Privacy Policy of Nashfolk AS
Nashfolk is a customized service provided by Nashfolk AS ("Nashfolk") and can be downloaded as mobile phone
applications or used on the website nashfolk.no. Nashfolk is to provide a tool for home buyers to communicate so
they can find their ranking among other users according to their available equity and access for borrowing when
they approach buying residential units. The purpose of Nashfolk is to aid the user in the home bidding process.
You can find more information about Nashfolk and how it can be used at www.Nashfolk.no.
Owner and Data Controller
Nashfolk AS
Rødtvetveien 69
0955 Oslo
Norway
Contact us by email info@nashfolk.no
Company registration number: 824 489 912
Types of Data collected
Among the types of Personal Data that our websites collect, by themselves or through third parties, there are:
Cookies, Usage Data, email address, phone number and other information requested to use Nashfolk
functionalities, and various other types of Data.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy
policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using
our websites.
Unless specified otherwise, all Data requested by our websites is mandatory and failure to provide this Data may
make it impossible for our websites to provide their services. In cases where our websites specifically state
that some Data is not mandatory, Users are free not to communicate this Data without consequences to the
availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the
Owner.
Any use of Cookies – or of other tracking tools – by our websites or by the owners of third-party services used
by our websites serves the purpose of providing the Service required by the User, in addition to any other
purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through our websites and
confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or
unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures
and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be
accessible to certain types of persons in charge, involved with the operation of our websites (administration,
sales, marketing, legal, system administration) or external parties (such as third-party technical service
providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as
Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
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Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner
may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without
having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever
the processing of Personal Data is subject to European data protection law;
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provision of Data is necessary for the performance of an agreement with the User and/or for any
pre-contractual obligations thereof;
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processing is necessary for compliance with a legal obligation to which the Owner is subject;
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processing is related to a task that is carried out in the public interest or in the exercise of
official authority vested in the Owner;
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processing is necessary for the purposes of the legitimate interests pursued by the Owner or by
a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the
processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties
involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other
than their own. To find out more about the place of processing of such transferred Data, Users can check the
section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union
or to any international organization governed by public international law or set up by two or more countries,
such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this
document or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been
collected for.
Therefore:
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Personal Data collected for purposes related to the performance of a contract between the Owner
and the User shall be retained until such a contract has been fully performed.
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Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained
as long as needed to fulfill such purposes. Users may find specific information regarding the
legitimate interests pursued by the Owner within the relevant sections of this document or by
contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent
to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to
retain Personal Data for a longer period whenever required to do so for the performance of a legal
obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access,
the right to erasure, the right to rectification and the right to data portability cannot be
enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for
the following purposes: Advertising, Analytics, Contacting the User, Content performance and
features testing (A/B testing), Heat mapping and session recording, Hosting and backend
infrastructure, Registration and authentication, Tag Management and Traffic optimization and
distribution.
Users can find further detailed information about such purposes of processing and about the specific
Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Advertising:
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This type of service allows User Data to be utilized for advertising communication purposes
displayed in the form of banners and other advertisements on our websites, possibly based on
User interests.
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This does not mean that all Personal Data are used for this purpose. Information and conditions
of use are shown below.
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Some of the services listed below may use Cookies to identify Users or they may use the
behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and
behavior, including those detected outside our websites. For more information, please check the
privacy policies of the relevant services.
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Personal Data collected: Cookies and Usage Data.
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Place of processing: United States – Privacy Policy.
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Criteo (Criteo SA)
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Criteo is an advertising service provided by Criteo SA.
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Personal Data collected: Cookies and Usage Data.
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Place of processing: France – Privacy Policy – Opt Out.
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Google AdSense (Google Inc.)
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Google AdSense is an advertising service provided by Google Inc. This service uses the
“Doubleclick” Cookie, which tracks use of our websites and User behavior concerning ads,
products and services offered.
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Users may decide to disable all the Doubleclick Cookies by clicking
on: google.com/settings/ads/onweb/optout.
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Personal Data collected: Cookies and Usage Data.
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Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Analytics:
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The services contained in this section enable the Owner to monitor and analyze web traffic and
can be used to keep track of User behavior.
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Google Analytics (Google Inc.)
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Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes
the Data collected to track and examine the use of our websites, to prepare reports on its
activities and share them with other Google services.
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Google may use the Data collected to contextualize and personalize the ads of its own
advertising network.
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Personal Data collected: Cookies and Usage Data.
- Firebase by Google
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Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Contacting the User:
Contact form
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By filling in the contact form with their Data, the User authorizes us to use these details to
reply to requests for information, quotes or any other kind of request as indicated by the
form’s header.
- Mailing list or newsletter
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By registering on the mailing list or for the newsletter, the User’s email address will be added
to the contact list of those who may receive email messages containing information of commercial
or promotional nature concerning our websites.
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Personal Data collected: email address, phone number, Anticipated Equity amount and available
loan amount and the Bank letter.
Heat mapping and session recording:
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Heat mapping services are used to display the areas of a page where Users most frequently move
the mouse or click. This shows where the points of interest are. These services make it possible
to monitor and analyze web traffic and keep track of User behavior.
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Some of these services may record sessions and make them available for later visual playback.
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Hotjar Heat Maps & Recordings (Hotjar Ltd.)
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Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
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Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to
collect any of the User's data. This is a setting that is available in all major browsers. Find
Hotjar’s opt-out information here.
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Personal Data collected: Cookies, Usage Data and various types of Data as specified in the
privacy policy of the service.
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Place of processing: Malta – Privacy Policy – Opt Out.
Hosting and backend infrastructure:
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This type of service has the purpose of hosting Data and files that enable our websites to run and be
distributed as well as to provide a ready-made infrastructure to run specific features or parts of our
websites. Some of these services work through geographically distributed servers, making it difficult to
determine the actual location where the Personal Data are stored.
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Microsoft Azure (Microsoft Corporation)
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Microsoft Azure is a hosting service provided by Microsoft Corporation.
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Personal Data collected: various types of Data as specified in the privacy policy of the
service.
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Privacy Shield participant.
Registration and authentication:
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By registering or authenticating, Users allow our websites to identify them and give them access
to dedicated services.
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Depending on what is described below, third parties may provide registration and authentication
services. In this case, our websites will be able to access some Data, stored by these
third-party services, for registration or identification purposes.
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Facebook Authentication (Facebook, Inc.)
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Facebook Authentication is a registration and authentication service provided by Facebook, Inc.
and is connected to the Facebook social network.
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Personal Data collected: various types of Data as specified in the privacy policy of the
service.
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Place of processing: United States – Privacy Policy. Privacy Shield participant.
- Google OAuth (Google Inc.)
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Google OAuth is a registration and authentication service provided by Google Inc. and is
connected to the Google network.
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Personal Data collected: various types of Data as specified in the privacy policy of the
service.
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Place of processing: United States – Privacy Policy. Privacy Shield participant.
Tag Management
- This type of service helps the Owner to manage the tags or scripts needed on our websites in a
centralized fashion.
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This results in the Users' Data flowing through these services, potentially resulting in the
retention of this Data.
- Google Tag Manager (Google LLC)
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Google Tag Manager is a tag management service provided by Google LLC.
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Personal Data collected: Cookies and Usage Data.
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Place of processing: United States – Privacy Policy. Privacy Shield participant.
- The rights of Users
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Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
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Withdraw their consent at any time. Users have the right to withdraw consent where they have
previously given their consent to the processing of their Personal Data.
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Object to processing of their Data. Users have the right to object to the processing of their
Data if the processing is carried out on a legal basis other than consent. Further details are
provided in the dedicated section below.
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Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain
disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing
processing.
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Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask
for it to be updated or corrected.
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Restrict the processing of their Data. Users have the right, under certain circumstances, to
restrict the processing of their Data. In this case, the Owner will not process their Data for
any purpose other than storing it.
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Have their Personal Data deleted or otherwise removed. Users have the right, under certain
circumstances, to obtain the erasure of their Data from the Owner.
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Receive their Data and have it transferred to another controller. Users have the right to
receive their Data in a structured, commonly used and machine-readable format and, if
technically feasible, to have it transmitted to another controller without any hindrance. This
provision is applicable provided that the Data is processed by automated means and that the
processing is based on the User's consent, on a contract which the User is part of or on
pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection
authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner
or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by
providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can
object to that processing at any time without providing any justification. To learn, whether the Owner is processing
Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details
provided in this document. These requests can be exercised free of charge and will be addressed by
the Owner as early as possible and always within one month.
Additional information about Data collection and processing Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages
leading to possible legal action arising from improper use of our websites or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of
public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, our websites may provide the User
with additional and contextual information concerning particular Services or the collection and
processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, our websites and any third-party services may collect files
that record interaction with our websites (System logs) use other Personal Data (such as the IP
Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the
Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Our websites do not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests,
please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to
its Users on this page and possibly on our websites and/or - as far as technically and legally
feasible - sending a notice to Users via any contact information available to the Owner. It is
strongly recommended to check this page often, referring to the date of the last modification listed
at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the
Owner shall collect new consent from the User, where required.
Definitions and legal references Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a
personal identification number — allows for the identification or identifiability of a natural
person.
Usage Data
Information collected automatically through our websites (or third-party services employed on our websites),
which can include: the IP addresses or domain names of the computers utilized by the Users who use our websites,
the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the
request to the server, the size of the file received in response, the numerical code indicating the status of
the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and
the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page
within our websites) and the details about the path followed within our websites with special reference to the
sequence of pages visited, and other parameters about the device operating system and/or the User's IT
environment.
User
The individual using our websites who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on
behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with
others, determines the purposes and means of the processing of Personal Data, including the security
measures concerning the operation and use of our websites. The Data Controller, unless otherwise
specified, is the Owner of our websites.
Service
The service provided by our websites as described on our websites.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include
all current member states to the European Union and the European Economic Area.
Cookies
Small sets of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including
Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: March 29, 2020
Protecting your personal information is important to us and we have therefore created these
guidelines on how we protect, store and use information.
Cookies
Like many other websites, this website uses cookies to make the service more user-friendly. A cookie
is a small data file that identifies you as a unique user and makes your experience faster and more
efficient. This website uses cookies to improve the quality of our service and in understanding our
user base better.
Consent and changes to the Privacy Policy
You consent to our policy and terms of use by using this website. We have the right to make changes
to our policies. We will inform of any changes on this page.
© NASHfolk | 2020
