Introduction

Exabel AS (“Exabel”, “we”, “us”) is the sole owner of all Exabel software products, Exabel websites, reports, algorithms, tools and services on all Exabel platforms including all software products purchased by you or your business through us or made available by us to you or your business (“Service”). This privacy policy (“Privacy Policy”) discloses how we collect, process, store and share information related to you as you use the Service. The document also outlines your rights to this information. If you do not agree with this policy, please do not access or use the Service.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

The Service is not intended for children and we do not knowingly collect data relating to children.

Important Information and who we are

Exabel is the controller and responsible for your personal data. If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Exabel AS

Email address: contact@exabel.com

Postal address: Peder Claussøns Gate 2, 0165 Oslo, Norway

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What User Information we receive

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Exabel receives a range of personal information about your use of or interest in our Service (we call this “User Information”). Some information is directly provided by you when using the Service, or if you sign up for our updates, some information is collected automatically, and some is obtained from third party sources, as set out below.

Information that you provide to us:

• Account and profile information: We collect information about you when you sign up for our updates, register for (or we provide you with) an account, when you modify your profile, set your preferences, or in other ways interact with options in the Service. This includes information such as your user name, name, title, email address, organization, job title, phone number, company address.
• Support channel information: We collect information that you provide to us through email or support tools, such as concerns, feedback, complaints, or requests regarding your User Information.
• Financial information: we collect information to process payments from you or your business, this includes bank account details, details about payments to and from you and details of products and services you or your business have purchased from us.
• Prospect information: We collect information about you if you sign up for our updates or express an interest in the Service. This includes information such as your name, title, email address, organization, job title, phone number, company address.
• Supplier information: if you are one of our suppliers, we collect information about you to communicate with you: this includes information such as your name, title, email address, organization, job title, phone number, company address.

Information that we automatically collect:

• Device and log data: We collect information about your device and environment when accessing the Service, including your IP address, your operating system and browser, the time and date, the frequency, and other meta information.
• Usage information: We collect information that you create while using the Service, such as companies you enable monitoring for, files you upload, saved searches, saved time series, as well as tracking information we collect which are attached to your login details (excluding the specific data that you review) and IP addresses, and your usage of the features provided in the Service.
• Cookies and tracking technologies: We collect information about how you interact with the Service such as the frequency at which you use different features, and at which level you engage with different content. Please see our cookie policy here for further information.

Information from third party or publicly available sources

We will receive User Information about you from various third parties and public sources as set out below:

From data partners:

Account information: if your access to the Service is being enabled by one of our data partners, the data partner will provide us with information for your account. This includes information such as your user name, name, title, email address, organization, job title, phone number, company address.

Support channels: We collect information that you provide to the data partner through email or support tools, such as concerns, feedback, complaints, or requests regarding your User Information.

Aggregated User Information

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your User Information but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific product feature. However, if we combine or connect Aggregated Data with your User Information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide User Information

Where we need to collect User Information by law, or under the terms of a contract we have with you or your business, and you fail to provide that User Information when requested, we may not be able to perform the contract we have or are trying to enter into with you or your business (for example, to provide the Service). In this case, we may have to cancel a service you or your business has with us but we will notify you if this is the case at the time.

How we use User Information

Exabel uses the User Information where we need to perform a contract with you, where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests, or where we need to comply with a legal obligation. Generally, we do not rely on consent as a legal basis for processing your User Information although we will get your consent before sending newsletters to you via email. You have the right to withdraw consent to our marketing newsletters at any time by contacting us.

See the Glossary at the end of this document to find out more about the types of lawful basis that we will rely on to process your User Information.

Purposes for which we will use the User Information

We have set out below, in a table format, a description of all the ways we plan to use your User Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your User Information for more than one lawful basis depending on the specific purpose for which we are using your User Information. Please contact us if you need details about the specific legal basis we are relying on to process your User Information where more than one basis has been set out in the table below.

Opting out of marketing information

We only send you marketing information if you have consented to receive it. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to User Information provided to us as a result of a subscription to a service or other transactions.

Change of purpose

We will only use your User Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your User Information for an unrelated purpose, we will communicate the changes to you before starting any new processing. This will typically happen through email or through your Profile account. If you disagree with the changes that are made, you should deactivate your Profile account or please contact Exabel support if you wish to request a removal of your User Information under their control.

Please note that we may process your User Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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How we disclose User Information

We may share your User Information with the parties set out below for the purposes set out in the table (Purposes for which we will use the User Information) above.

• Internal Third Parties: other companies in the Exabel Group acting as joint controllers or processors and who are based in the US and the UK and provide product, system administration and commercial services.
• External Third Parties as follows:
• Service providers acting as processors based in the EEA, UK and USA      who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, accountants and insurers based in Norway, the UK and the US who provide consultancy, banking, legal, insurance and accounting services.
• Tax authorities acting as processors or joint controllers based in Norway, the UK and the US who require reporting of processing activities in certain circumstances.
• Marketing agencies that act as processors based in Norway and the UK.
• Government or law enforcement: We may be legally required to share your User Information, for example in case of police investigation or legal proceedings, which will only include User Information that is provided for the given purpose.
• Corporate change: In the event that Exabel is acquired by or merged with a third-party entity, or in any partial or complete sale of assets including in the event of bankruptcy, or in any other corporate change such as Exabel seeking to acquire other businesses or merge with them, Exabel may transfer User Information as part of that merger, acquisition, sale, or other change of control (or in connection with related due diligence) and the new owners may use the User Information in the same way as set out in this privacy policy.

We require all third parties to respect the security of your User Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your User Information for their own purposes and only permit them to process your User Information for specified purposes and in accordance with our instructions.

International transfers

We share your User Information within the Exabel Group. This will involve transferring your User Information outside the EEA.

We transfer User Information between the EEA and the UK, and both the EEA and the UK have been deemed to provide an adequate level of protection for personal data.

Whenever we transfer your User Information out of the EEA whether to a non EEA service provider or for transfers within the Exabel Group, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your User Information to countries that have been deemed to provide an adequate level of protection for personal data;
• Where we use service providers based outside the EEA and if that country has not been deemed to provide an adequate level of data protection, we will use specific contracts approved for use in the UK (for transfers from the UK) or the EEA (for transfers from Norway) which give personal data the same protection it has in the UK or Norway as the case may be.

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Keeping your User Information Secure

Security features

We have put in place appropriate security measures to prevent your User Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes integrated safeguards, encryption and anonymisation.

In addition, we limit access to your User Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your User Information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How we anonymise data

Anonymisation is a data processing technique to remove any information that can identify an individual. The purpose is to be able to analyse anonymised data to improve the Service, without putting the privacy of our users at risk. When your data is subject to anonymisation, for example after account deletion, we will remove identifiers like your name, organization, and contact information, and whenever appropriate add noise to the data set.

Retaining and deleting your User Information

How long will you use my User Information for?

We will only retain your User Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your User Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your User Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

User Information when you deactivate your account

When you choose to deactivate your account, all your User Information will be retained for a period of one year in case you wish to reactivate it. In some cases, such as unpaid bills, missing contract agreement, or other disputes, Exabel may temporarily disable your account until the situation is resolved.

User Information when you delete your account

When you explicitly request to have your account deleted, Exabel will within one month of such request permanently delete any User Information that can identify you, except what is necessary for financial record-keeping, fulfilling billing, or complying with our legal obligations.

When deleting your account, you can opt-in to let Exabel retain your contact information, in order to inform you about future products and services.

In some circumstances we will anonymise your User Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your rights

You as a user, have the right to request the following in relation to your User Information, and more information on these rights are set out in the Glossary:

• Request access to your User Information.
• Request correction of User Information.
• Request deletion of User Information.
• Object to processing of User Information.
• Request the transfer of your User Information.
• The right to object to processing of User Information.

If you wish to exercise any of your rights mentioned above, tools are provided in the Service. For cases not solved using the tools, please get in touch (see “Contacting Exabel”).

You will not have to pay a fee to access your User information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your User information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You may also at any time lodge a complaint with a supervisory authority, such as The Norwegian Data Protection Authority, for any complaints related to Exabel’s use of your User Information.

Changes to this Privacy Policy

Exabel regularly reviews and will, where necessary, update our Privacy Policy. This version was last updated on August 1, 2022.

It is important that the User Information we hold about you is accurate and current. Please keep us informed if your User Information changes during your relationship with us.

Contacting Exabel

If you have any further questions about this Privacy Policy or your rights regarding your User Information, please do not hesitate to contact us at contact@exabel.com.

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Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your User Information for our legitimate interests. We do not use your User Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your User Information where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your User Information (commonly known as a “data subject access request”). This enables you to receive a copy of the User Information we hold about you and to check that we are lawfully processing it.
• Request correction of the User Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your User Information. This enables you to ask us to delete or remove User Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your User Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your User Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your User Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your User Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your User Information. This enables you to ask us to suspend the processing of your User Information in the following scenarios:

1. If you want us to establish the data’s accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your User Information to you or to a third party. We will provide to you, or a third party you have chosen, your User Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Be aware of your own security system and take reasonable steps to protect the information when getting your User Information transmitted.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.