4Subsea Privacy Policy

1. INTRODUCTION

4Subsea is committed to protecting and respecting your privacy during your relationship with us. This Privacy Policy explains how 4Subsea processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of its website and digital services: What Personal Data and Special Categories of Personal Data we collect from you and about you, how it will be used, and your individual rights. We will only Process your Data as permitted by applicable law.

 

2. DEFINITIONS THAT WILL HELP YOU UNDERSTAND THIS PRIVACY POLICY

As defined by the General Data Protection Regulation (GDPR) data privacy law:

 

3. WHAT DATA DO WE PROCESS ABOUT YOU?

Type of data collected and how these are obtained:

We do not process Special Categories of your Personal Data as defined in the data privacy law, i.e. we do not process any kind of sensitive information about you.

 

4. HOW LONG DO WE PROCESS YOUR DATA?

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Where we determine that there is no longer any need or requirement to retain your Data, we will no longer Process that Data and your Data will be deleted in accordance with our Privacy Policy and applicable laws.  If you want to receive more information about our data processing practices, we can be reached at the contact details set out in this Privacy Policy’s Section 10.

 

5. WHAT WE DO WITH THE INFORMATION WE GATHER

We use the information to maintain relations with customers, to inform customers about 4Subsea’s commercial interests, and to communicate information about 4Subsea and its products and services. Processing is necessary for the legitimate interests of 4Subsea, cf. GDPR article 6.1 (f). The legitimate interests are commercial activity and marketing (sending newsletters) and informing about current changes in 4Subsea. In our view, this does not represent a risk for your rights and freedoms. We have made individual assessments of the processing in relation to the different purposes.

 

6. WHO ARE RECIPIENTS (OR CATEGORIES OF RECIPIENTS) OF THE PERSONAL DATA?

Your Personal Data may be sent to or may be accessed by the following recipients, solely in a role as Data Processor for 4Subsea:
  • Microsoft Office 365, Norway (CRM)
  • ClickDimensions, USA (Email marketing)
  • 4Subsea Ltda, Brazil (Subsidiary)
  • Intercom, USA (Customer messaging platform)

In all these instances, we have appropriate contractual and security measures in place to ensure that personal data is protected. Please contact us if you need any further information, cf. section 10.

 

7. IS YOUR DATA USED FOR AUTOMATED DECISION-MAKING?

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not use automated decision-making.

 

8. YOUR RIGHTS IN RELATION TO OUR PROCESSING

You have rights in relation to our Processing of your Data. These rights are summarised in Annex 1 to this Privacy Policy. You can exercise your rights at any time by contacting us at the contact details set out in Section 10 below.

 

9. COOKIES

We use cookies on our website. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. You can delete or block cookies, but his might lead to some parts of our website not working properly. If you continue without changing your settings, we’ll assume that you are happy to receive cookies from this website.

Unless you adjust your browser settings to refuse cookies, we will see this as a consent and issue cookies when you interact with us. Processing is necessary for the legitimate interests of 4Subsea, cf. GDPR article 6.1 (f). The legitimate interests are delivering, developing and improving 4Subsea’s services, and customise or modify our services. In our view, this does not represent a risk for your rights and freedoms.

Overview Over Cookies in Use:

 
Google Analytics:

_ga: Used to distinguish users. Expires after 2 years.
_gat: Used to throttle request rate. Expires after 10 minutes.

 

Click Dimensions:

_cuvid: Used to determine unique visitors to the site. Expires after 2 years from set/update.
_cusid: Used to establish and continue a user session with the site. Expires after 30 minutes from set/update.
_cuvon: Used to signal the last time a visitor viewed a page. Expires after 30 minutes from set/update.

 

10. CONTACT US

4Subsea is the Data Controller. For any questions regarding this Privacy Policy, data processing, or to exercise your rights, please contact us at privacy@4subsea.com or +47 66 98 27 00.

 

If you believe that your data protection rights have been breached by 4Subsea, please let us know. You also have the right to lodge a complaint with Datatilsynet, the supervisory authority for data protection issues in Norway. We appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

 

Last updated May 24th 2018

 

ANNEX 1

The rights that are referred to in Section 8 of the Privacy Policy must be interpret in accordance with GDPR, and are:

 

1. Right of Access
You have the right to receive confirmation as to whether your Data is being Processed by us, as well as various other information relating to our use of your Data and copies of that information. You also have the right to request access to your Data which we are Processing.

 

2. Right to Erasure
You have the right to request us to erase your Data.
We shall comply with your request without delay unless an exception to compliance applies, for example if the Data is required to establish, exercise or defend legal claims.

 

3. Right to Object
You have the right to object to us Processing your Data.  The relevant circumstances where you may invoke this right are where we are Processing your Data based on our legitimate interests. If you ask us to stop Processing your Data, we will stop Processing your Data unless we can demonstrate compelling grounds as to why the Processing should continue in accordance with data protection laws or, if the information is required to establish, exercise or defend legal claims.

 

4. Right to Rectification
You have the right to require us to rectify any inaccurate Data we hold about you. You also have the right to have incomplete Data we hold about you completed, by providing a supplementary statement to us.

 

5. Right to Restriction
You have the right to request that we restrict the Processing of your Data.
Where any exercise by you of your right to restriction determines that our Processing of particular Data is to be restricted, we will then no longer Process the relevant information, except for storage purposes and for the purpose of establishing, exercising or defending legal claims.

 

6. Right to Withdraw Consent
In certain circumstances, you may have given your consent to us for the Processing of your Data. You have the right to withdraw your consent at any time. To do this, you should contact 4Subsea in accordance with section 10 in this Privacy Policy.

 

7. Right to Data Portability
You have the right request that you receive copies of the relevant Data provided by you in structured, standard machine-readable format and, where technically feasible, to request that this information is transmitted directly to another controller.
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