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Privacy Policy

Norse GroupPrivacy PolicyV1 May 2018
IntroductionWelcome to the Norse Group’s privacy notice. The Norse Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.


1. Important information and who we arePurpose of this privacy noticeThis privacy notice aims to give you information on how we collect and process your personaldata, including any data you may have provided through this website or when you sign up to ournewsletters, request information concerning our products or services or take part in acompetition. It is important that you read this privacy notice together with any other privacy notice or fairprocessing notice we may provide on specific occasions when we are collecting or processingpersonal data about you so that you are fully aware of how and why we are using your data. Thisprivacy notice supplements the other notices and is not intended to override them.ControllerThe Norse Group is made up of different legal entities but is divided into three main trading areas:ï‚· Norse Commercial Services (which provides a wide range of facilities management services);ï‚· NPS Property Consultants (which provides multi-disciplinary property consultancy services); andï‚· Norse Care (a provider of care homes and care services). This privacy notice is issued on behalf of the Norse Group Limited so when we mention Norse, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the NorseGroup responsible for processing your data. Norse Group Limited is the controller andresponsible for this website. We have appointed a data protection officer (DPO) who is responsible for overseeing questionsin relation to this privacy notice. If you have any questions about this privacy notice, including anyrequests to exercise your legal rights, please contact the DPO using the details set out below. Contact detailsOur full details are:Full name of legal entity: Norse Group LimitedName of DPO: Stuart McWilliamEmail address: dpo@norsegroup.co.ukPostal address: Lancaster House, 16 Central Avenue, Norwich, NR7 0HRTelephone number: (01603) 706000You have the right to make a complaint at any time to the Information Commissioner’s Office(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please to contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes this version was last updated on 25th May 2018. It is important that the personal data we hold about you is accurate and current. Please keep usinformed if your personal data changes during your relationship with us. Third-party linksThis website may include links to third-party websites, plug-ins and applications. Clicking onthose links or enabling those connections may allow third parties to collect or share data aboutyou. We do not control these third-party websites and are not responsible for their privacystatements. When you leave our website, we encourage you to read the privacy notice of everywebsite you visit.

2. The data we collect about your personal data or personal information means any information about an individual from which people can be identified. It does not include data where the identity has been removed(anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Contact Data includes billing address, delivery address, email address and telephonenumbers. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details ofproducts and services you have purchased from us. Technical Data includes internet protocol (IP) address, your login data, browser type andversion, time zone setting and location, browser plug-in types and versions, operatingsystem and platform and other technology on the devices you use to access this website. Profile Data includes your username and password, purchases or orders made by you, yourinterests, preferences, feedback and survey responses. Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketingfrom us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for anypurpose. Aggregated Data may be derived from your personal data but is not consideredpersonal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data sothat it can directly or indirectly identify you, we treat the combined data as personal data whichwill be used in accordance with this privacy notice. We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, certain companies within the Norse Group, for example, Norse Care, may collect Special Categories of Personal Data as part of the preparation and administration of individual resident’s care plans. Where Special Categories of Personal Data are collected we willprovide further privacy information at the point of collection. We do not collect any information about criminal convictions and offences. If you fail to provide personal dataWhere we need to collect personal data by law, or under the terms of a contract we have withyou and you fail to provide that data when requested, we may not be able to perform the contractwe have or are trying to enter into with you (for example, to provide you with goods or services).In this case, we may have to cancel a product or service you have with us but we will notify you ifthis is the case at the time.

3. How is your personal data collected? We use different methods to collect data from and about you including through ï‚· Direct interactions. You may give us your Identity, Contact and Financial Data by filling informs or by corresponding with us by post, phone, email or otherwise. This includes personaldata you provide when you:ï‚· apply to purchase our products or services;ï‚· create an account on our website;ï‚· subscribe to our service or publications;ï‚· request marketing or other product/service information to be sent to you;ï‚· enter a competition, promotion or survey; orï‚· give us some feedback.ï‚· Automated technologies or interactions. As you interact with our website, we mayautomatically collect Technical Data about your equipment, browsing actions and patterns.We collect this personal data by using cookies, server logs and other similar technologies.ï‚· Third parties or publicly available sources. We may receive personal data about you fromvarious third parties and public sources such as Companies House, the Electoral Registerand any websites where your contact information is published.

4. How we use your personal dataWe will only use your personal data when the law allows us to. Most commonly, we will use yourpersonal data in the following circumstances:ï‚· Where we need to perform the contract we are about to enter into or have entered into withyou.ï‚· Where it is necessary for our legitimate interests (or those of a third party) and your interestsand fundamental rights do not override those interests.ï‚· Where we need to comply with a legal or regulatory obligation.Purposes for which we will use your personal dataWe have set out below, in a table format, a description of all the ways we plan to use yourpersonal data, and which of the legal bases we rely on to do so. We have also identified what ourlegitimate interests are where appropriate.Note that we may process your personal data for more than one lawful ground depending on thespecific purpose for which we are using your data. Please contact us if you need details aboutthe specific legal ground we are relying on to process your personal data where more than oneground has been set out in the table below:Purpose/Activity Type of data Lawful basis for processing includingbasis of legitimate interestTo register you as a newcustomer and provide theordered goods/services to you(a) Identity(b) ContactPerformance of a contract with youTo process and deliver yourorder including:(a) Manage payments, fees andcharges(b) Collect and recover moneyowed to us(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing andCommunications(a) Performance of a contract with you(b) Necessary for our legitimate interests(to recover debts due to us)To manage our relationship withyou which will include:(a) Notifying you about changesto our terms or privacy policy(b) Asking you to leave a reviewor take a survey(a) Identity(b) Contact(c) Profile(d) Marketing andCommunications(a) Performance of a contract with you(b) Necessary to comply with a legalobligation(c) Necessary for our legitimate interests(to keep our records updated and tostudy how customers use ourproducts/services)To enable you to partake in aprize draw, competition orcomplete a survey(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing andCommunications(a) Performance of a contract with you(b) Necessary for our legitimate interests(to study how customers use ourproducts/services, to develop them andgrow our business)To administer and protect ourbusiness and this website(including troubleshooting, dataanalysis, testing, systemmaintenance, support, reportingand hosting of data)(a) Identity(b) Contact(c) Technical(a) Necessary for our legitimate interests(for running our business, provision ofadministration and IT services, networksecurity, to prevent fraud and in thecontext of a business reorganisation orgroup restructuring exercise)(b) Necessary to comply with a legalobligationTo deliver relevant website (andother) content andadvertisements to you andmeasure or understand theeffectiveness of the advertisingwe serve to you(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing andCommunications(f) TechnicalNecessary for our legitimate interests (tostudy how customers use ourproducts/services, to develop them, togrow our business and to inform ourmarketing strategy)To use data analytics to improveour website, products/services,marketing, customerrelationships and experiences(a) Technical(b) UsageNecessary for our legitimate interests (todefine types of customers for ourproducts and services, to keep ourwebsite updated and relevant, to developour business and to inform our marketingstrategy)To make suggestions andrecommendations to you aboutgoods or services provided bythe Norse Group that may be ofinterest to you(a) Identity(b) Contact(c) Technical(d) Usage(e) ProfileNecessary for our legitimate interests (todevelop our products/services and growour business)MarketingWe strive to provide you with choices regarding certain personal data uses, particularly aroundmarketing and advertising. We have established the following personal data control mechanisms:Promotional offers from usWe may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what wethink you may want or need, or what may be of interest to you. This is how we decide whichproducts, services and offers may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us orpurchased goods or services from us or if you provided us with your details when you entered acompetition or registered for a promotion and, in each case, you have not opted out of receivingthat marketing.Third-party marketingWe will get your express opt-in consent before we share your personal data with any companyoutside the Norse group of companies for marketing purposes.Opting outYou can ask us or third parties to stop sending you marketing messages at any time by followingthe opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal dataprovided to us as a result of a product/service purchase, product/service experience or othertransactions.Change of purposeWe will only use your personal data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason is compatible withthe original purpose. If you wish to get an explanation as to how the processing for the newpurpose is compatible with the original purpose, please contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we willexplain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal dataWe may have to share your personal data with the parties set out below for the purposes set outin the table in paragraph 4 above.ï‚· Internal Third Parties as set out in section 10 below (Glossary).ï‚· External Third Parties as set out in section 10 below (Glossary).We require all third parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers to use your personaldata for their own purposes and only permit them to process your personal data for specifiedpurposes and in accordance with our instructions.

6. International transfersWe do not transfer your personal data outside the European Economic Area (EEA).If this changes at any time we will amend this Privacy Policy and set out the specific mechanismswe have put in place to protect your personal data.


7. Data securityWe have put in place appropriate security measures to prevent your personal data from beingaccidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, welimit access to your personal data to those employees, agents, contractors and other third partieswho have a business need to know. They will only process your personal data on our instructionsand they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notifyyou and any applicable regulator of a breach where we are legally required to do so.In some circumstances, you can ask us to delete your data (see below).We may anonymise your personal data (so that it can no longer be associated with you) forresearch or statistical purposes in which case we may use this information indefinitely withoutfurther notice to you.

8. Your legal rightsUnder certain circumstances, you have the following rights under data protection laws in relationto your personal data:-Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that weare lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have anyincomplete or inaccurate data we hold about you corrected, though we may need to verify theaccuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personaldata where there is no good reason for us continuing to process it. You also have the right to askus to delete or remove your personal data where you have successfully exercised your right toobject to processing (see below), where we may have processed your information unlawfully orwhere we are required to erase your personal data to comply with UK law. Note, however, thatwe may not always be able to comply with your request of erasure for specific legal reasonswhich will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (orthose of a third party) and there is something about your particular situation which makes youwant to object to processing on this ground as you feel it impacts on your fundamental rights andfreedoms. You also have the right to object where we are processing your personal data fordirect marketing purposes. In some cases, we may demonstrate that we have compellinglegitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us tosuspend the processing of your personal data in the following scenarios: (a) if you want us toestablish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us toerase it; (c) where you need us to hold the data even if we no longer require it as you need it toestablish, exercise or defend legal claims; or (d) you have objected to our use of your data butwe need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or athird party you have chosen, your personal data in a structured, commonly used, machinereadable format. Note that this right only applies to automated information which you initiallyprovided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrawyour consent. If you withdraw your consent, we may not be able to provide certain products orservices to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact the Norse GroupDPO (see section 1 above for contact details)No fee usually requiredYou will not have to pay a fee to access your personal data (or to exercise any of the otherrights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitiveor excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from youWe may need to request specific information from you to help us confirm your identity and ensureyour right to access your personal data (or to exercise any of your other rights). This is a securitymeasure to ensure that personal data is not disclosed to any person who has no right to receiveit. We may also contact you to ask you for further information in relation to your request to speedup our response. Time limit to respondWe tries to respond to all legitimate requests within one month. Occasionally it may take us longerthan a month if your request is particularly complex or you have made a number of requests. Inthis case, we will notify you and keep you updated.

9. GlossaryLawful BasisLegitimate Interest means the interest of our business in conducting and managing ourbusiness to enable us to give you the best service/product and the best and most secureexperience. We make sure we consider and balance any potential impact on you (both positiveand negative) and your rights before we process your personal data for our legitimate interests.We do not use your personal data for activities where our interests are overridden by the impacton you (unless we have your consent or are otherwise required or permitted to by law). You canobtain further information about how we assess our legitimate interests against any potentialimpact on you in respect of specific activities by contacting usPerformance of Contract means processing your data where it is necessary for theperformance of a contract to which you are a party or to take steps at your request beforeentering into such a contract.Comply with a legal or regulatory obligation means processing your personal data where it isnecessary for compliance with a legal or regulatory obligation that we are subject to.Third PartiesInternal Third PartiesOther companies in the Norse Group and who are based in the UK.External Third Partiesï‚· Service providers and sub-contractors based in the UK who provide various goods andservices to the Norse Group as part of our supply chain.ï‚· Professional advisers including lawyers, bankers, auditors and insurers based in the UK whosupport our business through the provision of consultancy, banking, legal, insurance andaccounting services.ï‚· HM Revenue & Customs, regulators and other authorities based in the United Kingdom whomay require reporting of processing activities in certain circumstances.