Last updated: April 15th, 2021
This Privacy Statement (the "Privacy Statement") is provided by: Rosberg AS ("Rosberg"/"we")
Kaien 11, 4250 Kopervik, Norway
Business organisation number 919 822 457
This policy describes what information we collect when you use Rosberg’s sites, services, mobile applications, products, and content (“Services”). It also provides information about how we store, transfer, use, and delete that information, and what choices you have with respect to the information.
This policy applies to Rosberg’s secure communication solution, including the website, Verji webapp and Verji mobile applications, and other Rosberg websites (collectively “the Websites”), as well as other interaction (e.g. customer support conversations, user surveys and interviews etc.) you may have with Rosberg.
This policy applies where we are acting as a Data Controller with respect to the personal data of users of our Services; in other words, where we determine the purposes and means of the processing of that personal data. For content and data that you send through the Service (“User Content”), you are responsible for ensuring this content is in accordance with our Terms of Service, and that the content is not violating other users’ privacy.
How we collect, process and store information
At Rosberg we are committed to safeguarding the privacy of our users. Our business model is to provide a paid service to organisations who need secure and compliant instant communication and does not rely on widespread collection of general user data. We will only collect information that we need to deliver the service to each organisation and continue to maintain and develop the service.
Rosberg may collect, store and process various kinds of data, with different legal grounds, as listed below. For the categories of data that require consent, we refer to the data processing agreement with your organisation. organisation can edit, control and delete their data by logging into their admin site and by contacting support
The following is a list of data we collect, process or store, with the purpose and legal ground listed for each item or group of items having the same purpose and legal ground:
User account information
Organisations that choose to register at Rosberg, will have to provide a valid e-mail address, phone number and name for each user.
The information may be used for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. This is required to deliver the Service to you as user, by taking steps, at your request, to enter into such a contract (Terms of Service) cf. GDPR art. 6 (1) b.
When you as a user interact with the Services, we collect metadata to provide additional context about the way the Service is being used. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our server software and our analytics tracking system.
Product Analytics data. Rosberg.com logs clicks when you as a user interact with our websites and when you visit a page. We do not collect or record the content in conversations between users of Verji, due to all conversations being end to end encrypted the user can be sure their privacy is complete.
Technical log data. Like most digital services, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited within the Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
Device information. Rosberg may collect information about devices used to access the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this information depends on the type of device used and its settings.
Location information. We receive information from you and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Rosberg may also collect location information from devices in accordance with the consent process provided by your device.
The legal basis for this processing is our legitimate interests cf. GDPR art. 6 (1) f, namely using this data for the purpose of ensuring the proper administration of our website and business, analyzing the use of the website and services, monitoring and
Customer Support Information
We may process information that you send to us, should you choose to submit a ticket to our support email. If you contact us, we may use Verji to respond.
Collecting this information is required for performing the contract we entered into with your organisation, (our Terms of Service), as well as our legitimate interest of handling your requests cf. GDPR art. 6 (1) f.
Product & Marketing communication
We may process information that you provide to us for the purpose of subscribing to our email newsletters. You can in each email choose not to receive future emails.
The notification data may be processed for the purposes of sending you relevant product information or newsletters. The legal basis for this processing is your consent cf. GDPR art. 6 (1) a.
Service and transactional notifications
Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “service or transactional” emails (unless you delete your account).
The legal grounds for collecting this information is that it is required for performing our commitment about communicating changes in plans and pricing to you in the contract we entered into with you, at your request (our Terms of Service) cf. GDPR art. 6 (1) b, and our legitimate interest of communicating important information about your account to you, cf. GDPR art. 6 (1) f.
We may process information that you choose to share with us if you participate in a focus group, contest, activity or event, apply for a job, interact with our social media accounts or otherwise communicate with Rosberg.
The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests cf. GDPR art. 6 (1) f, namely the proper administration of our website and business and communications with users.
How we process messages, attachments and speech
Verji is an end to end encrypted secure instant communication platform. The fact that all communication is end-to-end encrypted means that only the receiver can decrypt and access the information.
All communication be it text messaging, attachments, voice or video calls that are handled by Verji are highly encrypted.
Providing your personal data to others
We may share information about you with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonymization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) to protect the vital interest of others, when we have reason to believe that doing so will prevent harm to someone or illegal activities.
Our categories of service providers and partners are:
Analysis tools providers
Customer Support tools providers
Marketing and email providers
Internal communication tools providers
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
International transfers of your personal data
Your personal data may be transferred to countries outside the European Economic Area (EEA).
Rosberg`s office is in Norway. The hosting facilities for Account information and usage information stored by Rosberg are situated in EU and Norway. The hosting facilities for Rosberg`s website, CRM and web analytics tool are in the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data- protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third- countries_en.
Retaining and deleting personal 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.
We will retain your personal data as follows:
Transaction information will be retained for a minimum period of 5 years following the date of the transaction, and for a maximum period of 10 years following the date of the transaction.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
The account information will be retained until you decide to delete your account.
Information about you used for Product & Marketing communication will be retained as long as you have given us consent to use this information
The period of retention of usage information will be determined based on the need for historical data to determine statistical validity and relevance for product decisions and technical monitoring.
Regardless of the provisions above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Changes to this policy
We can change these Terms at any time. We keep a historical record of all changes to our Terms. If a change is material, we’ll let you know before it takes effect. By using Rosberg products on or after that effective date, you agree to the new Terms. If you don’t agree to them, you should delete your account before they take effect, otherwise your use of the Service and Content will be subject to the new Terms.
Managing and deleting your personal information
If you have a Verji account, you can access, modify, delete or export personal information through your organisations Admin access. If you delete your account, your information and content will be unrecoverable after that time. We may withhold personal information that you request to the extent permitted by law.
As an individual you are granted rights according to the applicable data protection law:
The right to access to your personal data
The right to rectification of your personal data
The right to object to and restriction of our processing of your personal data
The right to be forgotten; erasure of your data.
The right to data portability.
If you have provided your consent to your processing of personal data, you may also withdraw your consent at any time through your organisations admin access.
The rights are not absolute, and you may read more about your rights in the EU general data protection regulation Chapter III, or at https://ec.europa.eu/info/law/law- topic/data-protection/reform/rights-citizens_en
To exercise your rights or if you otherwise have any questions regarding our processing of your personal data, we encourage you to contact us as described below. However, we also notify you that you may raise complaint to a data protection authority, e.g the supervisory authority where you live or the Norwegian Data Protection Authority. You may find further information on their
Data protection officer
Our data protection officer's contact details are: Unni Bergquist firstname.lastname@example.org
What is a cookie?
A cookie is a small text file with an identifier sent by us to your computer or mobile device and stored in your browser. “Session-based” cookies last only while your browser is open and are then deleted. “Persistent” cookies last until you or your browser deletes them, or they expire. Cookies do not typically contain any personally identifiable information but may be linked to personal information we store about you. E.g. if you are logged in with a registered user, the cookie will help us remember that you are logged in when you return to the site. To find out more about cookies,
visit this site.
What is local storage?
Local storage is a method by which web pages can store information inside your web browser. Similar to cookies, this stored information exists even when you close a browser tab, surf away from the current website or close the main browser. But unlike cookies this data is not carried to the remote Web server unless sent explicitly by the web page. Local storage is often used to remember choices a user has made inside a web application or to cache information to improve performance. Elements stored in browser local storage is covered by this policy to the extent that the information stored in these elements is communicated back to the server.
Managing cookies and local storage
Most browsers allow you to refuse to accept cookies and to delete cookies. If you block cookies, you may not be able to use all the features on our website or have a worse experience. Please check the links below for how to block and delete cookies and local storage elements.
Cookies and local storage that we use
We use local storage to identify you when you visit our website. If you're signed in to Rosberg.com, this helps us show you the right information and personalize your experience.
Please find below the full list of cookies that Rosberg and our providers use:
Wix Privacy and Cookies Policies: https://www.wix.com/about/privacy
Hubspot Privacy and Cookies Policies: https://legal.hubspot.com/privacy-policy
Third Party web browsers cookie/privacy policies:
We may make available integrations to other web-based services, allowing you to open those services inside Rosberg.com. In order to use third-party integrations in this category, it may be necessary for you to enable support for third-party cookies in your browser. The reason for this is that such integrations may depend on cookies to assert your identity and/or authenticate your access to any non-public assets (documents, boards, etc) opened through them.