1. Introduction
First Scandinavia Partner AS («hereinafter “we”, “First Scandinavia Partner”, “FSP” or “Company”) offers the websites firstscandinavia.org, hjernekraft.org, newtonroom.com and newton.no (hereinafter referred to as «FSP’s websites», «our websites» or «the websites»), newsletters and the possibility to use Newton-rooms in an educational setting through organizing on newtonroom.com.
The object of this privacy statement is to provide information concerning how and why FSP collects and processes personal data concerning visitors of FSP’s websites, in relation to our newsletters and for users of newtonroom.com. FSP is the data controller for the processing of personal data concerning visitors of FSP’s websites and subscribers of our newsletters. FSP is the data processor in relation the personal data that are processed concerning users of netwonroom.com.
It is important to us that your personal data and your personal integrity is protected and that we process information and personal data we hold about you in a lawfully and transparent manner in accordance with the applicable data protection regulations, hereunder the General Data Protection Regulation (GDPR) and other national and EU/EEA privacy legislation. Personal data is any information relating to an identifiable natural person, while processing means any operation or set of operations that is performed on personal data or on sets of personal data. These, and other terms used herein, shall have the meaning given to them in the relevant legislation.
2. How, Why and How Long We Process Personal Data
2.1 As Visitors of our Websites
This website collects standard internet log information, including IP-address, browser type and language, operating system, screen size, access times and referring URLs. In order to ensure that this website is properly administered and to facilitate better navigation, the Company or our service provider can make use of cookies (“cookies”, small text files stored in the user’s browser) or web beacons (“web beacons”, electronic image which allows this website to count number of visitors which have had access to a specific site, and in order to access certain cookies) to collect aggregated data.
We use Google Analytics in order to collect information about how visitors use the website through cookies. We use this information to generate reports that are further used to improve the website. The cookie information is not directly identifiable. Consequently, the information only says something about the number of visitors to the website, where they come from and which websites they visit. The information is exclusively used for internal review in connection with website optimization and is not shared with third parties.
Furthermore, we use Facebook to collect information about visitors in order to personalize our marketing on Facebook. This may mean that you will see specified offers directed towards you after having visited our website based on aggregated data from your visit statistics. The information processed is directly identifiable.
Processing and storage of personal data through use of cookies requires that the visitor is informed about the use of cookies and that the person has given his/her consent (cf. the Norwegian Act on Electronic Communications section 2-7b). Cookies are a standard internet technology used by most web sites. A cookie will be added to your browser's internal memory, which will help us to better understand how you use the site. In the long run, we use this knowledge to offer you a better experience the next time you visit the website. Supplementary information about the use of cookies on our website is available in our privacy policy. In most newer browsers, such as Opera, Internet Explorer, Firefox, Safari etc., cookies are accepted automatically. Please check your consent settings for cookies in your browser. If you do not want to accept cookies from our website, you must change the settings in your browser.
2.2 As a Subscriber to Our Newsletter
You can choose to subscribe and receive our newsletter. Newsletters will, among other things, contain information on services offered by First Scandinavian Partner that we believe may be of interest to you, together with general updates about FIRST LEGO League. In such cases, the information you provide will be stored on your profile. This includes the information you fill out about yourself when subscribing:
- Name: in order for us to manage your profile and address you in a more personal way.
- E-mail address: to be able to send you the newsletters.
The lawfulness of processing personal data for sending out newsletters is your consent given upon subscription to our newsletters.
FSP uses the services Mailchimp and SuperOffice when sending out the newsletters. The services process your personal data based on a data processor agreement entered between FSP and the other vendor. This means that the information that is being sent out, including your name and e-mail address, will be stored by our data processors in order to be able to preserve the logs for transmission. Contact information for each of the processors can be found by clicking on the link associated with the service names.
When you are a subscriber, FSP will register which newsletters you receive, what type of links you click on and which of our websites you visit. We do not collect information about your use of other services or digital channels unless it is our own. The information about your activity is stored on your profile card and used to give us insight into how actively you use our pages, how interested you are in our services and which topics that interest you the most. This information can be used to customize our inquiries so that they correspond with your interests.
FSP has a legitimate interest in becoming better acquainted with the preferences and interests of the readers of our newsletters, so that we can offer news and services that better suit their needs and desires. The registration of such information is necessary to safeguard this interest. The logic used for this limited profiling activity is simple and consists mainly of the fact that different activities the subscribers undertake are given a point value, which is summed up together. The registration is limited and is therefore not considered as invasive, so our legitimate interest can therefore serve as a lawful basis for processing. For further questions related to this you can use our contact form.
You can at any time request access to the data in question, and request that we stop registering such activity data about you and that the information we have stored shall be erased. Read more about this in section 4.
In exceptional cases, your personal data may be used to protect our and our visitors' rights or property and, where applicable, to comply with legal processes. This will only be applicable in very special cases, and will never happen without this being in accordance with applicable privacy legislation.
The personal data we have stored about you, who have agreed to receive our newsletters, is stored as long as you are a subscriber. If you withdraw your consent, the information we have stored will be erased within reasonable time.
2.3 As a User of Newtonroom.com
2.3.1 Personal Data
As a user of newtonroom.com, and in order to participate in the teaching hosted by Newton, conducting tests and receiving distributed teaching materials, we will, on behalf of the institution running your local Newton platform at newtonroom.com, process information about teachers and students (separately “user”, joint “users”) that are needed to accomplish this. For processing this data, FSP will be a data processor.
The data controller of the personal data processed is the institution that operates your local Newton platform. This can be either the school, the municipality, a private organization or your county authority. If you are uncertain of who is running your local educational platform at newtonroom.com, please send us an email at [email protected] or fill out our contact form and we will help you identify the correct controller.
For teachers, the necessary personal data includes:
- Name: To get an overview of who is the class teacher, and to manage the access control to our premises;
- Employer/school: To gain insight to which schools use the teaching platform and to form the basis for cooperation;
- Contact information (e-mail and phone number): In order to reach the teacher with information about lessons in the Newton room, for organizational reasons or if something should happen.
For students, the necessary personal data includes:
- Name: To have an overview of who is enrolled in the lessons, making it possible for students to create their own users and to manage the access control to our premises;
- Date of birth: To identify the student and the class the student is in;
- School: To be able to identify the school the student attends;
- Class teacher at the school: To be able to identify who is the student's contact person at the school.
The data is being processed based on a data processor agreement entered between FSP and the local institution for newtonroom.com.
As part of the institution's customer relationship with us, all emails sent to us will be stored on your user as long as we process data about you on behalf of the institution operating your local Newton Room. This is to provide better customer service, as well as understanding your needs when using the Newton rooms.
The personal information will be erased at the request of your affiliate institution. This will either be after the end of the school year, or after the student has finished or quit the affiliated school.
2.3.2 Special Categories of Personal Data
We generally do not ask for special categories of personal data (e.g. information related to race or ethnic origin, religious beliefs, criminal record, physical or mental health or sexual orientation) from users. In order for anyone enrolled in the teaching to be able to participate independently of their state of health, we may ask, on behalf of the institution that runs your local Newton Room, about information on other special needs that may require accommodation on our side. All such information is collected only if you choose to provide this information and only for the purpose of performing adequate teaching throughout the school year. Upon your request, we will erase the information. In any case, the information will be erased after the end of the school year, or after the student has finished or has quitted the affiliated school.
2.3.3 Children’s’ Data Protection
We understand the importance of protecting children's privacy in the interactive electronic world. Newtonroom.com is designed to securely process personal information about children 16 years and younger.
2.4 When Filling in our Contact Form
When you contact FSP you need to fill out a contact form so that we can contact you in the best possible way and get an overview of what we can help you with in order to provide better customer services. In the contact form, we ask you to provide the following personal data:
- Name: In order to know who is contacting us.
- Contact information (e-mail and phone number): To be able to reach you so we can help you;
- If you are a user of netwoonroom.com, the name of your local Newton room institution: to be able to locate the problem and help you in a more efficient way.
For visitors of FSP’s website and subscribers to our newsletters, we will store this information as long as the issue is unresolved. After the issue has been resolved, the information you provide will be erased.
For newtonroom.com users, please look at our erasure routines in section 2.3.1.
3. Information Security
We have introduced good commercial standards for technology and operational security, to protect all information provided by visitors through this websites from unauthorized access, disclosure, alteration or destruction.
4. Your Rights
As a data subject you have several rights in relation to our processing of your personal data. In the following, we will inform you about these rights, and how you can exercise these rights towards FSP in relation to our websites, newsletters and educational platforms (newtonroom.com).
If you have questions related to your rights, or would like to exercise them towards FSP in connection with our websites, newsletters or educational platforms, please send us an e-mail at [email protected] or fill out our contact form.
You can send us a request regarding access to information about whether we are processing personal data about you in connection with our newsletters, use of newtonroom.com, and thus gain access to which personal data we are processing about you if you are registered.
4.1 Access to Your Personal data
You can send us a request regarding access to information about whether we are processing personal data about you in connection with our newsletters, use of newtonroom.com, and thus gain access to which personal data we are processing about you if you are registered.
4.2 Rectification
If you believe the information we have stored about you are incorrect (e.g. email address, class teacher or school has changed) you time request at any time that we correct this information. In conjunction with your newsletter subscription, or when you are enrolled in teaching through newtonroom.com, the information stored on your profile will automatically be updated in accordance with what you register.
4.3 Objection
If you do not want us to process information about your use of our websites, you can object to the processing.
4.4 Withdrawal of Your Consent
You can at any time easily withdraw you consent for subscribing to our newsletter by unsubscribing at the bottom of the newsletter.
4.5 Erasure
If you withdraw your consent to receive our newsletters, the personal data we process about you will be erased. If you choose to object to our processing of personal data concerning the use of our websites, all activity we have previously registered on your profile will be deleted. If you want your personal data to be deleted under other circumstances, you can easily contact us about this. Your information about your activity on our websites will be deleted within two years.
4.6 Portability
In accordance with article 20 of GDPR you have the right to data portability for the personal data concerning yourself that you have provided to FSP where the processing is based on consent or on a contract. Our newsletters are based on consent, and you will therefore have the right to receive the data you registered about yourself when you signed up as a subscriber. This includes name and email address. If you want to exercise you right to data portability, the relevant data about you will be sent to you, or a third party you designate as long as this is technically possible.
4.7 Right to Restriction of Processing
If you want us to restrict the processing of your personal data, you can request this.
4.8 Right to file a Complaint to the Supervisory Authority
If you believe our processing of your personal data is not compliant with the General Data Protection Regulation or other data protection regulations, you have the right to file a complaint about this to the supervisory authority. In Norway, this is the Norwegian Data Protection Authority and a complaint can be filled on their website www.datatilsynet.no.
5. With Whom Do We Share Your Personal Data?
FSP uses several data processors to process personal data on our behalf. These will under no circumstances process personal data for other purposes than the purposes we determine, in accordance with this privacy policy.
Processing in conjunction to our websites, including newtonroom.com, is carried through by InCreo and IT-Sjefen. Both are IT suppliers and act as data processors on behalf of FSP in this regard.
Processing in conjunction with our newsletters is mainly implemented by the use of the systems of Mailchimp and SuperOffice Norge AS. The systems are cloud-based and act as data processors on behalf of FSP in this regard.
Mailchimp is located in the United States, outside EU/EEA. We only transmit personal data to such countries if the transfer takes place with a sufficient degree of protection; we have a separate agreement with Mailchimp where the transfer only takes place when there is a US Privacy Shield certification. You can find further information about the security mechanisms we use by clicking here.
Mailchimp is registered in USA, but the system delivered to us is operated from the company’s server parks in Europe. Therefore, Mailchimp’s processing of personal data on behalf of FSP does not imply transfer of personal data out of the EU/EEA.
All transmissions will be in accordance to laws and regulations and your personal data will not be used for anything other than what we have already informed you.
Also, personal data may be transferred to the police, public authorities, or to other third parties, if the necessary legal grounds for processing exists and FSP is legally obliged to comply with the request.
6. Data Controller
First Scandinavia Partner is the data controller for the processing of personal data of the visitors of our websites and subscribers to our newsletters.
The data controller of the personal data that is being processed about users of newtonroom.com is the institution that operates your local Newton room. This is either the school, the municipality or your county authority. If you are unsure of who is the right contact institution, please send us an e-mail at [email protected] or fill out our contact form.
7. Changes in Our Privacy Statement
We may change our privacy statement from time to time at our sole discretion. When we make changes to this statement we will change the audit date at the top of this page and the modified privacy policy will be effective from the date or revision. We encourage you to review this Privacy Statement to be informed about how we protect your information. If there are significant changes in the privacy statement, you will receive an e-mail about this.
8. Contact
If you have any questions or concerns regarding your data protection, please contact us by e-mail [email protected] or you can contact us by filling out our contact form. Our mailing address is:
FIRST Scandinavia
Sandhorngata 43
8008 Bodø
