Please note that you have to tailor a privacy notice to your own business. You might not know this, but copying my text is a copyright violation (and a rotten thing to do, since I make a living from this). ;)
Controller and contact information
This privacy notice explains how we process personal data in our business as per the General Data Protection Regulation (GDPR). This privacy notice is applicable to our websites riealeksandra.com and gdprstart.com.
Please note that this document is protected by copyright and you may not copy any text from it. All breaches will be legally pursued.
Our contact details are:
- Company name: Bedre Bedrift AS (dba. NoTies.Consulting)
- Company number: Foretaksregisteret 921 119 224 MVA (Norwegian registered limited liability company)
- Email address: info [at] gdprstart.com
We take your privacy seriously and we have taken several steps to ensure that we provide you with clear and transparent information on how we process your data, and also inform you about your rights. If you feel that any information is unclear, or missing, please do not hesitate to contact us.
This privacy notice was last updated: January 2022.
Your data protection rights
- Your rights of access and rectification: You may request access to or a copy of the information we process about you and ask us to rectify any incorrect data.
- Your right to erasure or restriction: In some circumstances, you may ask us to delete and/or restrict our processing of your data, but we cannot delete any data we are required to process.
- Your right to object to processing: In some circumstances, you may ask us to stop processing your data.
- Your right to data portability: In some circumstances, you may ask us to transfer your data to you or to another organisation.
- Also, if you’re unhappy about how we process your data, you have a right to complain to the national data authority (in Norway: Datatilsynet). We hope, however, that you will contact us first so that we can try to resolve the matter for you in a satisfactory way.
Please contact us if you have any questions about or want to exercise one of your rights. You are entitled to a reply within 30 days.
How we get your personal data
We typically process personal data about leads, customers, students, members, newsletter subscribers, website visitors, vendors and partners.
We process personal data when you:
- buy our products or services
- join our membership
- subscribe to our newsletter
- opt in for our free content
- sign up for our events, free or paid
- respond to one of our surveys
- provide us with your contact details, e.g. give us your business card
- contact us via phone, text, email, social media or our website
- otherwise use our website, e.g. submit a form
It is voluntary to provide us with personal data, but if you choose not to, we may not be able to provide you with our services. We do not rent, buy or sell personal data from or to others or use automated decisions or profiling in the processing of your personal data
Purpose, lawful basis and retention periods
We only process your personal data when we have a purpose and a lawful basis for doing so. Under the GDPR Article 6-1, the lawful bases we rely on, are:
- a) Your consent
- b) We have a contractual obligation (contract)
- c) We have a legal obligation
- f) We have a legitimate interest
As a rule, personal data should not be processed and kept for longer than necessary to fulfil the purpose for processing. To comply with this, we have yearly GDPR review days where we formally assess our GDPR work with the intention to amend, update and, if necessary, delete personal data. Generally, we will not process personal data any longer than three years, at the most. However, we will retain data for as long as we are required to as per applicable legal obligations related to for example accounting, tax or labour laws or any other relevant rules and regulations.
Your personal data is only retained for as long as we have a purpose and a lawful basis:
- Until you withdraw your consent (e.g. for email and SMS marketing)
- For as long as we have a contractual obligation, and, if applicable, in accordance with accounting and bookkeeping rules and regulations (e.g. for sales)
- For as long as we have a legal obligation; in accordance with accounting and bookkeeping rules and/or other legal requirements and regulations (e.g. for employment)
- For as long as we have a legitimate interest or until you ask us not to process your data in such a way (e.g. marketing to existing customers)
You can always withdraw your consent for any data processing based on consent, and you can also reach out to us at any time if you’d like us to stop processing and/or ask us to delete any of your data.
We have routines in place to ensure that personal data is deleted from all relevant systems when we no longer have a purpose and/or legal basis to continue to process them.
Details on the processing of your personal data
In this section we describe in detail when and how we process your data, for what purposes and our legal grounds to do so (lawful bases). We also specify the retention periods for the processing.
We process personal data when:
You communicate with us
When you contact us through our website (contact form, blog comments, chat), e-mail, phone (call, text message), social media and/or give us your business card, we process personal data. Depending on where and how you contact us, this may include your name, contact details, IP address and other information you choose to send to us.
The purpose is to be able to respond to your inquiries and, on some occasions, to keep records in case of complaints or legal claims. The lawful basis is f), where the legitimate interests are to be able to respond to your inquiries and, on some occasions, to keep records in case of complaints or legal claims. We review this data at our yearly GDPR review day and delete personal data as appropriate. Due to the nature of our business, we can keep this type of personal data up to three years, or five years if we have a legal obligation in accordance with accounting and bookkeeping rules.
You purchase our products and services, including digital ones
When you purchase products and services from us, we process personal data such as your name, contact details, order and payment details as well as purchase history. If your purchase includes digital delivery, for example over video (recorded or not), either one to one between us and you, or one to many between us and a group of people, we also process personal data such as profile picture, video (picture and sound), messages (chat) and IP address. Depending on the type of purchase, we may share the content from or the recording, or the entire recording, with other people, e.g. where the service is structured as a group program (e.g. related to coaching or masterminds). The recording will not be shared with unauthorized people. For services where we use a webinar system, please read more below.
The purpose is to be able to fulfil our obligation to deliver products and services you have purchased and to manage the customer relationship. The lawful bases are b) contract and c) legal obligation related to accounting, tax and other business rules and regulations we are required to abide by.
We process the data for as long as we have a legal obligation as per any applicable rules and regulations we are bound by. E.g. we are required by law to store business records, which could include personal data, for a minimum of five years for accounting and tax purposes. In addition, we store data from customer projects/engagements, for up to five years following the end of the customer relationship, where the purpose and our legitimate interest (cf. the GDPR Article 6(1)(f)) is to be able to document deliverables and defend against legal claims.
You use our website and/or online platform (in Kajabi)
When you use our website, we process as little personal data as possible and use only strictly necessary cookies. When you submit a form on the website, we receive a notification in our inbox, but we’re not able to see your IP address. Read more in our Cookie notice.
The tool we use to analyse website traffic, Fathom Analytics, was built with privacy as their business model. It processes your IP address (briefly), however we can't identify you from this. Read more about the technology here (and note that we don't process the User agent on our website). The purpose of using this tool is to track our website traffic, in the most privacy-friendly way as possible, so that we can continually improve our website and business. The lawful basis is f) where our legitimate interests are to continually improve our website and business. Cf. the explanation over, no data is stored over time.
When you become a student or member of ours, we process personal data such as your name, contact details, IP address, order and payment details as well as purchase history. The purpose is to be able to fulfil our obligation to deliver products and services you have purchased, such as courses and memberships, and to manage the customer relationship. The lawful bases are b) contract and c) legal obligation related to accounting, tax and other business rules and regulations we are required to abide by.
Kajabi has integrated analytics showing sign in count, last activity date, quiz results and progress. This functionality is native and cannot be disabled. If you do not want your data to be analysed in this way, please do not purchase access to or use our systems. If you have purchased a product or a service, note that you will lose access to your content if you do not want to continue to use our platform. We use this data to analyse our content and to make continuous improvements in our service offerings. The lawful basis is f), where the legitimate interest is to be able to offer you digital products and services and to continuously improve our products and services. We process the data for as long as you are a member/student, after which it will be deleted within two years.
You subscribe to our email newsletter
We regularly send out email newsletters which sometimes contain information about our products and services. When you become a subscriber, we process personal data such as your name, email address and IP address. The purpose is to share updates, articles, discounts, give-aways and other useful content. The lawful basis is a) consent and you can easily unsubscribe at any time by clicking the "unsubscribe" link in any such newsletter.
Our email service provider has integrated analytics showing email opens and clicks. This functionality is native in our system and cannot be disabled. If you do not want your data to be analysed in this way, please do not subscribe to our newsletter. We use this data to analyse the performance of our newsletters and to tailor our content to you. The lawful basis is f), where the legitimate interest is to be able to offer you electronic newsletters and to continuously improve our products and services.
We process the data for as long as you subscribe, after which it will be deleted at our next GDPR review day.
You gain access to our complimentary content
We regularly offer content to you free of charge, such as a downloadable PDF or a mini course inside of our online platform. The content often includes one or a series of emails, but we will not, however, add you to our general marketing/newsletter list. To get access to the content, we require that you share personal data such as your name and email address. The purpose is to be able to give you access to the content. We will clearly inform you what such content includes when you sign up for it. The lawful basis is a) consent. If you do not wish to receive the email messages, which often are a part of the complimentary content, you can opt out at any time through an unsubscribe link in the emails.
Our email service provider has integrated analytics showing email opens and clicks. This functionality is native in our system and cannot be disabled. If you do not want your data to be analysed in this way, please do not request access to any complimentary content that will be delivered to you via email. We use this data to analyse the performance of our emails and to tailor our content to you. The lawful basis is f), where the legitimate interest is to be able to offer you digital, complimentary content and to continuously improve our products and services. The data is kept for up to two years after you requested access to the content unless you subscribe to e.g. our newsletter and/or are a customer of ours.
You attend our events, including digital ones
When you attend our events that are free of charge, we process personal data such as your name and contact details. For paid events, we also collect order and payment information. The purpose is to be able to process your registration and attendance, and, if applicable, your payment. The lawful basis is a) consent, or, for paid events, b) contract and c) legal obligation related to accounting, tax and other business rules and regulations we are required to abide by. If we collect any information about dietary and/or access requirements, we also need your consent under GDPR Article 9 (2) (a).
We may also use your data to send you an evaluation of the event you attended, to invite you to other relevant events and/or to offer relevant products and services. The lawful basis is f), where our legitimate interest is to offer you relevant products and services, we think you will be interested in. If you do not wish to receive such messages, you will have an easy way to opt out, e.g. through an unsubscribe link in our emails. The data is kept for up to two years after you requested access to the content unless you subscribe to e.g. our newsletter and/or are a customer of ours.
When you participate in a digital event (e.g. webinars)
The platform we use for digital events has integrated analytics showing time of registration, number of minutes participated and links you may have clicked. This functionality is native in the system and cannot be disabled. If you do not want your data to be analysed in this way, please do not sign up for or participate in our digital events. We use this data to analyse the performance of our digital events to continuously improve our business and services. The lawful basis is f), where the legitimate interest is to be able to offer you digital events and to continuously improve our products and services. The data is kept for up to two years after you requested access to the content unless you subscribe to e.g. our newsletter and/or are a customer of ours.
You respond to our evaluations or surveys
Responding to our evaluations and surveys are voluntary. We process personal data such as your name, contact details and other information you choose to share with us. Some evaluations or surveys may be anonymous, and in such cases, we do not process any personal data
The purpose is to gather your feedback so that we can continuously improve our products and services, as well as provide you with better customer service in the future. The lawful basis is a) consent. We keep this data until you ask us to delete them, or at the latest up to two years after you responded to the survey.
You supply services to or collaborate with us
When you enter into an agreement with us either as a vendor, partner or data processor, we process personal data such as your name, contact details and correspondence. The purpose is to be able to enter into this agreement and to respond to your inquiries and the lawful basis is b) contract. We review this data at our yearly GDPR review day and delete personal data as appropriate, however no later than five years after the contract has been terminated. We process other communication data as per the first paragraph in this chapter, please see above.
Whom we share personal data with
To run our business efficiently and securely, we sometimes will have to share your personal data with other parties:
- Public authorities we are obliged to report to (in Norway)
- Our accountant
- Data processors: providers of services that process your personal data on our behalf*
- IT support, if necessary
We require that all such recipients secure data in accordance with good information security. We enter into a data processing agreement/addendum with anyone who processes data on our behalf, as per the requirements in the GDPR Article 28-3.
* We use data processors for:
- Email, calendar and digital meetings
- Accounting/bookkeeping and invoicing
- Cloud storage
- This website, which includes our online store, online payments and online web portal (where you access digital products you purchase from us)
- Business receipts
- Project management, timekeeping, digital notebook and scheduling
- Signing documents electronically
- Surveys and customer satisfaction feedback
To protect our business we don't publish further details (like names) of our data processors. If you'd like to know more about our processing and whom we share your personal data with, please contact us.
Transfer of personal data outside the EU/EEA
In short; Bedre Bedrift AS has taken every step possible to manage the Schrems II ruling. If you have any questions about our use of third country-based data processors and the transfer impact assessments we've conducted, please contact us.
We use Kajabi, LLC as a data processor for our websites (bedrebedrift.no, gdprstart.com and riealeksandra.com), including blogs, online stores, web portals and email marketing (including newsletters). Kajabi is owned and operated by a US company subject to legislation which, according to the Schrems II judgment, is challenging when it comes to our privacy.
Bedre Bedrift AS started using Kajabi in the fall of 2018 and have built a significant part of the business structure around the system. Since the Schrems II ruling we have reassessed our use of Kajabi, but, unfortunately, we currently don’t have an option to stop using the system. We’re in close dialogue with Kajabi about potential supplementary measures as per the EDPB recommendations from November 2020. We’re also continuously assessing for other options where data is stored in the EEA. When the EDPB publishes their updated recommendations, we’ll review these immediately as well.
Therefore, if you use our websites, sign up for newsletters and/or makes a purchase from the online store, be aware that your personal data doesn’t have the same protection as if it had been stored in the EEA. Feel free to contact us if you want to know more about what this means for you, in practice.
That said, we’d like to highlight that we’ve taken every precaution to secure your personal data in the safest way possible with the systems and tools that we use. We don’t collect more data than we need, store them no longer than what’s strictly necessary, and we have robust internal security measures (use of password manager, strong passwords (40+ characters, where possible), multifactor authentication (where possible), strict data sharing routines etc.).
We do a thorough due diligence on every single data processor we use in our business, where we (among other things) assess the quality (and security) of their website, privacy notice (if it’s in line with the GDPR), review data processor agreements, general GDPR information, whether they have a Data Protection Officer and (if applicable) a European representative, their use of sub-data processors, and technical and organizational security measures.
We also carry out a risk assessment for each data processor - especially those located in third countries and/or that store personal data in third countries. If so, we review transfer tools and also do a transfer impact assessment. Finally, we assess the data processor against the processing activity in question. All use of data processors and storage of personal data in third countries has been thoroughly considered and (risk) assessed.
Here is an overview of the personal data we process for your online purchase (with HQ country/country of storage), as well as a link to the data processors’ privacy notices:
- Kajabi (USA/USA): data from purchase form (except payment card details), Stripe ID, payment details, last login date etc.
- Stripe (USA/USA): data from purchase form, purchase and payment information, last four digits of payment card details, IP address, metadata from Kajabi etc.
- Fastmail (Australia/USA): Email confirmation from Kajabi with purchase information (name, email address and purchase ID).
Otherwise in our business we use Fastmail for email correspondence, Microsoft OneDrive as cloud provider and various platforms for online meetings (typically the one our customers use, e.g., Microsoft Teams, Google Meet, Zoom, Whereby or other).
The transfer tools for the aforementioned data processors are the EU Standard Contractual Clauses and your explicit consent.
If you’d like more information about how we process your personal data, please reach out.
We take information security seriously and we will always do our utmost to safeguard your personal data in the best possible way. For example, we use SSL on our websites, strong passwords, a password manager, encryption and two-factor authentication to secure our data and prevent unauthorized persons from accessing, altering, deleting, or in any way affecting the data we store, including your personal data.
We only allow others to access and/or process your personal data in accordance with our instructions, and only when strictly necessary (e.g. when we require IT support).
We have implemented a policy for technical and organisational measures and a routine for managing data breaches. If we experience a personal data breach, i.e. a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, and it poses a medium to high risk for the people affected, we will notify the national data authority within 72 hours. If the risk is deemed high for the people affected, we will also notify them directly, if possible
Unlawful copying of this privacy notice
This privacy notice explains how we process personal data in our business as per the General Data Protection Regulation (GDPR).
Please note that this document is protected by copyright and you may not copy any text from it. All breaches will be legally pursued.