ONTOGENY GROUP

Privacy statement

PRIVACY STATEMENT

This Privacy Policy applies to personal data processed by Ontogeny Group AS and its subsidiaries (hereinafter referred to as "Ontogeny" or "we").

Ontogeny is committed to your privacy and processes personal data in accordance with the applicable data protection legislation, including the EU General Data Protection Regulation (GDPR). This Privacy Policy contains, among other things, information about how Ontogeny processes your personal data and what rights you have.

1. Controller

Ontogeny is the controller of your personal data. This also applies where Ontogeny receives personal data in connection with assignments that are part of the company's business. Ontogeny will only in exceptional cases process personal data as a data processor, in which case a separate agreement regulating the rights and obligations of the parties will be concluded.

The contact details of Ontogeny are:

Address: Klingenberggata 7B, 0161 Oslo
E-mail: post@ontogeny.no
Organisation number: NO 819386552 VAT

2. What personal data is processed and what is it used for?

In the course of Ontogeny's performance of customer engagements, including the establishment and management of customer relationships, Ontogeny will collect and process personal data for the following activities. We process personal data to the extent necessary for purposes related to Ontogeny's legitimate interest, which includes:

  • Customer control
  • Managing client relationships
  • Invoicing
  • Operation of IT
  • Storage and archiving

Ontogeny may collect and process personal data such as:

Name, email address, phone number, job title, affiliation, and investment preferences.

2.1. Suppliers and partners

We may process personal data in connection with our agreements with suppliers and partners. The personal data that will be processed is contact information and other information deemed necessary to respond to inquiries, or to enter into or fulfil agreements.

For private individuals, the legal basis for processing will be contract. Where the supplier or partner is a company, personal data is processed on the basis of Ontogeny's legitimate interest. This legitimate interest is the need to be able to have a dialogue in connection with the agreement.

2.2. Distribution of newsletters, information on courses, lectures and events, etc.

When registering to receive information memoranda, newsletters, event invitations, etc. via our website, you must provide your e-mail address, first name, last name and company/employer (or educational institution). You can also select which investment, market and competence areas you are interested in. Your personal data will be used to send you IM, newsletters, information on courses, lectures and other updates by email.

It may also be possible to register for relevant seminars and events via the website and by following links on Ontogeny's social media posts. When registering, you may be asked to provide your first name, last name, telephone number, email address and company/employer (or university if you are a student). This personal data is used to confirm your registration and to invite you to other relevant seminars and events, as well as to follow up on such events. The invitation will inform you that (if you register) you will receive an email after the seminar/event asking you to evaluate it on an anonymous basis. The evaluation will include some simple questions, including what you think about the seminar/event and its implementation. Completion of the survey is voluntary.

We may also use your contact information to send you newsletters, information about courses, lectures and events to you or your employer where there is another natural relationship.

The legal basis for processing is either Ontogeny's legitimate interest in sending information and marketing requests to clients and relations to inform about news and events or the consent of the addressee.

Recipients of our newsletters and other mailings may at any time indicate that they do not wish to receive further mailings. If you wish us to stop sending you newsletters, you can use a link to an unsubscribe form at the bottom of the newsletter/invitation to opt out of future mailings. It is also possible to unsubscribe from a newsletter for a specific market and competence area by using another link at the bottom of the mailing.

2.3. Website management and use of cookies

Ontogeny uses the analysis tool Google Analytics, which in turn uses cookies placed on our website. A cookie is a text file that is stored in your browser when you access a website. This means that when you visit our website, your IP address will be recorded to provide us with information about traffic and usage patterns on the website, but we will not use this information to identify you. Your IP address is anonymised before information is stored and used to compile statistics that are used, among other things, to develop and improve the website.

Data collected through Google Analytics is stored on Google's servers in the United States. Google is considered a data processor and is a member of the Privacy Shield.

The processing basis for recording IP address before anonymising it is Ontogeny's legitimate interest in ensuring optimal operation of the website.

The use of cookies requires your consent. Pre-setting your browser to accept cookies as a user is considered consent. You can change your browser settings at any time if you do not wish to accept a cookie. For more information about cookies and how to change your browser settings, see https://nettvett.no/informasjonskapsler/.

3. Who do we share your personal data with?

3.1. Data processors

Ontogeny will only share your personal data with third parties if they provide operations, maintenance and other technical solutions to Ontogeny. In order to safeguard your rights, we have entered into data processing agreements with them, which means, among other things, that your personal data cannot be used for purposes other than what we have agreed with you.

Our use of data processors may involve your personal data being transferred to data processors located in countries outside the EU/EEA. This means that personal data may be transferred to a country with a regulatory framework that does not provide the same level of protection of personal data as the rules in Norway. To ensure your privacy, such transfer will only take place in accordance with the applicable data protection legislation, for example via contractual arrangements approved under the GDPR.

3.2. Other third parties

Ontogeny will not disclose your personal information to others unless we have a lawful basis for such disclosure. Examples of such a basis are if you have consented to it, because the disclosure is necessary to carry out the assignment, or because we are required by law to disclose information. If the recipient is located in a country outside the EU/EEA, disclosure will only take place on legal grounds.

4. Your rights

You have, subject to certain conditions, the right to request access, rectification or erasure of the personal data we process about you. You also have the right to request restriction of processing, to object to the processing and to claim the right to data portability if certain conditions are met. You can read more about the content of these rights and when they can be exercised on the Norwegian Data Protection Authority's website: www.datatilsynet.no.

Ontogeny does not use automated decision-making, including profiling.

If our legal basis for processing is based on your consent, you can withdraw it at any time by contacting Ontogeny at the following email address: post@ontogeny.no.

If you have any questions about our processing of personal data or wish to exercise any of your rights, please contact us by email at post@ontogeny.no.

If you believe that we are in breach of data protection legislation, you can complain to the Danish Data Protection Agency. You can find information on how to contact the Data Protection Authority on the Data Protection Authority's website: www.datatilsynet.no.

5. Deletion of personal data

Personal data will only be stored for as long as necessary to fulfil the purpose of the processing.

This means, for example, that personal data we process on the basis of your consent will be erased when that consent is withdrawn. If the basis for processing is our legitimate interest, the personal data will be erased when such legitimate interest no longer exists. Data stored in accordance with statutory obligations will be erased when the obligation ceases. Typical examples of this are retention obligations under money laundering legislation and bookkeeping legislation.

Case documents will be retained for as long as Ontogeny deems relevant, normally 2-5 years. This retention period is considered necessary for the client and Ontogeny's legitimate interest in being able to review older case information that may be relevant to ongoing disputes or case management.

6. Ontogeny social media profiles

Ontogeny may create profiles in social media such as LinkedIN. User profiles are created in accordance with the terms of use of the relevant social media platform. Ontogeny processes personal data in accordance with the terms and conditions set by each platform from time to time and in accordance with the data protection rules.

The social media use cookies when you use their services. Information on what personal data is collected and how it is used by the respective social media can be found in their privacy statements.

7. Measures to ensure the security of your personal data

Ontogeny is committed to preventing unauthorised access to your personal data. Ontogeny therefore uses a variety of security technologies that provide a high level of protection against unauthorized access and misuse of your personal information. Ontogeny has also established internal procedures to ensure your privacy.

8. Disclaimer etc.

The content of our website is for general information only.

9. Use of information from the websites

Copying and making available information from our website requires written consent from Ontogeny.

10. Telephone recordings

As part of our compliance with applicable laws and regulations, telephone conversations with Ontogeny Corporate Finance employees will be recorded and stored. Please note that these recordings may be made with or without the use of a verbal warning, tone or similar notice.

11. Contact us if you have any questions

If you have any questions about Ontogeny's processing of personal data, any changes, etc. you can always contact Ontogeny directly by email: post@ontogeny.no.