Privacy Policy

 

Attensi AS (“Attensi“) provides a simulation-based platform, portal, software, technical interfaces and related technology (the “Service“). The Service is provided to a customer for the purpose of performing internal training of own employees or customers, suppliers or other relevant third parties.

The Service is only available to authorised users, as further described in the Terms of Use, which is available here: https://legal.attensi.com/tos.html. An authorised user will be referred to in the following as “we“, “us“, “our“.

 

1. DATA CONTROLLER AND DATA PROCESSOR FOR YOUR PERSONAL DATA IN RELATION TO THE SERVICE

For the purpose of this privacy policy, The Attensi Customer is data controller for the personal data provided by you to access and use the Service.

Attensi is data processor for The Attensi Customer, and will only use your personal data for the purposes they were collected, and in order to perform our Services towards The Attensi Customer. The relationship between Attensi and The Attensi Customer is governed by a data processor agreement, and Attensi will process your personal data in accordance with applicable laws on privacy.

Together, Attensi and The Attensi Customer will be referred to as “we”, “us”, “our”.

 

2. THE INFORMATION WE COLLECT FROM YOU

  1. In order to provide the Service, we will process certain information about you. Information about you: may include name, title/position, email, phone number, employers name, employee number etc. depending on the specific requirements for use of the Service from case to case.
  2. Information about your use of the Service: in particular performance data resulting from training sessions and competence development performed in connection with the Service or as preparation for use of the Service. We also process statistics from your use of the service, including the scoring you obtain on each module, how many times you play each module, the time you use per playthrough, etc.
  3. Inquiries: if you submit questions regarding the Service, this privacy policy or the Terms of Use, this information will be saved and used to resolve your enquiries.
  4. Your IP address and other information about your computer: we may collect and store Your IP address (the number that identifies your computer on the internet) and other information about your computer for system administration purposes (e.g. to calculate how many users that has accessed and used the Service). The IP address will only be stored for the duration of the visit on the website and will thereafter be either deleted or anonymized.
  5. Cookies: we use cookies and other information gathering methods to enhance the user experience and optimize the Service. Please refer to our Cookie Policy, which is available here: https://legal.attensi.com/cookie-policy.html

 

3. HOW AND WHY DO WE USE YOUR INFORMATION?

We will only process the personal data mentioned for the purposes stipulated in this privacy policy. We use the personal data you provide to us or that we collect through your use of the Service for the following purposes:

  1. to enable you to use the Service, e.g. to give you access to the Service;
  2. to improve the Service, the content of the Service and the user experience;
  3. to compile statistics of all users in an organisation, individually and as organisational groups, in order to provide analysis, insight and key numbers regarding training efficiency and effect;
  4. to respond to your questions or inquiries;
  5. to notify you of changes to the Service, to the Terms of Use or to this privacy policy;
  6. if applicable: to identify and provide content that is relevant to any particular user or group of users;
  7. If applicable: to send you email, push or SMS notices that you have signed up for;
  8. investigations, prevention and protection against violations of this privacy policy, fraud or other potential threats to Attensi’s or third parties’ rights;
  9. to comply with all applicable rules and regulations; and
  10. for any other purposes for which we will notify you specifically at the time of collection or upon obtaining you consent, or as permitted or required by law, rule, regulation or any other legal process.

 

4. CONSENT AND OTHER LEGAL BASIS FOR PROCESSING

In order to process your personal data, we require your consent or other legal basis. The legal basis for processing of your personal data are:

  1. Consent; Consent may be given upon request from The Attensi Customer and/or by your voluntarily submittal of the information to The Attensi Customer or through the Service. You can withdraw your consent at any time by contacting The Attensi Customer. Please be advised that use of the Service is dependent on processing of certain information regarding the users, and that a withdrawal of consent may lead to full of partial loss of the Service’s functionality. Examples of processing based on consent, are in particular the purposes addressed in section 3 vi), vii) above.
  2. Processing necessary to fulfil an agreement with you; Examples of processing which partly or in whole are based on contractual obligations are in particular the purposes mentioned in section 3 i), iv) and v) above.
  3. Processing necessary for attending to the legitimate interests of The Attensi Customer or a third party; Processing is lawful when it is necessary for the purpose of legitimate interests of The Attensi Customer or a third party, and are not overridden by your interests. For certain processing purposes – e.g. to improve the Service (section 3 ii)), to compile statistics on the use of the Service (section 3 iii)), and to improve the Service’s attractiveness through targeted content (section 3 vi)) – the legitimate interests of The Attensi Customer and third parties like Attensi, will constitute legal basis for processing as a supplement to consent. This legal basis will also allow processing to e.g. prevent loss or damages to The Attensi Customer or any third parties or to prevent any actions that may compromise The Attensi Customer or a third party’s property or the personal data of the other users of the Service, cf. section 3 viii).
  4. Processing necessary for compliance with legal obligations; We will also process certain personal data to comply with all applicable rules and regulations to which we are subject, e.g. statutory rules related to storage for accounting purposes, cf. section 3 ix).

 

5. YOUR RIGHTS

Under relevant data protection legislation, you have the right to:

  1. receive information about the personal data we have registered on you;
  2. request a change or update of the stored data and correct any errors in that data;
  3. request that unnecessary data is erased;
  4. for processing based on consent; to withdraw your consent at any time;
  5. restrict processing or object to processing under certain circumstances; or
  6. data portability, i.e. your right to obtain, reuse and transfer personal data provided to Attensi to another IT environment;

If you want to exercise your rights as defined above, you can contact The Attensi Customer via the contact information stipulated below under section 12.

 

6. RETENTION PERIOD

We will retain your personal data for as long as it is necessary to fulfil the purposes for processing as defined above, and will as a main rule, delete your personal data upon your request. Please note that legal obligations, e.g. statutory rules related to storage for accounting purposes, may render necessary that your personal data is stored after your registration with the Service is cancelled. Continued storage may also occur where such storage is necessary for the purposes of legitimate interests pursued by The Attensi Customer or third parties, including, but not limited to the establishment, exercise or defence of legal claims.

Please also note that a cancellation or deletion of your personal data will not occur automatically upon termination of your employee relationship at The Attensi Customer. Thus, statistics about your use of the Service may be processed after you leave the employment of The Attensi Customer, unless you specifically request that your registration is cancelled and your personal data is deleted.

 

7. DISCLOSURE TO THIRD PARTIES

As stipulated in section 1, Attensi is data processor for The Attensi Customer, and will process your personal data on The Attensi Customer’s behalf and in accordance with an agreement with The Attensi Customer.

We may also disclose your personal data to third party vendors and hosting partners that perform services for The Attensi Customer or Attensi, in order to be able to deliver the Service to you. These third party vendors will only use your personal data for the purposes they were collected, and in order to perform their services towards The Attensi Customer or Attensi. The relationship to such third party vendors will be governed by a data processor agreement.

Except as described in this Privacy Policy, we will not transfer, sell, rent or exchange your personally identifiable information with any third party without your express consent, unless such obligation is imposed by law or binding court order, or when necessary in a business transaction.

 

8. PROTECTION OF YOUR DATA

We take the privacy rights of our users seriously and has taken reasonable steps to protect the user’s privacy, including physical, technical and organisational measures, to prevent loss, alterations, theft and unauthorized access to information stored and otherwise processed in relation to the Service.

 

9. LINKS TO THIRD PARTY WEBSITES

The Service or websites where the Service is available may include links to other third party sites. These third party sites have own privacy policies that determines how the third party site is operated and how personal data is collected and processed. If you submit personal information to any of these third party sites, your information is governed by their privacy policies. We take no responsibility for such third party sites, how they are operated and how they process your personal data. We recommend that you familiarize yourself with such third party sites’ privacy policies and terms of use when visiting and using such sites.

 

10. RIGHT TO LODGE COMPLAINT WITH A SUPERVISORY AUTHORITY

If you believe that our processing of your personal data infringes relevant data protection regulations, you are entitled to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement, or other relevant supervisory authority.

 

11. MODIFICATIONS TO THE PRIVACY POLICY

We reserve the right to modify this privacy policy from time to time. The most recent revision shall supersede any earlier versions. The current version of the privacy policy will be available in the Service at all time and you can also find a company default version of the policy at https://legal.attensi.com/privacy.html. We advise you to check the privacy policy from time to time, to keep up to date with the current policy. We will notify the user of any changes to the privacy policy that will require your consent.

 

12. QUESTIONS – CONTACT

If you have any questions relating to this privacy policy or want to exercise your rights in accordance with section 5, you should contact The Attensi Customer via the address stipulated below, and your request will be forwarded to the Attensi Customer.

dataprivacyofficer@attensi.com

 


 

 

Last updated: 2020-03-05