General Business Privacy Policy

In order for us to deliver our services to you in accordance with your needs, we need to process your personal data.

2.1 What we use your personal data for

We need to use your personal data to deliver our services to you. The usage of your personal data must comply with the Norwegian Personal Data Act. Frid, as the data controller, will ensure that we use personal information about you in accordance with the rules of law.

We use personal data for:

• Marketing for our products and services;
• Product development and analysis;
• Managing your information and accounts;
• Providing access to specific features and functionalities on our Services;
• Communicating with you about your account, activities on our Services, and Policy changes;
• If applicable, processing your financial information and outer payment methods for products or Services purchased;
• Answering your requests for customer or technical support;
• Security;
• Compliance with industry-specific regulations;
• Measuring interest and engagement in our Services;
• Ensuring internal quality control;
• Detecting bugs or other software issues;
• Preventing potentially prohibited or illegal activities;
• Frid has various advisors and employees with different areas of expertise. If you consent, we may transfer information to one or more of them so that we can provide you with the assistance you need. You will always be provided with an overview of which information is being shared before you consent to sharing, and consent must be given in each individual case. The advisors will treat the information you choose to share confidentially.

In addition, we use your personal information for the following purposes:

1. Offer website and the App: We use information to adapt our website and App to the technical equipment you use. We may also use the information to adapt the content of our website and app to what we think you are interested in.
2. Carry out data collection from Third-parties: we use your data to obtain the information we need to provide you with a good service (e.g., bank accounts and other financial information).
3. Create your user account: we use information if you create a user account (e.g., giving you access with username and password, to store your contact information, payment information, and your purchase history.
4. Customer service: we store information that you provide if you contact us requesting customer service and managing customer relationships.
5. Statistics: we compile statistics and map market trends to improve and further develop our products and services. As much as possible, we compile data with anonymous information (without knowing that the information is specifically related to you).
6. Marketing: we use your contact information (e.g., telephone number and email address) to send you recommendations and information about our Services. We may use Feed Admin Services to send recommendations and information to you as relevant as possible, unless you have objected to this. If you wish, we will also send you recommendations and information.
7. Invitations: If you wish, we will also send you recommendations and information.
8. Anonymized Information for Employers: If the app is affiliated with an employer and conducts financial health checks, anonymous information about the results of the health check may be aggregated with the results of other employees, for the purpose of providing the employer with anonymous management information. As a result, the employer will be able to implement collective assistance measures more easily. Frid ensures full anonymity before the employer gains access to such aggregated 

Basis for processing

The processing is considered lawful according to Article 6 of the Privacy Law, as the data subject has consented to the processing of personal data in accordance with the purposes outlined above.

Frid will not use your personal information beyond what is necessary to fulfill its agreement with you, develop upcoming services, or what the company is required to by law.

2.2 Categories of personal data

Personal data covers all information and analyses that can be linked to you as an individual. Frid processes the following categories of personal data:

• Identification & contact details: name, gender, date of birth, telephone number, address, and email address. The purpose is to identify you, as well as manage the customer relationship. Your address, email address and any other contact information are also used for marketing purposes (Customer service, marketing and consent). We only retrieve the data by having your free and explicit consent.
• Purchase information: purchase of goods or services from us such as card number and payment method (e.g., Visa, Mastercard, Vipps, historic purchase transactions, etc.)
• Communication: telephone calls, video calls, emails, SMS, and others.
• Location: city, zip-code, country, IP address, chat, and others.
• Website/app: type of device (operating system), IP address, functions, pages visited, login time. Login time is stored at an individual level.
• Third-party information: If you explicitly and freely agreed to it, Frid may collect your bank account and transaction information from accounts in other banks.
• Financial information: customer and product agreements and transaction data.
• Information to meet regulatory obligations and reporting to public authorities.

2.3 Customer and market research

We process personal data in connection with market and customer feedback. For example, your feedback helps us to provide you with better products and services. In addition, we can measure the effectiveness of improvement measures and look at the link between customer satisfaction and customer behavior over time.

If you do not want to share this type of information with us, you may opt out of responding to the survey we send you.

Basis for processing

The processing is based on explicit and free consent from users. By consenting, Frid may obtain information about how our customers perceive us and what opinions our customers have about our Services.

2.4 Product development and analyses

Based on analysis purposes, Frid may collect information about how a customer uses its services on digital platforms and in other communication channels. This information is also used to identify potential demand for new products and services, and to improve the functionality of existing products and services.

The following are examples of how we apply analyses:

• To determine price levels;
• To personally adapt our web pages;
• To analyze website traffic and use of email and text messaging;
• To personally adapt information and relevant ads.

You can read more about our website’s cookies policy here.

Basis for processing

Frid has a legitimate interest in conducting market and customer analysis to develop new and existing products and services, and to provide good customer service.

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app

We need personal data to give the most personalized service to our users. Most personal data that we record comes directly from you as our user.

3.1 Collection of personal data from you as customer and from others

The personal data that we collect about you will generally come from you as our user. When we enter into an agreement with you, we will record information about you and other people related to the agreement, such as marital partners or other Frid account holders. We will also record information about people we have not entered into agreements with. This way, we can inform you about the personal refusal and acceptances, and possibly document the matter later (e.g., show the refusal of tracking activities on the mobile application). The documentation store lasts as long as necessary to achieve the purpose for which it was collected, or if we are required to store the information by law.

If we wish to obtain information from you that is not important to manage contractual relationships, we will firstly inform you explicitly that it is optional to disclose the information and what the information will be used for.

Sometimes, we collect your personal information from other institutions, such as Vipps. This may include market-related or demographic information, for instance, identification and contact information as stated on Section 2.2 “Categories of personal data”.

3.2 Storage period

We store information about you, only as long as it is necessary to achieve the purpose for which it was collected, or if we are required to store the information by law. The information will be deleted or anonymized when it is no longer necessary to achieve the purpose. Below is an overview of how long we store your information:

• Identification & contact details: if you have a user account with us, we will delete the information when you cancel the user account within two weeks, or if you have been inactive for more than 12 months. We will also delete information if you object to being profiled.
• Purchase information: we will delete your card number three months after the transaction took place, unless you ask us to save the information for the next purchase. We store transactions and payment information for 5 years in accordance with the Norwegian Accounting Act.
• Website: based on our Cookies policy, we store general use information about you for up to 12 months as a user, customer, and potential customers. Read more about our website's Cookies policy.
• Third-party information: we store any information from partners as long as you have an active user account with us or as long as you have freely and explicitly consented. We will delete the information within two weeks, if you cancel your user account, or the user account has been inactive for 12 months.
• Communication: we store communication with our customers for three years, unless we need to store it longer (e.g. in connection with complaints or claims).

3.3 Disclosure of personal data

By disclosure of personal data, we mean transfer to other institutions and people that have the right to use the information. Transfer of personal information to our data processors is not considered as disclosure.

To other institutions

Registered personal data will only be provided to public authorities and other third parties when required by statutory disclosure obligations or rights. An example might be if the Norwegian government requests data from us.

We share personal information with companies that provide technical and administrative services to us, such as IT providers. Sharing personal information is based on providers’ privacy policy and European Commission’s Standard Contractual Clauses (SCCs).

By explicitly consenting, we may share your personal information with our partners as described in your consent. This can be, for example, consulting services or service providers, so that they can send you recommendations and information that is relevant to you. Additionally, so that they can carry out their own market analysis and service development.

We can also share anonymized information with partners, for example market analysis and service development.

3.4 Use of data processors

We use IT suppliers outside the EU/EEA. If we transfer personal data out of the EU/EEA, Frid certifies that privacy is ensured through the conclusion of contracts in accordance to the European Commission’s Standard Contractual Clauses (SCCs) for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. We use it as a mechanism to transfer data from the EU to the US. These guarantees are structured to assure the appropriate groups that Frid’s data-handling processes meet rigorous policy requirements. You can request more information or a copy of the security mechanisms we use to secure the transfer of the information.

Frid collects and processes all your data through Amazon Web Service in Sweden and Great Britain and Google Analytics in the United States. User data is stored solely in Sweden and cannot be moved, except to comply with the law or binding order of a governmental body. Additionally, we use HubSpot analytics to collect information about traffic analysis on our website. HubSport servers store your activity information in the United States of America and Germany. Frid possesses signing agreements with any third parties. The agreements guarantee that users will remain anonymous and that no personally identifiable information is sent or shared. We may not use the data for any other purpose other than what it has been collected for.

When you are logged in, we may use information from your activities on the website to improve your user experience. The purpose of the information we collect is to:

• Adapt the platform to better suit your needs.
• Provide you with better recommendations, products and services.
• Contact you if you get stuck.

Please, read more about our Cookies policy.

Here you can find the following third-parties that we might share and store your data with:

• Amazon Web Services
• Tink
• HubSpot Privacy Policy
• Google Analytics

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app

It is important that you should feel confident that your personal data is secure with us. Here you can understand what we do to safeguard information against loss, misuse, accidental access, disclosure, alteration and destruction.

4.1 Technical, organizational, and administrative security measures

We evaluate the risks associated with all functions and systems, and we and security-test solutions and systems so that errors and weaknesses are avoided as much as possible. Solutions and systems that are in development and production processing your information are constantly updated and monitored so that errors are avoided or detected as quickly as possible.

Frid is continually working to maintain the security of its systems and solutions. This includes the appropriate use of security technologies such as end-to-end encryption, data encryption at rest, Amazon API gateway for DDOS mitigation, and Amazon Cognito for access control, as well as developing other measures that support security at Frid. Key measures are a separate management system for information security, access control, and non-conformance management.

Your primarily personal data comes from Tink AB. The data is made accessible when Tink provides the service to Frid and in connection to the user request regarding the provision of the service. The data disclosed from Tink only refers to such data that is necessary to provide the Tink Service the user has requested.

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app

Here you can find information about your rights.

5.1 Right of access

You have the right to information about the personal data that we process and how we process it. Your personal data is generally available from online open banking. If you do not have online banking or cannot read electronic documents for some other reason, please contact us on support@frid.app

In certain situations, there are exceptions to the right of access. Typically, when we are legally bound to secrecy or where we have to keep the information confidential for the prevention, investigation, detection and prosecution of criminal acts. Another exception is where the information is contained only in documents prepared for internal case handling and exclusion from access is necessary to ensure proper processing.

You may have the right to ask us to:

• Provide you with further information on how we process your personal information.
• Give you a copy of personal information about you.
• Update your personal information.
• Delete information (under certain conditions).
• Limit or stop processing your information (under certain conditions).
• Stop automatic decisions, including profiling.
• Withdraw any consent you may have given.

5.2 Rectification and erasure

It is important that the information we have about you is correct. Within the limitations set out in the Personal Data Act you can ask us to correct and delete information about you if they are wrong or unnecessary. Frid checks its data against other sources.

Frid deletes or anonymizes personal data when the purpose of the particular processing of personal data has been met, unless the law allows or requires the information to be retained for longer than this.

5.3 Restriction of personal information

In some cases you can ask for restrictions on the processing of your personal data without wishing to have the data deleted.

Restricting processing may mean that your personal data cannot be used, but we are still able to retain your information.

Frid may start processing your personal data again in connection with legal requirements or in order to protect another person’s rights. For further terms of service and information on restricting personal data, contact our data protection expert at privacy@frid.app.

5.4 Shielding your personal data

If you have a particular requirement for us to restrict the number of employees who have access to, and knowledge of, your personal information, we may consider this.

Shielding your information entails a substantial reduction in our ability to follow up on you as a user. For further terms and information on shielding personal data, contact our data protection expert at privacy@frid.app.

5.5 Objection to processing

In some cases you may have the right to object to processing of personal data by Frid. Your right to object will be assessed based on your situation; it may be, for example, that you have a special need to protect your identity or that you belong to a particularly vulnerable group in society.

You have the right to object to the processing of personal data in connection with direct marketing. If you wish to opt out of direct marketing, please contact our Customer Service, at support@frid.app.

5.6 Automated decisions

Automated decisions are decisions made by computer programs without human intervention or influence. When such decisions have a legal or equally significant impact on you, Frid can only use them when necessary to enter into or fulfill an agreement with you, when the law requires/allows it, or when it is based on consent that you have given.

5.7 Right of appeal

If you believe that Frid is not processing your personal information in the manner required by the rules, you can complain to our data protection expert at privacy@frid.app. We will clarify and handle any question and misunderstanding accordingly. You may subsequently lodge a complaint to the Norwegian Data Protection Authority.

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app

With the aid of personal data, interest, and user group profiles, we adapt communication, advice, and offers to be relevant and useful. The information about you is also used in analyses, customer surveys and product, and service development.

6.2 Digital customer service and marketing channels

Web page

• Frid

Our apps

• Frid App (iOS)
• Frid App (Android)

Newsletters, e-mail and customer surveys

Social media

• Facebook
• Instagram
• LinkedIn

6.3 Social media and responsibility for processing

For social media sites, such as our Facebook page, we may share the responsibility for processing with the provider of the social media (limited to the data we have control over or access to). For use by social media of information about you, we encourage you to read their privacy information.

We process information about your activities on our site, including when you visit it, publish content (e.g. text, images, and videos) and respond to our own or other content (e.g. likes and comments), in order to administer the site. The legal basis for our use of information for this purpose is our legitimate interest in making available our content on social media and in communicating with you.

We also manage aggregated information about visits and activities on our social media pages for statistical and analytical purposes. This is not personal data for us, because we cannot link it to individuals.

We do not store this information ourselves, but we do have access to it as long as we maintain the particular social media site. You can delete information about yourself at any time (e.g., removing any content or responses you have published). Please note that your information is not deleted simply by you ceasing to follow our site.

Ad purchases

You can see ads from us on social media and websites when we buy ad slots through various media. The information is encrypted so that personal information security is safeguarded and the information is used only to carry out the placement of the ad.

Facebook Pixel

Facebook Pixel directs network traffic across Frid’s web page and the Facebook interface. The information that we collect is used to provide customize content and to provide relevant ads on Facebook channels. Facebook Pixel collects information about your activity.

Customer Matching Services from Facebook and Google

We can show interest-based ads to you when you use Facebook or Google through the Facebook Custom Audience and Google Customer Match services. Using Facebook Custom Audiences, we can customize our ads based on your behavior on the website. When these services are used, your e-mail address or phone number is linked to what is registered with your user at the social media provider. In this way, we can advertise more relevant than a standard ad. We do not share any of your personal information with Facebook.

Here is an overview where you can make changes:

• Change settings for ads on Facebook
• How to opt out of ads on Facebook (will apply to all advertisers)
• How to turn off custom ads from Google
• See also our website’s cookies policy.

6.4 Consents

In order for Frid to provide you with customized advice and offers we must first obtain your freely and explicit consent. The consent we request can be found in mobile Frid under Settings. You can change your consent at any time on our app.

6.5 Right to opt out

If you do not wish to receive offers from us, you can opt out. Contact our Customer Service at support@frid.app and we will record your decision to opt out. We will still follow-up your service agreements, as we are obliged to do, even if you have opted out to marketing material.

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app

In very specific cases, Frid makes audio recordings of telephone calls and video meetings with our users.

7.1 Audio recording of phone calls

With your explicit consent, we may occasionally record phone calls made to and from our call center. We do this to improve our products or services. For example, with your consent, we might record a user testing feedback on our platform.

As a rule, we ask for your explicit consent when we wish to make recordings of phone calls or video meetings. The recording will be used only if you or we need to document the content of the conversation.

You can request access to audio recordings by contacting Frid. When you make your request, you must specify the time when the call was made and from what phone number.

Please contact us by mail support@frid.app if you want access to a recording that has been saved.

Basis for processing

Processing of personal data by sound recording is done in order for Frid to fulfill its legal obligations, and is based on the company's legitimate interest.

7.2 Saving chat communication

If you start a chat from Frid’s website, the communication will not be anonymous. The chat is saved for use in customer service statistics and evaluation, but cannot be linked to you as a lead-customer. The chat conversation will be made available to this adviser. The purpose is to give the chat supporter an opportunity to familiarize themselves with your inquiry before the chat continues. Chats are stored for 12 months.

Basis for processing

Personal data is processed based on our legitimate interests in following up on you as a user and documenting our contact with you.

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app

Our mobile app, sometimes, needs access to functions and information on your phone. The app only asks for the access required to work. We are unable to view the data on your phone.

Mobile app asks for access to:

• View network connections, in order to use the network, and hence the Internet.
• The internet, for the app to be able to send and receive data to and from our servers.

You can decide whether to give Vipps access or not, but be aware that the app will not work as intended if the accesses are turned off. Android requires you to approve all or none.

• Read also How We Safeguard Your Personal Data.

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app

It is important to us that you should feel secure when you visit our website, and for us to do our best to provide you with what you need.

9.1 Web analytics tools and statistics make us improve our services for you

Frid’s website makes use of cookies. These are small pieces of data that are stored on your computer or your mobile phone by the browser you are using. A cookie belongs to a particular website and cannot be read by other websites. In addition to cookies, we use pixels from third parties.

The tools we use to collect information are Google Analytics, and we have agreements that guarantee that users will remain anonymous and that no personally identifiable information is sent or shared. Google Analytics is used, the information on your activity is stored on Google's servers in the United States.

If you have not logged in to our website, we are not able to identify you as an individual, unless you start a chat communication with us. However, we do measure any activity on our website in the form of statistics such as:

• Your activity on our website, such as the pages you visit and how often or for how long you stay there. 
• Your approximate geographical location using the IP address, which then is made anonymous.
• Technical information about your browser and your operating system.

This will again be passed on to various customer groups so that we can make better recommendations, and provide you with information and products tailored to your needs.

9.2 Marketing and third party cookies

Our cookies are used to measure what you do on our website. The information can be used to build interest and user group profiles, as well as to develop and show you relevant ads.

You may receive marketing messages from us based on pages you have visited (retargeting) thanks to third-party cookies such as pixels. This also enables us to stop showing an ad when you have completed a defined point in a process. These cookies only contain aggregated information and no information that can identify you as a user.

You can read more about Customer service, marketing and consent.

9.3 Cookies settings

We use cookies on our websites to ensure functionality, analyze web traffic and see which areas of our website you have visited.

You can delete cookies placed on your PC via your browser if you so wish. However, please note that this may result in some parts of our website not functioning properly.

You can learn how to check which cookies have been placed on your PC and manage your use of cookies on nettvett.no.

Contact us:

Call: (+47) 57 00 63 33

Send email: support@frid.app