PRIVACY POLICY
Last updated 07.08.2024
1. INTRODUCTION
Optime Subsea is committed to your right to privacy. This Privacy Policy ("Privacy Policy") has been prepared by Optime Subsea AS, Optime Holding AS, Optime Subsea Services AS and Optime Subsea Services Inc. ("Optime Subsea", "we", or "us") to ensure that you receive the information we are required to provide to you, and which is necessary for you to exercise your rights under the General Data Protection Regulation (the "GDPR") and Norwegian data protection legislation (together "data protection legislation").
This Privacy Policy describes how we process personal data about you, the purpose of our processing activities, and the legal basis for our processing activities. This Privacy Policy also describes your rights under applicable data protection legislation and other relevant information relating to our processing of personal data.
As a "data controller", Optime Subsea is responsible for ensuring that all processing activities we initiate, for example as part of providing our website and other services, are in compliance with the data protection legislation.
2. GENERALLY ABOUT PERSONAL DATA
Personal data means any information relating to an identified or identifiable natural person (a "data subject"). A person's name, phone number, email address and address may constitute personal data. Processing of personal data comprises any operation or set of operations which is performed on personal data, such as collection, assembly, storage and other forms of use.
3. WHOSE PERSONAL DATA WE PROCESS
This Privacy Policy describes our processing of personal data regarding the following categories of data subjects:
• Visitors on our website
• Persons contacting us via email, social media or the contact form on our website
• Business associates, such as customers, partners and suppliers
• Visitors to our premises
• Shareholders and directors
• Job applicants
4. OUR PROCESSING OF PERSONAL DATA
The personal data we process depends on the context of your interactions with Optime Subsea. The following includes information about the personal data which we process, and the purposes which the personal data is processed for.
Personal data collected from representatives of our business associates
We process personal data about representatives of our business associates (e.g. customer, partners and suppliers). This includes the following personal data:
• the representative's name, telephone number, email address, position, employer and place of work
• the representative's signature as included in the agreements we have entered into.
We process personal data about the representatives and contacts of our business associates in order to fulfil any contractual obligations with them (e.g. registering a purchase) or in furtherance of our legitimate interest in establishing and administering the business relationship we have with these persons.
Personal data we process when you contact us
If you contact us through social media, e-mail or by the contact form on optimesubsea.com, we may collect the following information about you:
• e-mail address
• technical information such as operating system, version, browser, IP-address, location based on IP address
• any personal information that appears in your inquiry
The purpose of our processing is to be able to answer your inquires and offer support. We process this data based on our legitimate interest in answering inquiries and helping users who have reached out to us.
Personal data we process when you visit our premises
We process personal data concerning visitors to Optime Subsea's premises for visitor management purposes. Such personal data include the name and contact details of the visitors, as well as the time of the visit. We process the aforementioned information based on our legitimate interest in keeping account of the persons that have visited our premises].
Personal data we collect from visitors to our website
We process personal data relating to visitors to our website. For example, we may offer website visitors to register on our website in order to access certain additional functions. The registration data we receive will only be used for the purpose of providing you with the relevant site or service. We process the aforementioned data based on your consent per Art. 6 (1) (a) GDPR. You may revoke your consent at any time by contacting us as described in Section 12 below.
We may process personal data from visitors to our website via cookies, for example to be able to provide certain functions that the website visitor wish to use, based on our legitimate interests in providing an optimized service free of errors. Although we generally use anonymized data for this purpose, we may also process personal data about website visitors to create statistics and analyses, for example regarding the number of website visitors, which pages are visited and the duration of a visit. We process personal data for the purpose of creating statistics and analyses in furtherance of our legitimate interests in improving our services and websites and understanding how users interact with them. For further information about our use of cookies, please see Section 5 below.
Personal data we process to comply with legal obligations
We may store and otherwise process certain personal data because we are required to do so pursuant to applicable law, for example obligations pursuant to the Norwegian Bookkeeping Act. For example, we may process personal data of our shareholders and directors due to obligations in the Limited Liability Companies Act. We may also process personal data to comply with requests by public authorities, court orders and other appropriate legal mechanisms.
Personal data we process for marketing purposes
We may provide contact persons of customers, visitors to our facilities and others with information about our products, campaigns and other business initiatives of Optime Subsea. For the purpose of providing such marketing material, we may process personal data such as name and email address. We will only process personal data for marketing purposes based on the recipient's consent and/or our legitimate business interests in promoting Optime Subsea and our service offerings and initiatives.
Recipients of newsletters may terminate a newsletter subscription at any time by following the "unsubscribe"-information included in the newsletter emails or by contacting us as described below.
Personal data we process about job candidates
If you are a job applicant or a potential candidate for any of our positions, we may collect and process the following information:
• contact details, such as your name, email address, postal address and phone number
• your cover letter and CV, as well as test results, diplomas, certifications and statements from references
• interview history, questions, notes and, if relevant, assessment results
• any other information that you provide to us in connection with the application process
We may also process the aforementioned personal data when we assist companies we have ownership interests in with hiring new personnel.
Our processing is based on our legitimate interest in finding and hiring new personnel, as well as assisting companies which we have ownership interest in with the same.
For information about how we process personal data of our employees, please refer to our internal Privacy Policy for employees.
5. OUR USE OF COOKIES
Cookies are small pieces of text used to store information on the user's web browser or computer hard drive. They are widely used to store and receive information to make websites work, or work more efficiently, as well as to provide information to the website owner about the users' surfing behavior. The cookies we use allow us to collect information such as browser type, IP address and anonymous traffic data and allow us to, for example, see how users navigate on our website.
We use cookies for the following purposes:
• Necessary cookies. These cookies are necessary for the website to function properly. They ensure basic functionalities and security features.
• Performance cookies. These cookies, often also referred to as analytical cookies, are used to gather statistical information about the use of our website. We use this data for performance and website optimization.
• Functional cookies. These cookies enable more functionalities for our website visitors. For example, these cookies may be used to recognize you and your preferences (such as your choice of language) when you return to our website.
• Advertising cookies. These cookies, also called marketing cookies, are set by external advertising partners and are used for profiling and tracking data across multiple websites. If you accept these cookies, we may show our advertisements on other websites based on your user profile, user activity and preferences.
You can find more information about the individual cookies we use, and the purposes for which we use them, in the table below:
Cookie |
Category |
Description |
Provider / Domain |
| __cf_bm | Strictly necessary | This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. | Cloudflare Inc. / .vimeo.com |
| CookieScriptConsent | Strictly necessary | This cookie is used by Cookie-Script.com service to remember visitor cookie consent preferences. It is necessary for Cookie-Script.com cookie banner to work properly. | CookieScript / .optimesubsea.com |
| _cfuvid | Functionality | This cookie is used for purposes of tracking users across sessions to optimize user experience by maintaining session consistency and providing personalized services. | .vimeo.com |
| _ga | Performance | This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. | Google Universal Analytics / .optimesubsea.com |
| _ga_LPXE2VLD3N | Performance | This cookie is used by Google Analytics to persist session state. | Google Analytics / .optimesubsea.com |
You can choose to opt out of all but the necessary cookies. You may change your cookie preferences at any time by clicking on the cookie banner at the bottom of our website. You can then adjust the available sliders to ‘On’ or ‘Off’, and click "Accept settings". You may need to refresh your page for your settings to take effect. You may also disable the cookies we use through the settings in your internet browser. Please note that if cookies are disabled, some or all of our services may become unavailable or not function as intended.
6. SHARING OF PERSONAL DATA AND INTERNATIONAL TRANSFERS
We use external service providers to assist with IT services and other administrative services. These service providers will act as data processors on our behalf. We have entered into data processing agreements with our processors which contain obligations for each of the data processors to implement technical and organizational measures to ensure an appropriate level of security, confidentiality and integrity for the personal data, as well as to only process the relevant personal data in accordance with the data protection legislation and our instructions.
In addition, we may share your personal data with our affiliates, with potential buyers (in the case of a sale, merger, consolidation, liquidation, reorganization or acquisition), with social media partners (both via our websites and the social media platforms) and with any other person or entity subject to your consent.
We will not disclose your personal data to any other third parties than the third parties described above, unless we are required to do so under applicable law, or if it is necessary in order to establish, exercise or defend legal claims.
We will only transfer personal data to countries outside the EU/EEA in accordance with applicable data protection legislation, including by using a valid data transfer mechanism, such as the Standard Contractual Clauses ("SCCs") issued by the European Commission.
7. THIRD-PARTY APPLICATIONS, PLUGINS AND WEBSITES
We may use personal data to enable your use of integrations, plugins and other functionalities we offer on our website. For example, our website uses plugins from YouTube, which is operated by Google. If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
Your interactions with the third-party features are governed by the privacy policies of the companies that provide them.
8. RETENTION OF PERSONAL DATA
We will delete or anonymize personal data when they are no longer necessary in relation to the purposes for which they were collected or otherwise processed. For instance, we delete personal data in accordance with the criteria included below:
• Personal data we process to comply with legal obligations will be deleted or anonymized when it is no longer necessary to process the data to comply with the relevant legal obligations. For example, bookkeeping material is kept for 3½ or 5 years in accordance with the Norwegian Bookkeeping Act.
• Personal data collected by Optime Subsea for the purpose of administrating contracts with customers and suppliers/partners (including financial advisors, attorneys etc.) may be stored throughout the companies lifetime if such personal data are included in the contract. The company has a legitimate interest in knowing such history beyond the contractual relationship.
• Personal data collected by Optime Subsea for visitor management purposes shall be deleted three months after the relevant visit.
9. SECURITY
As a controller, Optime Subsea is responsible for the security and confidentiality of the personal data we process. We are responsible for implementing appropriate technical and organizational measures to ensure an appropriate level of security of processing.
We are for security reasons not entitled to disclose detailed information on the security measures which we have implemented. However, all of our employees are bound by a duty of confidentiality with respect to the personal data which we process. Furthermore, we have implemented measures, policies and routines to ensure the security of our processing.
10. YOUR DATA PROTECTION RIGHTS
You have the following rights in connection with our processing of your personal data:
• Access: You may contact us if you want to obtain confirmation with respect to whether or not we are processing your personal data, as well as access to and further information regarding our processing of your personal data. You may also request a copy of the personal data we are processing about you.
• Rectification: You may request us to rectify and/or complete inaccurate or incomplete personal data.
• Erasure: You may request that we delete your personal data. We will respect and comply with your request insofar as there are no other legal obligations or overriding legitimate interests requiring further retention, or the personal data is necessary for the establishment, exercise or defense of legal claims.
• Restriction of processing: You may also request the restriction of our processing of your personal data in accordance with data protection legislation. If the processing has been restricted, such personal data will, with the exception of storage, only be processed with your consent, for the exercise or defense of legal claims, the protection of the rights of another person, or for reasons of important public interest.
• Right to object: You are entitled to object to certain processing activities, including for example processing of your personal data for marketing purposes. You are furthermore, on grounds relating to your particular situation (for example, a specific need for protection of your identity), entitled to object to processing of personal data based on legitimate interests, which we will comply with, unless there exists compelling legitimate grounds for our processing which override your interest, or if our processing is necessary for the establishment, exercise or defense of legal claims.
• Data portability: If we process your personal data based on consent or based on our performance of a contract, and the processing is carried out by automated means, you may request us to transfer the personal data to you or another controller, in a structured, commonly used and machine-readable format.
Certain limitations exist in the rights provided by the data protection legislation and the rights available to you will depend on the particular circumstances of the processing.
You may contact us at any time if you have any questions or complaints regarding our processing of your personal data. You may also file a complaint to the Norwegian Data Protection Authority, or a data protection authority in the EU/EEA Member State of your habitual residence, place of work, or the place of the alleged data protection infringement. The Norwegian Data Protection Authority is responsible for supervising Norwegian organizations' processing of personal data.
You can obtain the contact details of the Norwegian Data Protection Authority on the following website: www.datatilsynet.no. You will also find more information on your rights and the data protection legislation on this website.
11. CHANGES TO THIS PRIVACY POLICY
We may update and revise this Privacy Policy to reflect any changes in our processing activities or in applicable data protection legislation or other legislation which may affect our processing of personal data. When we update the Privacy Policy, the updated version will be published on our websites.
12. CONTACT
If you have questions about this Privacy Policy, including how we process personal data, or would like to submit a request to exercise your rights, please contact us at:
Atle Huseby
Chief Human Resources Officer
ahu@optimesubsea.com