Privacy Policy for the Eterni Group

This Privacy Policy applies to:
Our current and past employees
Our customers and other recipients of our services
Job applicants applying for a position with us
Candidates and job applicants associated with the Eterni Foundation
Freelancers and recipients of freelance services
Contact persons at our suppliers and partners
Visitors to and users of our website and apps
 
This Privacy Policy does not apply to the administrative staff of the Eterni Group.
This Privacy Policy describes how we process personal data and Personal Identifiable Information, abbreviated as PII. Personal data refers to all forms of data, information, knowledge, assessments, etc. related to you as an individual. For data to be considered personal data, it must be possible to identify a concrete person, either directly or indirectly. 
This policy statement describes when and how we collect personal data, how we process data, who we share it with, how information is safeguarded, your rights and how you can contact us in connection with your rights.
 

1. Who is the data controller?
Eterni Group AS is headquartered at Fjøsangerveien 57, 5054 Bergen. reg. no. 914 108 373, and has the following subsidiaries: 

Eterni Norge AS, bus. reg. no. 996 674 347
Pedagogisk Vikarsentral AS, bus. reg. no. 986 550 909 
Eterni Sweden AS, bus. reg. no. 556863-7283 
 
Eterni Group and its subsidiaries (hereinafter referred to as ‘We’ or ‘Us’) under the direction of its CEO, is the data controller for the processing of personal data at our organisation. This responsibility includes ensuring that personal data is used and processed in accordance with the relevant regulations.

2. Our processing of personal data
The types of personal data that we collect and process depends on our relationship and contact with you. The personal data that we process must have a purpose and a legal basis.  Below is an overview of our processing of personal data in the various situations that involve you. 

When you contact us

When you contact us, such as through our website, email or phone, we may process personal data on you. In most cases, the data we collect is your contact information, such as your name, email address, phone number and the reason you contacted us. Relevant information that you provide during phone conversations and email correspondence may be stored if we deem this necessary. 

We would like to draw your attention to the fact that regular email is not encrypted, so you should not send us confidential, sensitive or other personal information by email. 

The purpose of processing your personal data is to be able to respond to your inquiry, as well as to store information that may be relevant in connection with the reason for which you contacted us. Data processing for this purpose is based on our legitimate interest in the processing that is not overridden by the rights or interest of individuals. 

Job applicants

If you apply for a job with us, we will use the information you provide to evaluate your job application. This information is usually your name, date of birth, contact details, civil status, interests, CV, course certificates, diplomas, education and work experience, references, etc. During interviews, we ask questions to determine whether the applicant is suitable for the position. In some cases, we may use tests or questionnaires for this purpose. If you are considered for a position, we may request additional information, as well as documentation for the information we have already received. You are not required to provide any information. 

The purpose of this processing is to potentially offer you a job. The processing of personal data is based on a consideration of interests. We need to use this information to evaluate job applications that are submitted to us. If you are not offered a position with us, we will delete your personal data within six months, provided, of course, that you do not consent to continued registration in our database as a job seeker. 

Current and past employees

Personal data is collected on you as our employee and from other relevant authorities with regard to the customary information that is needed to manage your employment with us. The personal data that we collect and/or store incudes the following:

Name
Contact information (address, phone number, private email address)
Personal identification number
Next of kin information
Tax-related information
Bank account information
Salary information
Information about travel and expense account claims
Job information
Employment agreement
Information about absenteeism, sick leave, compensatory time off, holidays and leaves of absence
Working hours information
Personnel file information
Documents from application processes, such as leaves of absence
Employment documents, such as a job application, CV, references, certificates and diplomas
Course and other certificates
Warnings
Performance assessments
Feedback from customers/workplace
Resignation and dismissal
Results of questionnaires or work-related surveys
Notes from performance interviews
Health-related information or police certificate of good conduct if absolutely necessary for your position We limit the storage of such information to the absolute minimum and process all data in accordance with security measures and procedures for information protection.
 
The purpose of processing your personal data as an employee is to facilitate personnel administration, such as the payment of salaries and holiday allowances, reimbursement of expenses, calculation of tax deductions and pension contributions, holiday and absence planning. This provides the basis for salary and performance assessments. It is also necessary for reporting to the relevant government authorities. The legal basis is the Personal Data Act, section 8, first paragraph, and section 8 a), b) or f), as well as section 9 a), b) and f). 

As a former employee, the processing of most personal data is based on a consideration of interests. It may become necessary for us to document the employment relationship even after employment has ended, such as due to a dispute with the former employee. This may concern, for example, documentation that shows that we have fulfilled our obligations as an employer according to the law or employment agreement. This is a legitimate interest and it is not possible to access this information in any other way, so this processing is therefore necessary. The information will not be provided to third parties unless requested specifically by the former employee, such as in connection with potential employment with a new employer. Personnel files are discarded at the end of an employment relationship.

Freelance services

If you register as a freelancer or use our freelance services, we may save contact information on you and your clients that you provide. Examples of contact information that we collect are names, addresses, phone numbers and email addresses. If you would like for us to procure assignments for you as a freelancer, we may collect information on your work experience, work skills, CV and other relevant information that you choose to share with us in order to carry out a freelance project for us. We also save personal identification numbers and bank account information in order to pay for services rendered. Evaluations or feedback from clients are saved if considered necessary for purposes of offering potential future freelance projects. However, you are not required to provide any information. 

We process contact information for private individuals or contact persons at businesses that use freelance services. This information is usually provided by the freelancer when submitting invoice-related information on the website. This information is generally contact details, such as a name, phone number and email address, as well as information on the position and employer. Communication and agreements in which we are involved are also processed. 

The purpose of processing your personal data as a freelancer or recipient of freelance services is to facilitate personnel administration in order, for example, to pay for services rendered, reimbursement expenses, calculate tax deductions, and so on. This processing is necessary to fulfil an agreement with you, as well as to meet our legal or contractual obligations. 

Candidates and job applicants associated with the Eterni Foundation

If you apply for the mentor programme at the Eterni Foundation, we will use the information you provide to evaluate your application. Examples of personal data that we collect are your name, address, date of birth, phone number, email address, work experience, job skills, duration of unemployment and other information you choose to share with us. During interviews, we ask questions in order to determine which candidates can be selected for the mentor programme and in some cases, we use tests or questionnaires for this purpose. If you are considered a potential candidate, we may ask for additional information, as well as documentation for the information we have already received. However, you are not required to provide any information. 

The purpose of this processing is to potentially offer you assistance in finding employment. The processing of personal data is based on a consideration of interests. We need to use this information to evaluate the applications submitted to us by candidates. If you are not selected as a candidate for the Eterni Foundation, we will delete your personal data within six months. 

The Eterni Foundation also processes personal data on contact persons at companies, organisations or institutions that apply for subsidy schemes for “Good everyday experiences for children and adolescents”. This information is generally contact details, such as your name, phone number and email address, as well as information on your position and employer. Other information that you share with us or that originates from our contact with you will be processed if deemed necessary to manage the application process, including information originating from application letters and other attachments. 

The processing of personal data is based on a consideration of interests. We require this information in order to process your application and to contact individuals directly in order to effectively manage the application process. 

Pictures, drawings, etc. that you submit may be used for marketing purposes for the Eterni Foundation and in announcements of a winner(s), provided you consent to this specifically during the application process. This is not required to be considered as an applicant.

Representatives of our suppliers and partners

If you are an employee of one of our suppliers or partners, it may be necessary for us to process personal data on you in order to manage and follow up on offers, purchases, orders and deliveries. This information is generally contact details, such as your name, phone number and email address, as well as information on your position and employer. Other information that you share with us or originating from our contact with you will be processed if deemed necessary to manage our supplier/partner relationship. This also concerns information we receive through contact by phone, email or our website, social media, events, sales activities and other communication situations. 

The processing of personal data is based on a consideration of interests and we consider it necessary to contact individuals directly in order to effectively manage the supplier/partner relationship. 

Customer representatives

If you are an employee of one of our customers, it may be necessary for us to process your personal data. This information is generally contact details, such as your name, phone number and email address, as well as information on your position and employer. Other information that you share with us or originating from our contact with you will be processed if deemed necessary for the processing purpose. This also concerns information we receive through contact by phone, email or our website, social media, events, sales activities and other communication situations. 

The purpose for which we process personal data for registered contact persons at customers is primarily in order to carry out our services, as well as follow up on the customer relationship and carry out other sales activities. The processing of personal data is based on a consideration of interests. It is necessary for up to maintain contact with our business customers in order to follow up on offers, orders and deliveries. In some cases, we are required by law to process personal data. This may be to document obligations in relation to taxes, salaries, accounting or legal processes. This may be relevant if your name is stated on a contract that is subject to the archiving requirement. The legal basis for processing in this case is the legal obligation to which we are subject. 

Surveys

Surveys are sent to registered customers and employees for various purposes, such as invitations and registration for events, customer and employee surveys, including satisfaction surveys and questions pertaining to your relationship with us, etc. Participation in these surveys is voluntary. The responses we receive will be stored for as long as necessary in connection with the survey. If the survey is anonymous, you will be informed of this and we will not be able to identify those who have participated in the survey. 

The processing of information from surveys that concern registration and events is for purposes of planning and preparation, whether the event is professional or social or both. The processing of this kind of personal data is based on a consideration of interests.

The processing of information from surveys associated with satisfaction studies, etc. is to provide us with a basis to make improvements and develop as a company.  The personal data that we receive through surveys of this kind is processed based on our legitimate interest in the processing that is not overridden by the rights or interests of individuals. 

Newsletters

It is possible to subscribe to newsletters from Eterni and its associated subsidiaries. You can unsubscribe to a newsletter at any time by clicking on the unsubscribe link in the email. We do not use unsubscribed email addresses for new email lists without your reaffirmed consent and we do not share your information with third parties.

The personal data processed in connection with this includes your name, town/city, email address and the extent to which you have a customer or candidate relationship with the company and, if relevant, the extent to which you are a current, active employee (so that we can send you information on, for example, vacancies and projects).

Your personal data will be processed not only by us, but also by Mailchimp, which provides the technical solution for our newsletter.

If you have an active customer or employee relationship with us, you will be registered in our relevant email lists, so that we can send you information and news about us, our disciplines and/or other circumstances or matters that are important to your relationship with us. The legal basis for this processing is a consideration of interests (legitimate interest), as well as section 15 of the Marketing Control Act.

Other recipients of newsletters, such as potential customers and candidates, will only receive newsletters if they have explicitly consented to this in writing or digitally. You can revoke this consent at any time and will be removed from the recipient list.

Social media

We have created pages for the company in such social media as Facebook, Instagram, LinkedIn, Twitter and YouTube. We use our pages in social media to promote our company and recruit candidates. We use plug-ins and social media tools on our pages to enhance functionality and for traffic analyses of our pages. We occasionally publish external links on our social media pages, such as to our own websites, to enable users of our services to read about subjects related to our work, see new job vacancies that may be relevant for them to apply for, learn more about our services, business hours or other information we believe our followers or target group may find useful, interesting or informative. The basis for having our own company pages in social media is a consideration of interests.

By interacting with other users, posting and/or sharing posts, etc. with the company’s profile of services, we have access to the information you post. We wish to point out that this is public information and, consequently, all information that you post or provide can be seen by others. This information can be deleted by the person who posted it. Please note that it is voluntary to like, follow or interact with our social media pages. 

The company’s use of social media provides the company with access to tools for analytic and statistical purposes from the respective services (page insight). These only allow us to see anonymised statistics and do not provide access to personal identifiable information.  In some cases, we may use this information via the social media channel to show you targeted advertisements.

Please note that Facebook, Instagram, Linkedin, Twitter, YouTube, etc. use cookies and other tracking mechanisms to adapt the content of the page in order to reach the right target group with different advertising campaigns. It is possible for the individual user to change the settings for this and we recommend reviewing this information. We also recommend that you read the Privacy Policy for the site in question, as well as adapt the cookies to your own privacy preferences. Read more about how to manage cookies on Nettvett.no.

3. Sharing of personal data
In some cases, it is necessary for us to share your personal data with our data processors. This usually pertains to suppliers specialising in salary, accounting, operations, maintenance and IT services. We have entered into data processing agreements with all organisations that process personal data on our behalf. Our data processors cannot process personal data in any way other than agreed with us as the data controller.

We may also provide information about you if required by law or other regulations, usually the authorities or other government agencies. We also reserve the right to transfer the personal data we have on you in the event of a sale or transfer of our business in full or in part.
 

4. How is data secured?
We have implemented administrative, technical and physical security measures developed to protect the personal data you provide in terms of: 

Confidentiality (unauthorised persons cannot access the data)
Integrity (data cannot be modified unauthorised or unintentionally)
Accessibility (data is available when needed)
 

All digital transfer of PII is protected by encryption, TLS (email) and SLL (website traffic). All PII data that is stored is located on secure servers at our suppliers. We carry out risk and vulnerability analyses regularly of the data systems we use to protect your personal data. To prevent unauthorised persons from accessing personal data, we have implemented access control systems and all employees have a confidentiality obligation regarding personal data that they need to process as part of their daily work.

5. Retention periods
We store your personal data at our company for as long as necessary for the purpose for which it was collected, as well as in connection with legal and other compliance obligations. In some cases, it may be necessary for us to process and store personal data for specific periods of time. If a legal storage obligation applies, personal data will be deleted at the termination of that obligation, provided there is no reason to process the personal data further. 

You can request to have your personal data removed from our systems at any time. In this case, all information that is not necessary to save will be deleted. Salary information, employment agreements, etc. that we consider necessary to save will be saved in accordance with the legal basis for which it was collected, such as salary data and employment agreements.

All of our employees are personally responsible for deleting email, documents and other information that contains personal data that is no longer relevant and are required to review and delete unnecessary email from their inbox at least once a year. On termination of employment and retirement, the email accounts for administrative employees are deleted after six months, although a few relevant emails will usually be forwarded to colleagues first. 

If the data processing is based on your consent, we will delete personal data if you revoke your consent, unless there is a valid reason to continue to process the information.

6. Our contact information and your rights
You can exercise your rights by sending us an email at privacy@eternigroup.com. You have the right to a response without undue delay and within one month at the latest. 

All those registered in our system have the following rights:

Access. You have the right to know which personal data we process on you and how this data is processed.

Correction. You can ask us to correct any erroneous personal data about you.

Erasure (right to be forgotten).  You can ask us to delete your personal data.

Limitation. You can ask us to limit the processing of your personal data.

Objection. You can object to the processing of your personal data.

Data portability. You can ask us to transfer personal data to you or others in a structured, widely used and machine-readable format.

Please note that there may be exceptions and limitations to the rights stated above. For example, we are unable to delete personal data that we are legally required to save.

Complaint. If you believe that we have not adhered to the rules stipulated in the Personal Data Act, you have the right to complain to the Norwegian Data Protection Authority. We hope that you will contact us first to enable us to consider your objections. 

You can also find information on the rights of registered persons on datatilsynet.no.

7. Visit to our website and cookies
Information on cookies and privacy in connection with a visit to our website can be found on the following websites:

eternigroup.com/cookie-policy/
eterni.no/cookie-policy/
eterni.se/cookie-policy/
pvs.no/cookie-policy/

8. Changes to the Privacy Policy
We reserve the right to change or update this Privacy Policy. We update the Privacy Policy when necessary, such as in response to new legislation or if we make changes to our processing of personal data. This website will always contain the most recent version of our Privacy Policy.