PRIVACY POLICY

This document (hereinafter: “Privacy Policy”) sets out the principles on the basis of which TRADE STATE ehf with its registered office at Háteigsvegi 14, 105 Reykjavík (hereinafter: “TRADE STATE”), as a data controller (hereinafter: “Administrator”), processes personal data provided by users of websites, mobile applications, other types of software, mailing lists, publications of a different nature, etc., managed by TRADE STATE and in other endeavors, participation in which it is conditioned to agree to the provisions of this Privacy Policy (hereinafter referred to as “Products” and individually as “Product”).

By using the Products, users can provide us with a specific set of information about themselves or devices through which they use the Products. Some of the information left in this way may, either alone or in combination with other information, enable us to identify the user (in particular, it may be information such as email address, name, surname, telephone number, device ID). The information on the basis of which it is possible to identify a specific natural person is its personal data (hereinafter: “Personal data”). In the event that the user provides us with his Personal Data, as their Administrator we will process them on the terms set out in this Privacy Policy.

In order to be able to provide services within our Products, we need to gather some scope of information about our users. This allows us to offer the most matching and least intrusive ads, as well as display content tailored to individual preferences or user locations. Providing data by users is voluntary, however, it is possible that the lack of them will restrict or prevent the use of a particular Product. Users, while using the Products, may be asked by us whether they consent to the processing of their Personal Data and to the provisions of this Privacy Policy. Such an inquiry may be addressed in particular in cases of Products, where the use of Personal Data may be necessary for their proper functioning.

The personal data provided to us by the user should be provided by him in a correct and reliable manner. Providing us with false Personal Data may have effects similar to not providing them, i.e. such that the provision of services through individual Products may be restricted or prevented.

OBJECTIVES FOR WHICH WE PROVIDE PERSONAL DATA

Contacting the user of a given Product for information or marketing purposes: for this purpose, we use contact details provided by users and other data enabling contact with the user, such as, for example, the device identifier through which the user uses the Product. The form of contact may take the form of an electronic message, a message based on nearby beacon devices (using Bluetooth technology for this purpose), push notifications in mobile applications or via websites or other forms of electronic communication. Such communication may serve the marketing of own services or third-party services and its adaptation to the preferences of a given user or current communication regarding the use of a given Product by the user. This goal is related in particular to the processing of Users ‘personal data in order to make them personalized and tailored to their preferences, and for its implementation. Users’ personal data can be analyzed, used for profiling or for research of various purposes (such as marketing research, analytical tests, diagnostic tests, qualitative and other tests). Submitting third party marketing materials to users is based on users’ voluntary consent expressed during the use of a given Product – displaying personalized ads requires that user data may be processed by third parties and individuals; such consent is voluntary and may be withdrawn or modified in accordance with the principles set out in the “How Users Use Your Rights” section of this Privacy Policy, i.e. by sending a properly worded message to
info@skaer.is,

User account management: in this case, Users’ personal data are used by us to identify a given user or to offer him all the functionality of a given Product,

Statistical goals: We collect Personal Data to create statistics that enable us to continuously improve our Products so that the services provided through them are at the highest possible level. The aggregated statistical data understood in this way, which no longer form Personal Data, we also present to our contractors, so that the promotions, offers or advertisements ultimately displayed to our users are as customized as possible,

Analytical goals: We collect Personal Data in order to analyze the way our Products operate and how they function. By analyzing the behavior of individual users, we are able to remove the errors appearing in them and take care of the highest level of their quality,

Goals related to user profiling, service adaptation and improvement: we collect Personal Information to customize the content of individual Products or their messages to the preferences and preferences of a given user or groups of users, so that their or their experience of the Product is as good as possible. The collected Personal Data also serves to analyze the behavior of users when using the given Product and use this knowledge to constantly improve and improve our Products.

THE USE OF USERS THROUGH THEIR RIGHTS

When using the Products, our users have a certain set of rights in connection with the processing of their Personal Data by us. These rights include the right to access (retrieve) your Personal Data, withdraw consent to their processing, limit their processing, remove them (including the right to “be forgotten”, i.e. the right to request the complete deletion of all Personal Data currently processed and in the past by the Administrator and cease their processing in the future), their correction, transfer to another administrator or rectification.

The User whose Personal Data is being processed may also at any time request us to cease processing of Personal Data by all or by selected persons and third parties processing them at our request, primarily our subcontractors – persons and entities performing subcontracting services to us. that enable us to complete our services with the highest quality and efficiency (a list of these persons and entities is included in this Privacy Policy).

The User whose Personal Data is being processed may also at any time request us to cease processing of Personal Data by all or by selected persons and third parties, processing them for purposes related to the marketing of own services or marketing of persons or third parties (i.e. Trusted partners – a list of these persons and entities is included in this privacy policy).

To use all or any of the rights described in this section of our Privacy Policy, you should contact us by sending a message to info@skaer.is. In the message, the user should describe his request in any comprehensible way and provide data to identify him in the set of users of any of the Products, so that his request can be fulfilled. In the event that the user’s request cannot be executed due to failure to provide sufficient information or because of other uncertainties, we will contact you to complete or clarify it. A request addressed to us in this way will be implemented without undue delay.

PERIOD OF DATA STORAGE AND PROCESSING

Personal data that we will process in a manner, for the purposes and under the terms of this Privacy Policy, will be processed only as long as it is necessary for the purpose for which they are processed. After the termination or fulfillment of the purpose for which Personal Data was processed, excluding those purposes that occur periodically or permanently, and which are related to the proper fulfillment of our goals set out in this Privacy Policy, collected Personal Data will be permanently deleted by us , which means that we will delete all of this Personal Data, the purpose of which has been permanently expired.

SUB-CONTRACTORS AND TRUSTED PARTNERS

By providing services through the Products, based on this Privacy Policy, user consents granted when using particular Products or other premises defined in the provisions of generally applicable law, such as the legitimate interest of the controller, selected Personal Data are passed on to third parties that process them our order, first and foremost our subcontractors – people and entities implementing our subcontracting services, which are the people and entities that enable us to fulfill our services with the highest quality and efficiency. Among these persons and entities, one can distinguish primarily suppliers of technological services and analytical service providers. On similar terms, in order to offer users unobtrusive and adapted to the preferences of users of advertisements, selected Personal Data may be transferred to third parties or entities operating in the field of marketing of own services or marketing of third-party services (ie the so-called Trusted Partners).

As a rule, all Personal Data are processed in accordance with this Privacy Policy by entities based in the European Economic Area. In the event that their headquarters would be located outside this area, e.g. in the United States, we will do our best to ensure that the person or entity will ensure the level of data protection adequate to the European Union. In relations with this kind of entities, we will apply contractual provisions in accordance with model contract terms approved by the relevant bodies of the European Union.

Users expressing their consent to the processing of their Personal Data in accordance with this section of the Privacy Policy, expressing their consents when using individual Products. At the same time, users declare that they understand and agree that the administrator of their personal data, other than TRADE STATE, may be specified in this section by our subcontractors or Trusted Partners; Users can withdraw their consent for processing by a specific person or entity, following the procedure set out in the “How Users Use Your Rights” section of this Privacy Policy, i.e. by sending a properly worded message to info@skaer.is. TRADE STATE undertakes that other personal data administrators within the meaning of this paragraph will comply with the provisions of this Privacy Policy and any other provisions that apply to the Users of the Products users processed in accordance with these provisions.

List of our subcontractors and Trusted partners.

COOKIE POLICY

In connection with the use of the Products by the user, so-called. “Cookie files”, constituting files containing information stored in the device memory used by the user for the purpose of using the given Product. The use of these files is intended to accelerate and facilitate the use of the Products by users, and to improve their experience with such associated use.

The cookies referred to in this section are personalized information that reflects how a particular user uses the Product. The use of cookies does not adversely affect the devices through which the user uses the Products.

By expressing consent when using individual Products, their users also agree to place on the devices through which they use individual Products, cookies and our access to the device on which they are stored – in order to use cookies. To withdraw or limit the consent referred to in this section of the “Cookie Policy”, the user should contact us by sending a message to info@skaer.is. In the message, the user should describe his or her request in any meaningful way and allow it to be identified in the set of users of any of the Products, so that its request can be fulfilled. In the event that the user’s request cannot be executed due to failure to provide sufficient information or because of other uncertainties, we will contact you to complete or clarify it. A request addressed to us in this way will be implemented without undue delay.

Although the consent referred to in this section of the “Cookie Policy” is voluntary, we reserve that the withdrawal of consent referred to in this section of the “Cookie Policy” may result in the inability to use some or all of the services provided by us under the given Product.

PRODUCTS

The current list of Products for which this Privacy Policy is applied is 
available here.

REPORTING IRREGULARITIES AND INFRINGEMENTS

As a Personal Data Administrator, we treat issues of their protection in a responsible and serious manner. Any events that may be potentially treated as a violation or a significant risk of violating our internal procedures in this respect or provisions of the generally applicable law, we undertake to immediately report to the state offices set up for this purpose and to those users who may be affected by such events. In this case, we will also take action to eliminate the causes underlying such violations, as well as actions to ensure that such violations will not be repeated in the future.