Privacy policy

Last updated: 26 March, 2020

Introduction and Scope

Zwipe AS ("Zwipe", "us", "we", or "our") is a Norwegian joint-stock company with organization number: NO 994 553 607. As a technology company, Zwipe enables battery-less, ultra-low-power, self-contained biometric authentication solutions for payment cards and wearable devices.

As part of Zwipe's business operations, Zwipe may handle and process personal data about you, hereunder when you use our website, contact us for information regarding our services or if you are a representative of a Zwipe customer, supplier or partner.

To get more information regarding Zwipe's services and operations, please refer to Zwipe's terms and conditions, which can be found here.

Your privacy is important to us. This privacy policy informs you of how Zwipe processes personal data, what personal data we collect, the purposes and legal bases for processing and our disclosure of personal data to third parties. We also inform you of your rights associated with the processing of your personal data.

Zwipe is the controller for the processing of your personal data as described in this privacy policy and thus responsible for complying with applicable data protection legislation. You will find our contact information at the bottom of this privacy policy.

Unless otherwise defined in this privacy policy, the terms used shall have the same meaning as the terms found in the General Data Protection Regulation 2016/679.

Processing of Personal Data by Zwipe

This section describes the purposes for which Zwipe processes personal data, the types of personal data Zwipe collects, how the personal data will be used and the legal bases for processing such data.

WHEN YOU VISIT THE ZWIPE.COM WEBSITE

Zwipe.com is the general website for Zwipe. When you use our website, we collect personal data about you through cookies as described below under "Tracking & Cookies". The data we collect through cookies consists of data relating to your device, IP-address and your use of the website, hereunder browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent each visited page, unique device identifiers and other diagnostic data. We use the data collected through cookies for the purposes of offering you the best user experience and for improving the website content by tracking usage patterns and recording preferences.

Find more information regarding how to accept and reject cookies by adjusting the settings in your browser under "Tracking & Cookies" below.

TO CONDUCT MARKETING AND SEND OUT NEWSLETTERS

When you subscribe to receive a newsletter, we collect your e-mail address in order to be able to send you the requested newsletter. The purpose of the newsletter is to provide you with news, press releases and other relevant information from Zwipe. In order to subscribe, you must provide your consent prior to receiving the newsletter. Your consent is the legal basis for processing your e-mail address. You can withdraw your consent to stop receiving newsletters from us at any time by following the unsubscribe instructions at the bottom of the newsletter that you receive.

We may use your personal data, such as e-mail, name and telephone number, to contact you with information that may be of interest to you, hereunder news, special offers and general information about our other goods, services and events that are corresponding to those you have already purchased or enquired about, unless you have opted not to receive such information.

The legal basis for processing personal data for marketing purposes is your consent and our legitimate interests in running and improving our business operations. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email or other correspondence we send. Please note that withdrawing your consent does not affect the lawfulness of processing that has taken place based on your consent before such withdrawal.

WHEN YOU CONTACT US

When you contact Zwipe, for example through phone, e-mail or the website contact form, we collect information about you. The personal data can include your name, e-mail address and other information you wish to provide us with to respond to your comment or request.

The legal basis for this processing is that the processing is necessary for fulfilling a contract with you or for taking steps prior to entering into contract, or that it is in our legitimate interest to meet your request and to improve our business and services and these interests are not overridden by your rights to data protection.

WHEN WE RECRUIT NEW TEAM MEMBERS

When you apply for a job at Zwipe, we collect your name, contact information, CV, education level, competencies and skills, career and work experiences. If relevant, you may also provide us with social security number, job certificates, references and other relevant background information.

We use this information in order to determine your eligibility for the job that you apply for by assessing whether you are the ideal candidate for the position in question.

With your consent, we may also retain your data for the purposes of identifying you as a potential candidate for future suitable vacancies and/or to inform you of future suitable vacancies.

The legal basis for processing and storing your job application, CV and related information is your consent and that the processing is necessary in order to take steps at your request prior to entering into a contract. You can withdraw your consent or update your information at any time by contacting careers@zwipe.com.

CUSTOMER, SUPPLIER AND PARTNER MANAGEMENT AND SUPPORT

Zwipe processes business-related data on customers, suppliers and partners, and their employees, to support and manage customer, supplier or partner relationships (internal/external), to provide products and services to third parties, for business operation and protection of business interests and security such as information security, logging, conduction of audits and controls, surveys, analysis, reports and managing of daily operations. The legal basis for this processing is Zwipe's legitimate business interests in ensuring good management of and support for customers, suppliers, partners and third parties, to comply with legal obligations and in some occasions consent.

COMPLIANCE WITH LEGAL OBLIGATIONS AND INFORMATION RELATING TO LEGAL PROCEEDINGS

Zwipe may process personal data necessary to comply with legal obligations, for example tax and accounting information and information relating to legal proceedings. The purpose and legal basis for this processing is Zwipe's legal obligations and Zwipe's legitimate interests in the establishment, exercise or defense of legal claims.

Retention periods

Zwipe AS will retain your personal data as long as it is necessary to fulfil the purposes set out in this privacy olicy. We will retain and use your personal data to the extent necessary to comply with our legal obligations such as tax and accounting laws, to resolve disputes and enforce our legal agreements and policies.

Zwipe AS will also retain statistical and aggregated data from your use of our website ("Usage Data") for internal analysis purposes. Usage Data is generally retained for a short period, except where such data is used to strengthen the security or to improve the functionality of our website and services, or if we are legally obligated to retain Usage Data for a longer period.

Disclosure of Data by Zwipe

Zwipe may be required to disclose your personal data to third parties under certain circumstances, for example if required to do so by law or in response to valid requests by public authorities, hereunder courts or a government agencies.

Further, Zwipe may share your personal data with Zwipe America Inc. when it is necessary in order to fulfil a request from you or for entering into an employment contract with you or in other circumstances where sharing is necessary in order to meet your inquiry. Any sharing of personal data with Zwipe America Inc. is subject to appropriate transfer mechanisms, which are binding upon Zwipe America Inc.

We do not share your personal data with third parties except where such sharing is necessary to fulfil the legitimate purposes listed above. We use external third-party service providers who assist us, among other things, with website hosting, processing transactions and performing statistical analysis of our services. We will only share your personal data with the service providers to the extent it is necessary for them to deliver the services.

In the event that we sell or buy any business or asset, we may disclose your personal data to such prospective buyers or sellers.

Transfer of Data by Zwipe

Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction, where the data protection laws may differ from those of your jurisdiction.

If you are located outside Norway and choose to provide information to us, please note that we transfer the data, including personal data, to Norway and process it there. Zwipe will take all the steps reasonably necessary to ensure that your data is processed securely and in accordance with this privacy policy.

Further, Zwipe will not transfer your personal data to an organization or a country outside of the EEA that does not provide adequate protection of personal data, unless appropriate safeguards are in place or the transfer otherwise takes place in accordance with applicable data protection legislation. Examples of such safeguards are EU Standard Contractual Clauses or if the receiving party is certified under the EU-US Privacy Shield.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Tracking & Cookies

When you visit our website, we collect certain information by automated means using cookies and similar technologies.

Cookies are small text files stored on your device when you visit a website. The cookies we use on our website will identify the browser you use, and collect and track information about your use of our website. We also use other tracking technologies in order to collect and track information, such as beacons, tags and scripts. These technologies are used for the purpose of improving and analyzing our website and services.

Note that you can manage how your device and/or browser handles cookies and related technologies by adjusting your device's or browser's privacy and security settings. Please refer to the instructions provided by your browser or the manufacturer of your device to learn how to adjust your settings. If you decide to change your cookie settings, please note that you may not be able to use some parts of our website or services.

Examples of cookies we use:

  • Session cookies: We use session cookies to operate our website.
  • Preference cookies. We use preference cookies to remember your preferences and various settings.
  • Security cookies. We use security cookies for security purposes.

ANALYTICS

We may use third-party service providers to monitor and analyze the use of our website.

  • Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on our website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visitor activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

  • Piwik/Matomo

Piwik or Matomo is a web analytics service. You can visit their privacy policy page here: https://matomo.org/privacy-policy

  • Clicky

Clicky is a web analytics service. Read the privacy policy for Clicky here: https://clicky.com/terms

  • Statcounter

Statcounter is a web traffic analysis tool. You can read the privacy policy for Statcounter here: https://statcounter.com/about/legal/

  • Mixpanel

Mixpanel is provided by Mixpanel Inc.

You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/

For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/

Security of Data

The security of your data is important to us. However, remember that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visitno control over and assume no responsibility for the content, privacy policies or practices of any third party site or service.

Your Rights

When Zwipe processes your personal data, you have certain data protection rights. Zwipe aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal data.

If you wish to enforce any of the rights listed below, please contact us by using the contact information listed at the bottom of this privacy policy.

You have the following data protection rights, unless such rights are restricted in accordance with applicable law:

  • The right to access, update or delete the information we have on you.
  • The right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object to our processing of your personal data.
  • The right to request that we restrict the processing of your personal data.
  • The right to data portability, hereunder be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • Where Zwipe relies on your consent to process your personal data, the right to withdraw consent at any time.

Please note that we may ask you to verify your identity before responding to such requests.

If you believe that your personal data have not been processed lawfully, you have the right to lodge a complaint with the supervisory authority of the member state where you live or work, or where you believe the alleged unlawful conduct occurred. In Norway, the relevant supervisory authority is the Norwegian Data Protection Authority (NO: Datatilsynet).

Governing Law and Jurisdiction

This website is governed in accordance with Norwegian legislation, and the Oslo District Court shall be the legal venue with exclusive jurisdiction over any dispute arising from your use of this website.

Changes to this Privacy Policy

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page. Changes to this privacy policy are effective when they are posted on this page.

How to contact us

If you have any questions or comments regarding this privacy policy or want to exercise your rights, please contact us at info@zwipe.com.