SoluDyne Privacy Statement:
SoluDyne and its subsidiaries, hereby called SoluDyne, respects your privacy. This Privacy Statement outlines the rights to privacy and our commitment to safeguarding personal data.
SoluDyne is a European corporation, with legal entities, business processes, management structures and technical systems that cross borders.

SoluDyne delivers software and services to private and public businesses to Customers in Europe.  SoluDyne’s head office is located in Stavanger and the SoluDyne Group is subject to European privacy legislation, including the GDPR- General Data Protection Regulation. 
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All major decisions regarding privacy in SoluDyne are made at a corporate level supervised by the DPO - Data Protection Officer.
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This Privacy Statement is available on the soludyne.com home page and at the bottom of every SoluDyne website.
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The SoluDyne Privacy Statement helps you understand what personal data we collect and why we collect it, and how we handle, protect, store, export, and delete your personal data.
 
Personal data is information that can identify you as a person, such as an email address, street address, phone number, etc.

How and when does the Privacy Statement apply?
 
This Privacy Statement applies to all business processes in SoluDyne and to all SoluDyne websites, domains, mobile solutions, cloud services and communities as well as SoluDynes branded websites; SoluDynes Sites. Service specific appendices will be found in the Terms of Service, data processing agreements or equivalent information for the specific service in question.
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The Privacy Statement provides information about data processing carried out by SoluDyne when SoluDyne determines the purpose and means of the processing; SoluDyne act as data controller. It also provides information on data processing SoluDyne do on behalf of our Customers based on their instructions, the Customer as data controller and SoluDyne as data processor.
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Personal data is information that can identify you as a person, such as an email address, street address or phone number etc. Processing your personal data is necessary for us to serve our Customers. Please do not use SoluDyne Sites or our services if you do not agree with how we process personal data according to this Privacy Statement.
 
Personal data which SoluDyne may process
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Customer, Partner, Persons representing potential Customers; Leads, Contact persons and software users tied to our Customers, Job seekers.
SoluDyne process personal data about job seekers and contact persons or software users tied to our Customers. In addition we process personal data about persons representing potential Customers; leads that approach us via SoluDyne sites or other channels. Our statement in this regard is to be found in the data controller section.
We also process data on behalf of our Customers of which the Customer is the Data Controller. Our statement in these regards is to be found in the data processor section.
In this Privacy Statement data subjects may also be referred to as persons or you.


How does SoluDyne process personal data as data controller?
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When a SoluDyne subsidiary determines the purpose and means of processing your personal data, this company act as data controller. This includes scenarios where SoluDyne collects personal data in the context of you being a job seeker, you being a representative for a Customer or Lead, or when you are a software user.

 
What are your rights?
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Opt-out of marketing communications: You have the right to avoid receiving unsolicited product or service information of receiving marketing communications from SoluDyne and may do so by either:
 

• Following the instructions for opt-out in the relevant marketing communication,

• Change preferences under the relevant edit account section if you have an account with SoluDyne

• Contacting us via contact webform here

• By using SoluDynes subscription manager

 
Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from SoluDyne, such as order confirmations and notifications necessary to manage your account or the services provided to Customers.
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Accessing personal data: You have the right to access your personal data by requesting an overview of the personal data we process about you and you may have a right to data portability.
Correcting personal data: You also have the right to request that SoluDyne corrects inaccuracies in your personal data. If you have an account with SoluDyne for a SoluDyne Site, this can usually be done through the appropriate "your account" or "your profile" sections on the applicable SoluDyne Site or service.
Deleting personal data: Further, you have a right to request deletion of personal data, and to restrict or object to our processing of your personal data according to this Privacy Statement or other service specific terms.
 
Please use SoluDyne Contact webform here to file all requests as mentioned in this section. You also have a right to file a complaint with the data protection authorities with regards to our processing of your personal data
 
How does SoluDyne protect and store personal data?
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How we keep your personal data secure
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SoluDyne takes the trust you and our Customers place in us very seriously. SoluDyne is committed to preventing unauthorised access, disclosure or other deviant processing of personal data. SoluDyne shall ensure the confidentiality of personal data we process, maintain the personal data integrity and secure its availability according to applicable privacy legislation.  
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As part of our commitments, we utilize reasonable and appropriate organizational, technical and physical procedures and measures to safeguard the information we collect and process, taking into account the type of personal data and risk posed to you and our Customers upon breach. Since root causes for privacy breaches are most likely to be found internally, we believe that building a strong corporate culture where respect for and awareness around privacy among our employees are fundamental to ensure lawful processing and protection of your data.  The following measures are of particular importance in this regard:
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Organisational
 

• The Data Protection Council governing lawfulness of processing and privacy policies for the SoluDyne Group. The council is staffed with internal privacy and information security experts supervised by the Corporate Data Protection manager

• eLearning privacy courses that are mandatory for all employees 

• Mandatory procedures for keeping records of processing activities and assessing risks for data subjects applies to all SoluDyne subsidiaries

• Data processing agreements with subcontractors that process data on behalf of SoluDyne

 
 
Technical
 

• Classification of personal data to ensure implementation of security measures equivalent to risk assessment

• Assess the use of encryption and pseudonymisation as risk mitigating factors.

• Limiting access to personal data to those that need access to fulfil obligations according to law or service agreement etc.

• Manage systems that detects, restores, prevents and reports privacy incidents.

• Use security self-assessments to analyse whether current technical and organisational measures are sufficient to protect personal data, taking into account the requirements outlined in applicable privacy legislation.

 
Physical
 

• Premises protected by access control and video surveillance systems
   

 
How long do we store your personal data
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SoluDyne will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve challenges and to comply with legal requirements under applicable laws.
This means that SoluDyne may retain your personal data for a reasonable period after you and our Customer’s last interaction with us. When the personal data that we collected is no longer required we erase it.  We may process data for statistical purposes, but in such cases, data will be pseudonymised or anonymised.


How does SoluDyne protect and store personal data as data processor?
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SoluDyne provides many different services to our Customers. Most of our services involves processing of the Customers’ data, hereunder their personal data. The purposes of processing is determined by our Customers not by SoluDyne. Making the Customer the data controller. SoluDyne do in such cases act as data processor and process the data on behalf of and according to instructions given by the Customer. The relation between the Customer as Data Controller and SoluDyne as Data Processor is regulated by a separate Data Processing Agreement with each Customer.
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The Customer's obligations: When the Customer act as data controller the Customer shall, according to applicable privacy legislation, ensure the legal grounds for processing the personal data. Further, the Customer shall assess and establish ownership to the risks posed to data subjects by processing their personal data. Another important aspect of the Customer’s duty as data controller is to comply with the information duty towards data subjects.
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SoluDynes obligations: SoluDyne is a natural part of the Customers duties as data controller, in the sense that SoluDyne’s services constitutes parts of the processing of personal data that the Customer must ensure are compliant with applicable privacy legislation.  Thus, when SoluDyne processes personal data on behalf of its Customers, we must do so in accordance with privacy legislation applicable for data processors.      
In short, the Customer and SoluDyne are obligated to cooperate to ensure privacy for data subjects. SoluDyne shall provide the information necessary for the Customer to be compliant with applicable privacy legislation.
 

In what manner does SoluDyne use subcontractors?
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SoluDyne uses subcontractors to process personal data and may export your or our Customers data outside the EU in this regard. These subcontractors are typically vendors of cloud services or other IT hosting services.
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When using subcontractors, SoluDyne will enter into a data processing agreement (DPA) with subcontractors in order to safeguard your privacy rights and to fulfil our obligations towards our Customers.  When subcontractors are located outside the EU, SoluDyne ensures legal grounds for such international transfers on behalf of you or our Customers, hereunder by using the EU Model Clauses and making sure that we fulfill the additional requirements for transferral according to GDPR.
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SoluDyne relies on some strategic external third parties to support our business processes and to provide our cloud services. These third parties include but are not limited to:
 

• Visma.net (N), provider of our preferred accounting system

• Visma Sign (DK, N) provider of our preferred document signing solution

• e-conomic (DK), provider of our preferred accounting system

• Telia (N), Data Center

• Microsoft Teams (EU), Customer Support and Sales

• Google Analytics (EU)

 
You are welcome to request an overview and more detailed information on SoluDyne’s subcontractors, hereunder documentation of legal grounds for international transfers mentioned above.
 
Changes to this Statement
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We encourage you to review the Statement regularly. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and or social media pages prior to the changes taking effect.
The Privacy Statement is revised at least yearly and changes are approved by the SoluDyne Privacy Council. Last updated: 20210811.
 
How to contact us?
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We value your opinion. If you have any comments or questions about our Privacy Statement, any unresolved privacy or data use concerns that we have not addressed satisfactorily, or concerning a possible breach of your privacy, please send them via contact webform. You can also send it in writing. In privacy matters, contact at privacy@soludyne.com.
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We will handle your requests or complaints confidentially. Our representative will contact you to address your concerns and outline the options regarding how these may be resolved. We aim to ensure that complaints are resolved in a timely and appropriate manner.
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