Privacy is very important for Smart Cognition. All users of digital solutions and services provided by us can trust that we safeguard privacy and are open about how private information is processed. This statement describes what private information we process, how we use it and how we protect it.

Our Services

We provide a digital platform for sharing of customised information from a service provider (eg municipality, voluntary organisation or association) to persons who participate in or are interested in the service offering and who need customisation of the information. The need can e.g. be caused by disability or foreign language.

Private Information Processed

For definition of what is private information, see Norwegian Data Protection Authority website.

Information we Receive Directly from you

In order for you to use our services, we must have information about you. Some of the information is mandatory and necessary for the services to work, other information is voluntary. We process the following private information:

• User name
• Password
• Home municipality
• Preferred language
• Preferred information level: Symbols only, easy-to-read text, full text
• Leisure activities that you are contact person for
• Leisure activities that you are interested in

The information above is mandatory. In addition, the following information is optional:

• Profile photo
• First and last name
• Mobile phone number
• Email address

Information about Usage

We collect information about the use of our services. This information can be categorised as usage information, location information and other log information, respectively.

Usage information is which services are used, which queries (search / filter) are made and the results of these. Eg. which special leisure activities for people with disabilities take place in a municipality on a particular day. Usage information is stored anonymously.

Location information is information about your location. This requires you to give our services access to the location service on the devices you use. Location information is only used for queries, e.g. to find nearby leisure facilities, and is not stored.

Other log information is about the number of active users, the number of new users, error reports, etc. This information is also anonymised and collected using analysis tools like e.g. Crashlytics.

Purpose of Treatment of Private Information

The mandatory information that we receive directly from you is required for the solutions to function properly - providing individually tailored information and communication capabilities. Personalised content provides a better user experience. Localisation information is used to view nearby activities.

We use the information on use to analyse, maintain and further develop our services.

Sharing Private Information

We do not currently need to share your private information with other users of our services, even with the public. If this becomes relevant in the future, we will make sure that your private information is not used for any purpose other than what is agreed.

Insight

All private information we handle is available to you in the service you use. Alternatively, you can contact us, and we will compile and send you the information we have about you. See contact information below.

Correcting Private Information

You can by yourself correct information about home municipality, preferred language and level of information and which leisure activities you participate in or are interested in.

In order to correct information about you as a contact person for a service, you must contact the organiser that is responsible for the service or event for which you are responsible. Alternatively, you can contact us, see contact information below.

Deleting Private Information

You can by yourself at any time delete your user account and all associated private information, as described in "Private Information Processed."

If you participate in photos that are available in our services and you do not want to be available, you must contact the organiser that is responsible for the service where the photo is used and ask them to replace the photo with another photo. Alternatively, you can contact us, see contact information below.

How Long do we Store Private Information?

Private information we have about you is stored for 6 months after you last used our services. Twice a year we check inactive users, and all private information about users who have not used the services over the last 6 months is automatically deleted.

Security

We take security very seriously. Our services run in the Microsoft Azure cloud environment, and Azure meets the requirements of the GDPR. All communication between app and cloud services is via https, and all passwords are encrypted using secure algorithms so that they cannot be read or exploited by unauthorised persons.

Content Created by Users

Our services are largely based on user-created content, eg. text and images. We do not allow any kind of content that violates the guidelines given by the Norwegian Data Protection Authority, Google or Apple. Violation of the rules causes the content to be removed without prior notice and may lead to exclusion.

If you find content in our services that you find offensive or inappropriate, please email to mail@smartcognitionas.com explaining what you found and why it should be removed.

Norwegian Data Protection Authority on Photo Usage

The Norwegian Data Protection Authority distinguishes between portrait images, where the person (s) is the main motive for the image and situation images, where the situation or activity being performed is the actual motive in the image. Before using portrait image, consent from all persons depicted must always be obtained. The use of situation images does not require consent, as long as the images are harmless and in no way offensive to those depicted. Just who's in the image is subordinate.

In some cases, it may be difficult to determine whether an image is a portrait image or a situational image or whether the situation is offensive. At the same time, the use of situation images, where the person himself or the person's family, friends or other known persons contributes, is essential for the user experience of our services.

We encourage the users of our services to follow the Noreegian Data Protection Authority's guidelines. As a general rule, only group images should be used, taken at some distance. In case of doubt one should always obtain consent or avoid using such images.

What is written here about images also applies to the use of movie / video.

Contact Smart Cognition

Contact us in one of the following ways:

• email: mail@smartcognitionas.com
• Phone: +47 957 23 636
• Postal address: Frøyas vei 18, 1782 Halden, Norway