SMS verification code.
    - Enabling login and use of Account functionalities.
    - Enabling registration and login via a Google account.
  • Contacting the User regarding the provision of services, including:
    - Notifications about service status.
    - Reminders about deadlines and the need to take action related to services.
    - Information about changes to the Service, Terms of Use, or Privacy Policy.
  • Providing services tailored to the individual needs of the User, including reminders about the possibility to use certain benefits or services related to working and living in Norway.

3.1.2. The legal bases for processing personal data for the above purposes are:

  • Article 6(1)(b) of the GDPR – necessity of processing for the performance of a contract to which the User is a party.
  • Article 6(1)(a) of the GDPR – User consent (regarding data obtained from Google during registration via a Google account).

3.2. Communication with the User

3.2.1. Users' personal data is processed in order to:

  • Maintain the communication necessary to properly provide services, including:
    - Sending notifications about the need to take specific actions.
    - Reminders about deadlines and possibilities to use services or benefits.
  • Ensure high-quality customer service, including responding to User inquiries and requests.

3.2.2. Communication with the User may be carried out via:

  • Email messages.
  • SMS messages.
  • Phone calls.

3.2.3. The legal basis for processing data in this scope is:

  • Article 6(1)(b) of the GDPR – processing is necessary for the performance of a contract.

3.3. Marketing and Profiling

3.3.1. MultiNOR may process Users' personal data for the purposes of direct marketing, including:

  • Promoting its own products and services.
  • Presenting offers of products and services of External Partners.

3.3.2. As part of direct marketing, MultiNOR may:

  • Send commercial information to Users via electronic communication channels (email, SMS).
  • Contact Users by phone.

3.3.3. Profiling

MultiNOR may use profiling to tailor offers and marketing messages to the User’s preferences and needs.

Profiling involves automatic analysis or prediction of the User's behavior based on:

  • Activity within the Service.
  • Order history and use of services.
  • Demographic and geolocation data.
  • Information obtained during communication with the User.

3.3.4. Purposes of profiling:

  • Personalization of offers and marketing communications.
  • Improving the quality of provided services.
  • Informing the User about services and benefits they may use.

3.3.5. The legal basis for data processing for marketing and profiling purposes is:

  • Article 6(1)(a) of the GDPR – the User's consent (in the case of sending commercial information electronically and profiling for marketing purposes).
  • Article 6(1)(f) of the GDPR – the Controller’s legitimate interest (in the scope of direct marketing of its own products and services and profiling necessary for the provision of services).

3.3.6. User Rights:

  • The User has the right to withdraw consent to the processing of data for marketing and profiling purposes at any time by contacting the Controller or using the relevant functionalities within the Service.
  • The User has the right to object to the processing of their personal data for direct marketing purposes, including profiling.

3.3.7. Withdrawal of consent or objection does not affect the lawfulness of processing carried out before its withdrawal.

3.4. Use of AI and OCR

3.4.1. MultiNOR uses Artificial Intelligence (AI) and Optical Character Recognition (OCR) technologies for the purpose of:

  • Automatic analysis and pricing of documents submitted by Users.
  • Improving translation and formal processes.
  • Personalizing the offer and communication with the User through the AI Assistant.

3.4.2. Processing of personal data using AI and OCR may include:

  • Analyzing the content of documents and information provided by the User.
  • Creating analytical models to optimize services and adapt them to the User's needs.
  • Forecasting the User’s needs based on data analysis.

3.4.3. The legal basis for processing personal data using AI and OCR is:

  • Article 6(1)(b) of the GDPR – necessity of processing for the performance of a contract (to the extent necessary to provide services).
  • Article 6(1)(a) of the GDPR – the User's consent (to the extent that processing is not necessary for contract performance, e.g. for service improvement or additional profiling).

3.4.4. The User is informed about the use of AI and OCR technologies and consents to it by accepting this Privacy Policy and using the Service.

3.4.5. User Rights:

  • The User has the right to withdraw consent to data processing by AI and OCR at any time, but this may prevent or limit the provision of certain services.
  • The User has the right to obtain information about the applied procedure, its significance, and the anticipated consequences of such processing for them.

3.5. Fulfillment of Legal Obligations

3.5.1. Users' personal data may be processed for the purpose of fulfilling legal obligations imposed on the Controller under applicable laws, e.g. tax or accounting regulations.

3.5.2. The legal basis for processing data in this scope is:

  • Article 6(1)(c) of the GDPR – processing is necessary for compliance with a legal obligation to which the Controller is subject.

3.6. Establishment, Exercise, or Defense of Legal Claims

3.6.1. Personal data may be processed for the purpose of establishing, exercising, or defending legal claims related to a contract or data processing.

3.6.2. The legal basis for processing data in this scope is:

  • Article 6(1)(f) of the GDPR – the Controller’s legitimate interest in protecting its rights and interests.

 

4. Data Disclosure

4.1. Data Disclosure to Sworn Translators

4.1.1. In order to perform translation services, MultiNOR may disclose Users' personal data, including the content of documents, to Sworn Translators it cooperates with.

4.1.2. Sworn translators act as processors of personal data on behalf of MultiNOR, based on data processing agreements in accordance with Article 28 of the GDPR.

4.1.3. Sworn translators are obligated to maintain confidentiality and apply appropriate technical and organizational measures to protect personal data.

4.2. Data Disclosure to External Partners

4.2.1. With the User’s consent, MultiNOR may disclose personal data to External Partners for the purposes of:

  • Preparing and presenting personalized offers for products and services.
  • Providing services directly by the Partners.

4.2.2. External Partners are entities providing financial, insurance, energy, and other complementary services to MultiNOR's offerings.

4.2.3. Data is disclosed solely on the basis of the User’s explicit consent given when using specific Service functionalities.

4.2.4. External Partners become independent data controllers and process data in accordance with their own privacy policies.

4.3. Data Disclosure to Technology Providers

4.3.1. MultiNOR uses the services of technology providers who support the operation of the Service, particularly in the areas of:

  • Hosting and maintaining IT infrastructure.
  • Use of AI and OCR technologies.
  • Data analysis and statistical services.
  • Sending emails and SMS messages.
  • Email address authorization

4.3.2. Technology providers may have access to Users’ personal data to the extent necessary to provide services to MultiNOR.

4.3.3. These providers act as processors of personal data on behalf of MultiNOR, based on data processing agreements in accordance with Article 28 of the GDPR.

4.3.4. MultiNOR requires its technology providers to maintain confidentiality and to apply appropriate technical and organizational measures to protect personal data.

4.4. Data Transfers to Third Countries

4.4.1. If personal data is to be transferred to entities based outside the European Economic Area (EEA), MultiNOR ensures an adequate level of personal data protection in accordance with Chapter V of the GDPR.

4.4.2. Data transfer to third countries may be based on:

  • A European Commission decision confirming an adequate level of protection.
  • Standard data protection clauses adopted by the European Commission.
  • Binding corporate rules.
  • The User’s explicit consent after being informed of potential risks.

 

5. User Rights

5.1. Right of Access

5.1.1. The User has the right to obtain confirmation from MultiNOR as to whether or not their personal data is being processed and, where that is the case, access to the data and information on:
the purposes of processing;

  • categories of relevant personal data;
  • recipients or categories of recipients to whom the data has been or will be disclosed;
  • the planned retention period for the data or the criteria used to determine that period;
  • the rights of the User in relation to data processing;
  • the right to lodge a complaint with a supervisory authority;
  • the source of the data, if not collected from the User;
  • automated decision-making, including profiling.

5.2. Right to Rectification

5.2.1. The User has the right to request that MultiNOR promptly correct any inaccurate personal data concerning them.

5.2.2. The User has the right to request the completion of incomplete personal data, including by providing a supplementary statement.

5.3. Right to Erasure (“Right to be Forgotten”)

5.3.1. The User has the right to request that MultiNOR immediately delete their personal data, and MultiNOR is obligated to delete such data without undue delay if one of the following conditions applies:

  • the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
  • the User withdraws their consent and there is no other legal basis for the processing;
  • the User objects to the processing and there are no overriding legitimate grounds for the processing;
  • the personal data has been unlawfully processed;
  • the personal data must be erased to comply with a legal obligation.

5.3.2. The right to erasure does not apply to the extent that processing is necessary:

  • for exercising the right to freedom of expression and information;
  • for compliance with a legal obligation under Union or Member State law;
  • for the establishment, exercise, or defense of legal claims.

5.4. Right to Restriction of Processing

5.4.1. The User has the right to request that MultiNOR restrict processing in the following cases:

  • when the User contests the accuracy of the personal data – for a period enabling MultiNOR to verify the accuracy of the data;
  • the processing is unlawful, and the User opposes the erasure of the personal data and requests the restriction of its use instead;
  • MultiNOR no longer needs the personal data for the purposes of the processing, but it is required by the User for the establishment, exercise, or defense of legal claims;
  • the User has objected to processing – pending the verification whether MultiNOR's legitimate grounds override those of the User.

5.5. Right to Data Portability

5.5.1. The User has the right to receive their personal data, which they have provided to MultiNOR, in a structured, commonly used, and machine-readable format.

5.5.2. The User has the right to transmit that data to another controller without hindrance from MultiNOR where:

  • the processing is based on the User’s consent or on a contract;
  • the processing is carried out by automated means.

5.5.3. The User has the right to request that their personal data be transmitted by MultiNOR directly to another controller, where technically feasible.

5.6. Right to object to processing

5.6.1. The User has the right to object at any time – on grounds relating to their particular situation – to the processing of their personal data based on MultiNOR’s legitimate interest (Article 6(1)(f) of the GDPR), including profiling.

5.6.2. If the User objects, MultiNOR will no longer process their personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the User, or for the establishment, exercise, or defense of legal claims.

5.6.3. If personal data is processed for direct marketing purposes, the User has the right to object at any time to the processing of their data for such purposes, including profiling.

5.7. Right to withdraw consent

5.7.1. Where the processing of personal data is based on the User’s consent (Article 6(1)(a) of the GDPR), the User has the right to withdraw consent at any time.

5.7.2. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

5.8. Right to lodge a complaint with a supervisory authority

5.8.1. The User has the right to lodge a complaint with a supervisory authority for personal data protection, in particular in the Member State of their habitual residence, place of work, or place of the alleged infringement, if they consider that the processing of their personal data violates the provisions of the GDPR.

5.9. Exercising User rights

5.9.1. To exercise the above rights, the User may contact MultiNOR via:

  • Email address: rodo@multinor.no
  • Postal address: MultiNOR Sp. z o.o. Sp. k., ul. Lęborska 3B, 80-386 Gdańsk

5.9.2. MultiNOR will respond to the User’s request without undue delay, but no later than within one month of receiving the request. This period may be extended by another two months due to the complexity or number of requests, and the User will be informed accordingly.

 

6. Security Measures

6.1. MultiNOR makes every effort to ensure a high level of security for Users' personal data, in particular by applying appropriate technical and organizational measures in accordance with Article 32 of the GDPR.

6.2. Security measures used by MultiNOR include, among others:

  • Data encryption during transmission (SSL/TLS protocol);
  • Protection of IT systems against unauthorized access;
  • Access control to personal data;
  • Regular updates of software and security systems;
  • Staff training on personal data protection;
  • System monitoring for potential threats and security incidents.

6.3. In the event of a personal data breach that may pose a high risk to the rights or freedoms of Users, MultiNOR will inform the Users and the competent supervisory authority in accordance with applicable law.

 

7. Data Retention Period

7.1. Users' personal data will be stored for the period necessary to fulfill the purposes for which it was collected, in particular:

  • For the performance of a contract – for the duration of the contract and until the expiration of any potential claims;
  • For compliance with legal obligations – for the period required by applicable law (e.g., tax, accounting);
  • For direct marketing purposes – until an objection is raised or consent is withdrawn;
  • For data processed based on consent – until consent is withdrawn.

7.2. After the above periods, personal data will be deleted or anonymized in a manner that prevents the identification of the User.

 

8. Cookies and Tracking Technologies

8.1. The MultiNOR Service uses cookies and other tracking technologies to:

  • Ensure the proper functioning of the Service;
  • Personalize content and adapt the Service to the User’s preferences;
  • Conduct statistical analysis and examine traffic on the Service’s pages;
  • Conduct marketing and remarketing activities.

8.2. Detailed information on the use of cookies, their purposes, and how the User can manage them can be found in the Cookie Policy available on the Service’s website.

 

9. Changes to the Privacy Policy

9.1. MultiNOR reserves the right to make changes to this Privacy Policy at any time, for important reasons, such as:

  • Changes in the law;
  • Changes in the methods and purposes of data processing;
  • Introduction of new services or functionalities on the Service.

9.2. MultiNOR will inform Users about any changes to the Privacy Policy by:

  • Publishing the new content of the Privacy Policy on the Service’s website;
  • In the case of significant changes – sending information to the email address provided by the User (if the User has consented to this form of communication).

9.3. Changes to the Privacy Policy take effect on the date they are published on the Service’s website, unless another date is specified.

9.4. Using the Service after the changes to the Privacy Policy take effect means that the User accepts those changes.

 

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