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Privacy Policy 



Last updated: April 04, 2020


This Privacy Policy describes Our policies and procedures on the collection,

use and disclosure of Your information when You use the Service and tells You

about Your privacy rights and how the law protects You.


We use Your Personal data to provide and improve the Service. By using the

Service, You agree to the collection and use of information in accordance with

this Privacy Policy.


Interpretation and Definitions 






The words of which the initial letter is capitalized have meanings defined

under the following conditions.


The following definitions shall have the same meaning regardless of whether

they appear in singular or in plural.





For the purposes of this Privacy Policy:


  * You means the individual accessing or using the Service, or the company,

   or other legal entity on behalf of which such individual is accessing or

   using the Service, as applicable.


   Under GDPR (General Data Protection Regulation), You can be referred to as

   the Data Subject or as the User as you are the individual using the



  * Company (referred to as either "the Company", "We", "Us" or "Our" in this

   Agreement) refers to Gray Area AS, Oscarsgate 13, 9800 Vadsø.


   For the purpose of the GDPR, the Company is the Data Controller.


  * Affiliate means an entity that controls, is controlled by or is under

   common control with a party, where "control" means ownership of 50% or

   more of the shares, equity interest or other securities entitled to vote

   for election of directors or other managing authority.

  * Account means a unique account created for You to access our Service or

   parts of our Service.

  * Website refers to Gray Area AS, accessible from

  * Service refers to the Website.

  * Country refers to: Norway

  * Service Provider means any natural or legal person who processes the data

   on behalf of the Company. It refers to third-party companies or

   individuals employed by the Company to facilitate the Service, to provide

   the Service on behalf of the Company, to perform services related to the

   Service or to assist the Company in analyzing how the Service is used.


   For the purpose of the GDPR, Service Providers are considered Data



  * Third-party Social Media Service refers to any website or any social

   network website through which a User can log in or create an account to

   use the Service.

  * Personal Data is any information that relates to an identified or

   identifiable individual.


   For the purposes of GDPR, Personal Data means any information relating to

   You such as a name, an identification number, location data, online

   identifier or to one or more factors specific to the physical,

   physiological, genetic, mental, economic, cultural or social identity.


  * Cookies are small files that are placed on Your computer, mobile device or

   any other device by a website, containing the details of Your browsing

   history on that website among its many uses.

  * Usage Data refers to data collected automatically, either generated by the

   use of the Service or from the Service infrastructure itself (for example,

   the duration of a page visit).

  * Data Controller, for the purposes of the GDPR (General Data Protection

   Regulation), refers to the Company as the legal person which alone or

   jointly with others determines the purposes and means of the processing of

   Personal Data.


Collecting and Using Your Personal Data 



Types of Data Collected 



Personal Data 



While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:


  * Email address

  * First name and last name

  * Phone number

  * Usage Data


Usage Data 



Usage Data is collected automatically when using the Service.


Usage Data may include information such as Your Device's Internet Protocol

address (eg IP address), browser type, browser version, the pages of our

Service that You visit, the time and date of Your visit, the time spent on

those pages, unique device identifiers and other diagnostic data.


When You access the Service by or through a mobile device, We may collect

certain information automatically, including, but not limited to, the type of

mobile device You use, Your mobile device unique ID, the IP address of Your

mobile device, Your mobile operating system, the type of mobile Internet

browser You use, unique device identifiers and other diagnostic data.


We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.


Tracking Technologies and Cookies 



We use Cookies and similar tracking technologies to track the activity on Our

Service and store certain information. Tracking technologies used are beacons,

tags, and scripts to collect and track information and to improve and analyze

Our Service.


You can instruct Your browser to refuse all Cookies or to indicate when a

Cookie is being sent. However, if You do not accept Cookies, You may not be

able to use some parts of our Service.


Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on

your personal computer or mobile device when You go offline, while Session

Cookies are deleted as soon as You close your web browser. Learn more about

cookies: [All About Cookies] (


We use both session and persistent Cookies for the purposes set out below:


  * Necessary / Essential Cookies


   Type: Session Cookies


   Administered by: Us


   Purpose: These Cookies are essential to provide You with services

   available through the Website and to enable You to use some of its

   features. They help to authenticate users and prevent fraudulent use of

   user accounts. Without these Cookies, the services that You have asked for

   cannot be provided, and We only use these Cookies to provide You with

   those services.


  * Cookies Policy / Notice Acceptance Cookies


   Type: Persistent Cookies


   Administered by: Us


   Purpose: These Cookies identify if users have accepted the use of cookies

   on the Website.


  * Functionality Cookies


   Type: Persistent Cookies


   Administered by: Us


   Purpose: These Cookies allow us to remember choices You make when You use

   the Website, such as remembering your login details or language

   preference. The purpose of these Cookies is to provide You with a more

   personal experience and to avoid You having to re-enter your preferences

   every time You use the Website.


  * Tracking and Performance Cookies


   Type: Persistent Cookies


   Administered by: Third-Parties


   Purpose: These Cookies are used to track information about traffic to the

   Website and how users use the Website. The information gathered via these

   Cookies may directly or indirectly identify you as an individual visitor.

   This is because the information collected is typically linked to a

   pseudonymous identifier associated with the device you use to access the

   Website. We may also use these Cookies to test new advertisements, pages,

   features or new functionality of the Website to see how our users react to



For more information about the cookies we use and your choices regarding

cookies, please visit our Cookies Policy.


Use of Your Personal Data 



The Company may use Personal Data for the following purposes:


  * To provide and maintain our Service, including to monitor the usage of our


  * To manage Your Account: to manage Your registration as a user of the

   Service. The Personal Data You provide can give You access to different

   functionalities of the Service that are available to You as a registered


  * For the performance of a contract: the development, compliance and

   undertaking of the purchase contract for the products, items or services

   You have purchased or of any other contract with Us through the Service.

  * To contact You: To contact You by email, telephone calls, SMS, or other

   equivalent forms of electronic communication, such as a mobile

   application's push notifications regarding updates or informative

   communications related to the functionalities, products or contracted

   services, including the security updates, when necessary or reasonable for

   their implementation.

  * To provide You with news, special offers and general information about

   other goods, services and events which we offer that are similar to those

   that you have already purchased or inquired about unless You have opted

   not to receive such information.

  * To manage Your requests: To attend and manage Your requests to Us.


We may share your personal information in the following situations:


  * With Service Providers: We may share Your personal information with

   Service Providers to monitor and analyze the use of our Service, to show

   advertisements to You to help support and maintain Our Service, to contact

   You, to advertise on third party websites to You after You visited our

   Service or for payment processing.

  * For Business transfers: We may share or transfer Your personal information

   in connection with, or during negotiations of, any merger, sale of Company

   assets, financing, or acquisition of all or a portion of our business to

   another company.

  * With Affiliates: We may share Your information with Our affiliates, in

   which case we will require those affiliates to honor this Privacy Policy.

   Affiliates include Our parent company and any other subsidiaries, joint

   venture partners or other companies that We control or that are under

   common control with Us.

  * With Business partners: We may share Your information with Our business

   partners to offer You certain products, services or promotions.

  * With other users: when You share personal information or otherwise

   interact in the public areas with other users, such information may be

   viewed by all users and may be publicly distributed outside. If You

   interact with other users or register through a Third-Party Social Media

   Service, Your contacts on the Third-Party Social Media Service may see

   Your name, profile, pictures and description of Your activity. Similarly,

   other users will be able to view descriptions of Your activity,

   communicate with You and view Your profile.


Retention of Your Personal Data 



The Company will retain Your Personal Data only for as long as is necessary

for the purposes set out in this Privacy Policy. We will retain and use Your

Personal Data to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your data to comply with applicable

laws), resolve disputes, and enforce our legal agreements and policies.


The Company will also retain Usage Data for internal analysis purposes. Usage

Data is generally retained for a shorter period of time, except when this data

is used to strengthen the security or to improve the functionality of Our

Service, or We are legally obligated to retain this data for longer time



Transfer of Your Personal Data 



Your information, including Personal Data, is processed at the Company's

operating offices and in any other places where the parties involved in the

processing are located. It means that this information 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

than those from Your jurisdiction.


Your consent to this Privacy Policy followed by Your submission of such

information represents Your agreement to that transfer.


The Company will take all steps reasonably necessary to ensure that Your data

is treated securely and in accordance with this Privacy Policy and no transfer

of Your Personal Data will take place to an organization or a country unless

there are adequate controls in place including the security of Your data and

other personal information.


Disclosure of Your Personal Data 



Business Transactions 



If the Company is involved in a merger, acquisition or asset sale, Your

Personal Data may be transferred. We will provide notice before Your Personal

Data is transferred and becomes subject to a different Privacy Policy.


Law enforcement 



Under certain circumstances, the Company may be required to disclose Your

Personal Data if required to do so by law or in response to valid requests by

public authorities (eg a court or a government agency).


Other legal requirements 



The Company may disclose Your Personal Data in the good faith belief that such

action is necessary to:


  * Comply with a legal obligation

  * Protect and defend the rights or property of the Company

  * Prevent or investigate possible wrongdoing in connection with the Service

  * Protect the personal safety of Users of the Service or the public

  * Protect against legal liability


Security of Your Personal Data 



The security of Your Personal Data is important to Us, but 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 can not guarantee its absolute security.


Detailed Information on the Processing of Your Personal Data 

=============================================== ==========


Service Providers have access to Your Personal Data only to perform their

tasks on Our behalf and are obligated not to disclose or use it for any other






We may use third-party Service providers to monitor and analyze the use of our



  * 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 Service. 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 the Service 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 visits activity.


   For more information on the privacy practices of Google, please visit the

   Google Privacy & amp; Terms web page:



Email Marketing 



We may use Your Personal Data to contact You with newsletters, marketing or

promotional materials and other information that may be of interest to You.

You may opt-out of receiving any, or all, of these communications from Us by

following the unsubscribe link or instructions provided in any email We send

or by contacting Us.


We may use Email Marketing Service Providers to manage and send emails to You.


GDPR Privacy 



Legal Basis for Processing Personal Data under the GDPR 

-------------------------------------------------- -


We may process Personal Data under the following conditions:


  * Consent: You have given Your consent for processing Personal Data for one

   or more specific purposes.

  * Performance of a contract: Provision of Personal Data is necessary for the

   performance of an agreement with You and / or for any pre-contractual

   obligations thereof.

  * Legal obligations: Processing Personal Data is necessary for compliance

   with a legal obligation to which the Company is subject.

  * Vital interests: Processing Personal Data is necessary in order to protect

   Your vital interests or of another natural person.

  * Public interests: Processing Personal Data is related to a task that is

   carried out in the public interest or in the exercise of official

   authority vested in the Company.

  * Legitimate interests: Processing Personal Data is necessary for the

   purposes of the legitimate interests pursued by the Company.


In any case, the Company will gladly help to clarify the specific legal basis

that applies to the processing, and in particular whether the provision of

Personal Data is a statutory or contractual requirement, or a requirement

necessary to enter into a contract.


Your Rights under the GDPR 



The Company undertakes to respect the confidentiality of Your Personal Data

and to guarantee You can exercise Your rights.


You have the right under this Privacy Policy, and by law if You are within the

EU, to:


  * Request access to Your Personal Data. The right to access, update or

   delete the information We have on You. Whenever made possible, you can

   access, update or request deletion of Your Personal Data directly within

   Your account settings section. If you are unable to perform these actions

   yourself, please contact Us to assist You. This also enables You to

   receive a copy of the Personal Data We hold about You.

  * Request correction of the Personal Data that We hold about You. You have

   the right to have any incomplete or inaccurate information We hold

   about You corrected.

  * Object to processing of Your Personal Data. This right exists where We are

   relying on a legitimate interest as the legal basis for Our processing and

   there is something about Your particular situation, which makes You want

   to object to our processing of Your Personal Data on this ground. You also

   have the right to object where We are processing Your Personal Data for

   direct marketing purposes.

  * Request erasure of Your Personal Data. You have the right to ask Us to

   delete or remove Personal Data when there is no good reason for Us to

   continue processing it.

  * Request the transfer of Your Personal Data. We will provide to You, or to

   a third-party You have chosen, Your Personal Data in a structured,

   commonly used, machine-readable format. Please note that this right only

   applies to automated information for which You initially provided consent

   Us to use or where We used the information to perform a contract with You.

  * Withdraw Your consent. You have the right to withdraw your consent on

   using your Personal Data. If You withdraw Your consent, We may not be able

   to provide You with access to certain specific functionalities of the



Exercising of Your GDPR Data Protection Rights 



You may exercise Your rights of access, rectification, cancellation and

opposition by contacting Us. Please note that we may ask You to verify Your

identity before responding to such requests. If You make a request, We will

try our best to respond to You as soon as possible.


You have the right to complain to a Data Protection Authority about Our

collection and use of Your Personal Data. For more information, if You are in

the European Economic Area (EEA), please contact Your local data protection

authority in the EEA.


Children's Privacy 



Our Service does not address anyone under the age of 13. We do not knowingly

collect personally identifiable information from anyone under the age of 13.

If You are a parent or guardian and You are aware that Your child has provided

Us with Personal Data, please contact Us. If We become aware that We have

collected Personal Data from anyone under the age of 13 without verification

of parental consent, We take steps to remove that information from Our



If We need to rely on consent as a legal basis for processing Your information

and Your country requires consent from a parent, We may require Your parent's

consent before We collect and use that information.


Links to Other Websites 



Our Service may contain links to other websites that are not operated by Us.

If You click on 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



We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.


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.


We will let You know via email and / or a prominent notice on Our Service, prior

to the change becoming effective and update the "Last updated" date at the top

of this Privacy Policy.


You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this



Contact Us 



If you have any questions about this Privacy Policy, You can contact us:


  * By email:

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