Privacy Policy

Privacy Policy

FutureOn provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use and disclosure of personally identifiable information received from users of this website, located at https://futureon.com (“Site”) or by one of our SaaS services such as FieldTwin.

By using our Site/Service you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing” means using information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information. The Data Controller of personal data obtained or otherwise processed through our Site/Service is FutureOn AS, Norwegian business number 916 735 472, address: Universitetsgata 2, 0164 Oslo, Norway, email: info@FutureOn.com.

If you are using our Software as a Service product such as FieldTwin, please see the legal provisions in the commercial agreement.

Information Collection and Use
Our primary goals in collecting personally identifiable information are to provide you with the product and services made available through the Site, including, but not limited, to the Service, to communicate with you, and to manage your registered user account, if you have one. The legal basis for the processing is our legitimate interest in being able to communicate with our customers and fulfilling our obligations, cf. GDPR art. 6 nr. 1 f). Personal data will be stored only for as long as necessary for the purpose for which the data was collected. The personal data you have registered will be deleted if you delete your user account.

Information Collected Upon Registration
If you desire to have access to certain restricted sections of the Site, you will be required to become a registered user, and to submit certain personally identifiable information to FutureOn. This happens in a number of instances, such as when you sign up for the Service, or if you desire to receive marketing materials and information. Personally identifiable information that we may collect in such instances may include your IP address, full user name, password, email address, city, time zone, telephone number, and other information that you decide to provide us with.

Use of Contact Information
In addition, you may choose to let us use your contact information to market to you, and provide you with information about, our products and services, including but not limited to our Service. If you decide at any time that you no longer wish to receive such information or communications from us, please un-follow us, or follow the unsubscribe instructions provided in any of the communications.

Log Data
When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, the web-pages you visit, the search terms you use, and any advertisements on which you click. For most users accessing the Internet from an Internet service provider the IP address will be different every time you log on. We use Log Data to monitor the use of the Site and of our Service, and for the Site’s technical administration. We do not associate your IP address with any other personally identifiable information to identify you personally, except in case of violation of the Terms of Service.

Cookies
Like many websites, we also use “cookie” technology to collect additional website usage data and to improve the Site and our service. A cookie is a small data file that we transfer to your computer’s hard disk. We do not use cookies to collect personally identifiable information. FutureOn may use both session cookies and persistent cookies to better understand how you interact with the Site and our Service, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our services. A session cookie enables certain features of the Site and our service and is deleted from your computer when you disconnect from or leave the Site. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

Information Sharing and Disclosure

Service Providers
We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, billing, customer relationship, database storage and management, and direct marketing campaigns. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

Compliance with Laws and Law Enforcement
FutureOn cooperates with government and law enforcement officials to enforce and comply with the law. We may disclose information if necessary to respond to claims or legal process, the safety of the public or to comply with the law.

You have the right at any time to contact the appropriate authority in your country (in Norway: Datatilsynet) to address any processing of your personal data that you believe to be unlawful.

Business Transfers
FutureOn may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

Changing or Deleting Information
You have the right to require access to, correction or deletion of personal data processed by FutureOn. You may also have the right to demand limitations of the processing, objection to processing and claim the right to data portability. If you are a registered user of the Site, you may access and update or correct the information you provided to us by e-mailing us at info@FutureOn.com.

Security
FutureOn is very concerned about safeguarding the confidentiality of your personally identifiable information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Links to Other Websites
Our Site contains links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Towards Children
The Site is not directed to persons under 13. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at info@futureon.com. We do not knowingly collect personally identifiable information from children under 13. If we become aware that a child under 13 has provided us with personal identifiable Information, we will delete such information from our files.

Changes to this Policy
This Privacy Policy may be updated from time to time for any reason; each version will apply to information collected while it was in place. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Site. You are advised to consult this Privacy Policy regularly for any changes.

GDPR Rights of Data Subjects

In accordance with the General Data Protection Regulation (GDPR), you as a data subject have the following rights:

The right to be informed about the collection and use of your personal data.
The right to access your personal data.
The right to rectification if your personal data is inaccurate or incomplete, see the section Changing or Deleting Information above.
The right to erasure of your personal data in certain circumstances, most significantly: (i) when the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, (ii) for processing based on consent: you withdraw the consent and there is no other legal ground for processing, or (iii) you object to the processing and there are no overriding legitimate grounds for processing, cf. GDPR Art. 17.
The right to restrict processing when certain conditions apply, cf. GDPR Art. 18.
The right to data portability, allowing you to obtain and reuse your data for your own purposes across different services, cf. GDPR Art. 20.
The right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority, direct marketing, and processing for purposes of scientific/historical research and statistics, cf. GDPR Art. 21.
Rights in relation to automated decision-making and profiling, cf. GDPR Art. 22.

To exercise any of these rights, please contact our Data Protection Officer (DPO):

Data Protection Officer (DPO)

Contact Details Name: Elizabeth Russell

Email: dpo@futureon.com

FutureOn as Data Processor

Please note that this Privacy Policy addresses the collection and processing of personal data for FutureOn’s own purposes, hence where FutureOn is the Data Controller. In the course of FutureOn’s business FutureOn also processes personal data in the capacity as Data Processor for its customers. In such cases FutureOn’s processing is governed by a Data Processor Agreement that sets out the he subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of FutureOn as Data Processor and the customer as Data Controller.

Data Protection Addendum

This Data Protection Addendum (“Addendum“) between FutureOn AS Inc. (“FutureOn AS”) and the Customer (as defined in the Agreement) forms part of the FutureOn AS Inc. Terms of Service set forth at https://www.futureon.com/terms-of-use or such other written or electronic agreement incorporating this Addendum, in each case governing Customer’s access to and use of the Services (the “Agreement”).

Customer enters into this Addendum on behalf of itself and any Affiliates authorized to use the Services under the Agreement and who have not entered into a separate contractual arrangement with FutureOn AS. For the purposes of this Addendum only, and except where otherwise indicated, references to “Customer” shall include Customer and such Affiliates.
The Parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Agreement.

1. Definitions

1. In this Addendum, the following terms shall have the meanings set out below and cognate terms shall be construed accordingly:

1. “Affiliate“ means an entity that owns or controls, is owned or controlled by or is or under common control or ownership with either Customer or FutureOn AS (as the context allows), where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise;

1. “Customer Personal Data“ means any Personal Data provided by or made available by Customer to FutureOn AS or collected by FutureOn AS on behalf of Customer which is Processed by FutureOn AS to perform the Services;

1. “Controller to Processor Contractual Clauses“ means the standard contractual clauses for cross-border transfers published by applicable Data Protection Laws or any similar such clauses adopted by a data protection regulator relating to Personal Data transfers to Third Countries, including without limitation any successor clauses thereto;

1. “Data Protection Laws“ means any local, state, or national law regarding the processing of Personal Data applicable to FutureOn AS in the jurisdictions in which the Services are provided to Customer, including, without limitation, privacy, security, and data protection law;

1. “Services“ means the services to be supplied by FutureOn AS to Customer or Customer’s Affiliates pursuant to the Agreement; and

1. “Third Country” means countries that, where required by applicable Data Protection Laws, have not received an adequacy decision from an applicable authority relating to cross-border data transfers of Personal Data, including regulators such as the European Commission, UK ICO, or Swiss FDPIC.

1. The terms “Business”, “Business Purpose”, “commercial purpose”, “Contractor”, “Controller“, “Data Subject“, “Personal Data“, “Personal Data Breach“, “Process“, “Processor“, “Sell”, “Service Provider”, “Share”, “Subprocessor”, “Supervisory Authority“, and “Third Party” have the same meanings as described in applicable Data Protection Laws and cognate terms shall be construed accordingly.

1. Capitalized terms not otherwise defined in this Addendum shall have the meanings ascribed to them in the Agreement.

2. Roles of the Parties

The Parties acknowledge and agree that with regard to the Processing of Customer Personal Data, and as more fully described in Annex 1 hereto, Customer acts as a Business or Controller, and FutureOn AS acts as a Service Provider or Processor. This Addendum shall apply solely to the Processing of Customer Personal Data by FutureOn AS acting as a Processor, Subprocessor, or Third Party (as specified in Annex 1).

1. The Parties expressly agree that Customer shall be solely responsible for ensuring timely communications to Customer’s Affiliates or the relevant Controller(s) who receive the Services, insofar as such communications may be required or useful in light of applicable Data Protection Laws to enable Customer’s Affiliates or the relevant Controller(s) to comply with such Laws.

3. Description and Purpose of Personal Data Processing

1. In Annex 1 to this Addendum, the Parties have mutually set out their understanding of the subject matter and details of the Processing of the Customer Personal Data to be Processed by FutureOn AS pursuant to this Addendum. The Parties may make reasonable amendments to Annex 1 on mutual written agreement and as reasonably necessary to meet those requirements. Annex 1 does not create any obligation or rights for any Party.

1. The purpose of Processing under this Addendum is the provision of the Services pursuant to the Agreement and any Order Form(s).

4. Data Processing Terms

1. Customer shall comply with all applicable Data Protection Laws in connection with the performance of this Addendum and the Processing of Customer Personal Data. In connection with its access to and use of the Services, Customer shall Process Customer Personal Data within such Services and provide FutureOn AS with instructions in accordance with applicable Data Protection Laws. As between the Parties, Customer shall be solely responsible for compliance with applicable Data Protection Laws regarding the collection of and transfer to FutureOn AS of Customer Personal Data. Customer agrees not to provide FutureOn AS with any data concerning a natural person’s health, religion or any special categories of data as per applicable laws.

1. FutureOn AS shall comply with all applicable Data Protection Laws in the Processing of Customer Personal Data and FutureOn AS shall:

1. 1. Process the Customer Personal Data for the purposes of the Agreement and for the specific purposes in each case as set out in Annex 1 to this Addendum and otherwise solely on the documented instructions of Customer, for the purposes of providing the Services and as otherwise necessary to perform its obligations under the Agreement. The Agreement, this Addendum, and Customer’s use of the Services’ features and functionality are Customer’s written instructions to FutureOn AS in relation to Processing Customer Personal Data, including as follows:

1. 1. 1. FutureOn AS shall use, retain, disclose, or otherwise Process Customer Personal Data only on behalf of Customer and for the specific business purpose of providing the Services and in accordance with Customer’s instructions, including as described in the Agreement. FutureOn AS shall not Sell or Share Customer Personal Data, nor use, retain, disclose, or otherwise Process Customer Personal Data outside of its business relationship with Customer or for any other purpose (including FutureOn AS’s commercial purpose) except as required or permitted by law. FutureOn AS shall immediately inform Customer (a) if FutureOn AS determines that it is no longer able to meet its obligations under Data Protection Laws or (b) if, in FutureOn AS’s opinion, an instruction infringes applicable Data Protection Laws. Customer reserves the right to take reasonable and appropriate steps to ensure Graphite’s Processing of Customer Personal Data is consistent with Customer’s obligations under Data Protection Law and discontinue and remediate unauthorized use of Customer Personal Data;

1. FutureOn AS shall have rights to process Customer Personal Data solely (i) to the extent necessary to (a) perform the Business Purposes and its obligations under the Agreement; (b) operate, manage, test, maintain and enhance the Services including as part of its business operations; (c) to disclose aggregate statistics about the Services in a manner that prevents individual identification or re-identification of Customer Personal Data, including without limitation any individual device or individual person; and/or (d) protect the Services from a threat to the Services or Customer Personal Data; or (ii) if required by court order of a court or authorized governmental agency, provided that prior notice first be given to Customer; (iii) as otherwise expressly authorized by Customer;

1. 1. 1. FutureOn AS will not combine Customer Personal Data which FutureOn AS Processes on Customer’s behalf, with Personal Data which it receives from or on behalf of another person or persons, or collects from its own interaction with individual, provided that Graphite may combine personal information to perform any Business Purpose permitted or required under the Agreement to perform the Services;

1. 1. implement and maintain measures designed to ensure that FutureOn AS personnel authorized to process the Customer Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality unless disclosure is required by law or professional regulations;

1. 1. implement and maintain the technical and organizational measures set out in the Agreement, and, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, implement and maintain any further commercially reasonable and appropriate administrative, technical, and organizational measures designed to ensure a level of security appropriate to the risk of the Processing of Customer Personal Data, and specifically:

1. 1. 1. pseudonymization and encryption of Customer Personal Data;

1. 1. 1. ensuring ongoing confidentiality, integrity, availability and resilience of FutureOn AS’s processing systems and services that process Customer Personal Data;

1. 1. 1. restoring availability and access to Customer Personal Data in a timely manner in the event of a physical or technical incident; and

1. 1. 1. regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of Customer Personal Data.

1. 1. Customer hereby agrees that FutureOn AS is generally authorized to engage and appoint Sub-processors, and specifically the Sub-processors listed in Annex 2 hereto, subject to FutureOn AS’s:

1. 1. 1. notifying Customer at least thirty (30) calendar days in advance oof any intended changes or additions to its Sub-processors listed in Annex 2 by emailing notice of the intended change to Customer;

1. 1. 1. including data protection obligations in its contract with each Sub-processor that are materially the same as those set out in this Addendum; and

1. 1. 1. remaining liable to the Customer for any failure by each Sub-processor to fulfill its obligations in relation to the Processing of the Customer Personal Data.

In relation to any notice received under section 4.2(d)(i), Customer shall have a period of 30 (thirty) days from the date of the notice to inform FutureOn AS in writing of any reasonable objection on data protection grounds to the use of that Sub-processor. The parties will then, for a period of no more than 30 (thirty) days from the date of Customer’s objection, work together in good faith to attempt to find a commercially reasonable solution for Customer which avoids the use of the objected-to Sub-processor. Where no such solution can be found, either Party may (notwithstanding anything to the contrary in the Agreement) terminate the relevant Services immediately on written notice to the other Party, without damages, penalty or indemnification whatsoever (but without prejudice to any fees incurred by Customer prior to termination);

1. to the extent legally permissible, promptly notify Customer in case of any legally binding requests (i.e., disclosures required by law, court order, or subpoena) for disclosure of Customer Personal Data by FutureOn AS. In case if it is not legally binding then Customer Personal Data would not be disclosed and FutureOn AS will notify the Customer of such request rejection. A record of all legally binding disclosure requests relating to Customer Personal Data shall be maintained.

1. to the extent legally permissible, promptly notify Customer of any communication from a Data Subject regarding the Processing of Customer Personal Data, or any other communication (including from a Supervisory Authority) relating to any obligation under the applicable Data Protection Laws in respect of the Customer Personal Data. FutureOn AS will not respond to any such request or complaint unless expressly authorized to do so by the Customer or is otherwise required to respond under applicable Data Protection Laws. Taking into account the nature of the Processing, FutureOn AS will reasonably assist Customer (or the relevant Controller) by appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of Customer’s, Customer’s Affiliates’ or the relevant Controller(s)’ obligation to respond to requests for exercising the data subject’s rights. Customer agrees to pay FutureOn AS for time and for out-of-pocket expenses incurred by FutureOn AS in connection with the performance of its obligations under this Section 4.2(e);

1. upon FutureOn AS’s becoming aware of a Personal Data Breach involving Customer Personal Data, notify Customer without undue delay, of any Personal Data Breach involving Customer Personal Data, such notice to include, to the extent reasonably available to FutureOn AS, all timely information reasonably required by Customer (or the relevant Controller) to comply with its data breach reporting obligations under the applicable Data Protection Laws. FutureOn AS shall further take all such measures and actions as are necessary to remedy or mitigate the effects of such Security Incident and shall keep Customer reasonably informed of developments concerning Customer Personal Data;

1. to the extent required by the applicable Data Protection Laws, provide reasonable assistance to Customer, Customer’s Affiliates’ or the relevant Controller(s)’ with its obligations pursuant to applicable Data Protection Laws taking into account the nature of the Processing and information available to FutureOn AS; Customer agrees to pay FutureOn AS for time and for out of pocket expenses incurred by FutureOn AS in connection with any assistance provided in connection with applicable laws;

1. cease Processing the Customer Personal Data upon the termination or expiry of the Agreement, and at option of Customer, Customer’s Affiliates or the relevant Controller(s) either return or delete (including by ensuring such data is in non-readable format) all copies of the Customer Personal Data Processed by FutureOn AS, unless (and solely to the extent and for such period as) applicable law requires FutureOn AS to retain some or all of the Customer Personal Data. Any such Customer Personal Data retained shall remain subject to the obligations of confidentiality set forth in the Agreement; and

1. FutureOn AS shall maintain the necessary records in support of demonstrating compliance with its obligations (as specified in the applicable contract) for the processing of Customer Personal Data carried out on behalf of the Customer.

1. make available to Customer all information reasonably necessary to demonstrate compliance with this Addendum and allow for and contribute to audits, including inspections, by Customer, or an independent third party auditor mandated by Customer, provided that Customer gives FutureOn AS reasonable prior notice of its intention to audit, conducts its audit during FutureOn AS’s normal business hours, and takes all reasonable measures to prevent unnecessary disruption to FutureOn AS’s operations. For the purposes of demonstrating compliance with this Addendum under this Section 4.2(i), the Parties agree that in the first instance, once per year during the term of the Agreement (except if and when required by instruction of a competent Supervisory Authority or where Customer believes a further audit is necessary due to a Personal Data Breach concerning Customer Personal Data suffered by FutureOn AS), FutureOn AS will provide to Customer responses to cybersecurity and other assessments and only where Customer cannot establish FutureOn AS’s compliance with this Addendum from FutureOn AS’s responses shall Customer request to inspect FutureOn AS’s processing operations. Customer agrees to pay FutureOn AS for time and for out-of-pocket expenses incurred by FutureOn AS in connection with assistance provided in connection with such audits, responses to cybersecurity and other assessments.

5. Restricted Transfers

1. The parties agree that when the transfer of Customer Personal Data from Customer and/or any of its Affiliates (as exporter) to FutureOn AS (as importer) is a Restricted Transfer and relevant Area Law applies, the transfer shall be subject to the appropriate Controller to Processor Contractual Clauses.

6. Precedence

1. The provisions of this Addendum are supplemental to the provisions of the Agreement. In the event of any inconsistency between the provisions of this Addendum and the provisions of the Agreement, the provisions of this Addendum shall prevail. In the event that any provision of this Addendum and/or the Agreement contradicts, directly or indirectly, the Controller to Processor Contractual Clauses, the Controller to Processor Contractual Clauses will control.

7. Indemnity

1. To the extent permissible by law, Customer shall (a) defend FutureOn AS and its Affiliates (collectively, “Indemnified Parties”) from and against any and all claims, demands, suits, or proceedings made or brought against any of the Indemnified Parties by any third party (each, a “Claim”), and (b) indemnify and hold harmless the Indemnified Parties from and against any and all losses, damages, liabilities, fines and administrative fines, penalties, settlements, and costs and expenses of any kind (including, without limitation, reasonable legal, investigatory and consultancy fees and expenses) incurred or suffered by any of the Indemnified Parties, in each case arising from any breach by Customer of this Addendum or of its obligations under applicable Data Protection Laws. FutureOn AS may participate in the defense and/or settlement of a Claim under this Section 7.1 with counsel of its choosing at its own expense.

8. Severability

1. The Parties agree that, if any section or sub-section of this Addendum is held by any court or competent authority to be unlawful or unenforceable, it shall not invalidate or render unenforceable any other section of this Addendum.

9. Miscellaneous

1. The Addendum considers the following and follows:

1. 1. Privacy by Design and default

1. 1. Achieving security of Processing

1. 1. Notification of breaches involving Customer Personal Data to the relevant Supervisory Authority

1. 1. Notification of breaches involving Customer Personal Data to Customer

1. 1. Conducting Privacy Impact Assessment where appropriate and required by applicable Data Protection Laws.
  2. Assurance of FutureOn AS’s assistance by if prior consultations with relevant Supervisory Authorities are needed and required by applicable Data Protection Laws.

2. FutureOn AS shall comply with all statutory and regulatory requirements, ISO 27001:2013, ISO 27701:2019, ISO 27701:2022 and DPDPA requirements.

3. In the event a Data Subject wishes to exercise its data subject rights under applicable Data Protection Law, including, but not limited to, a data subject’s right of access, correction and/or erasure of its Personal Data in FutureOn AS’s control, the Data Subjects can submit such request done by contacting FutureOn AS’s Data Protection Officer (DPO) below. Also, for raising concerns and/or any complaints related to the Customer Personal Data that can be done by contacting the Data Protection Officer below:

Name: Lewis Carhart
Email ID: dpo@futureon.com

4. There are no Temporary files getting generated during processing.

Data Protection Addendum

This Annex includes certain details of the Processing of Customer Personal Data by FutureOn AS in connection with the Services. And a list of our subprocessors can be found here Subprocessors

List of Parties

Data Exporter

Name:	Customer (as defined in the Agreement)
Address:	As set forth in the relevant Order Form.
Contact person’s name, position and contact details:	As set forth in the relevant Order Form.
Activities relevant to the data transferred under these Clauses:	Recipient of the Services provided by FutureOn AS in accordance with the Agreement.
Signature and date:	Signature and date are set out in the Agreement.
Role (controller/processor):	Controller

Data Importer

Name:	FutureOn AS
Address: Rebel, Universitetsgata 2, 0164 Oslo, Norway.
Contact person’s name, position and contact details:	Elizabeth Russell, Governance & Compliance Manager, elizabeth@futureon.com
Activities relevant to the data transferred under these Clauses:	Provision of the Services to the Customer in accordance with the Agreement.
Signature and date:	Signature and date are set out in the Agreement.
Role (controller/processor):	Processor

2. Competent Supervisory Authority

Identify the competent supervisory authority/ies in accordance with Applicable Data Protection Clause

Data Protection Authority

3. Processing Information

Categories of data subjects whose personal data is transferred	Customer’s authorized users of the Services
Categories of personal data transferred	Processed automatically by the Services: Names email IDs Processed where and to the extent provided by Customer or its authorized users in connection with audit services provided by FutureOn AS: address date of birth past employment details
Sensitive personal data transferred	None
Frequency of the transfer	Continuous
Nature of the processing	The nature of the processing is more fully described in the Agreement and accompanying order forms but will include the following basic processing activities: The provision of Services to Customer. In order to provide people data, FutureOn AS receives identifying Customer Personal Data to permit FutureOn AS to query, cleanse, standardize, enrich, (when required) send to additional data to feed providers, and to store the query information. The purpose of the transfer is to facilitate the performance of the Services more fully described in the Agreement and accompanying order forms.
Purpose of the data transfer and further processing
For processing involving California consumers, please select the Business Purpose(s) for Processing Personal Data	☐ N/A  ☐ Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards  ☒ Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes  ☒ Debugging to identify and repair errors that impair existing intended functionality.  ☐ Short-term, transient use, including, but not limited to, Non personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business  ☒ Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.  ☐ Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.  ☒ Undertaking internal research for technological development and demonstration.  ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.  ☒ To retain and employ another service provider or contractor as a subcontractor where the subcontractor meets the requirements for a service provider or contractor under CCPA.  ☒ To build or improve the quality of the services it is providing to the business even if this Business Purpose is not specified in the written contract required by CCPA provided that Service Provider does not use the Customer Personal Data to perform Services on behalf of another person.  ☒ To prevent, detect, or investigate data security incidents or protect against malicious, deceptive, fraudulent, or illegal activity, even if this Business Purpose is not specified in the written contract.
Period for which the personal data will be retained or criteria used to determine that period	The period for which the Customer Personal Data will be retained is more fully described in the Agreement, Addendum, and accompanying order forms.
Subprocessor transfers – subject matter, nature, and duration of processing	The subject matter, nature, and duration of the Processing more fully described in the Agreement, Addendum, and accompanying order forms.

4. Technical and Organizational Security Measures

1. Security Management System.

1. 1. Organization. FutureOn AS designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
  2. Policies. Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data.  These policies are updated at least once annually.
  3. Assessments. FutureOn AS engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
  4. Risk Treatment. FutureOn AS maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.
  5. Vendor Management. FutureOn AS maintains an effective vendor management program
  6. Incident Management. FutureOn AS reviews security incidents regularly, including effective determination of root cause and corrective action.
  7. Standards. FutureOn AS operates an information security management system that complies with the requirements of ISO/IEC 27001:2022 standard.

1. Personnel Security.

1. 1. FutureOn AS personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. FutureOn AS conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law, customary practice and statutory regulations.

1. Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel must acknowledge receipt of, and compliance with, FutureOn AS’s confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). FutureOn AS’s personnel will not process Customer Personal Data without authorization.

Access Controls

1. Access Management. FutureOn AS maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted periodically to ensure that only those personnel with access to Customer Personal Data still require it.
2. Infrastructure Security Personnel. FutureOn AS has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. FutureOn AS’s infrastructure security personnel are responsible for the ongoing monitoring of FutureOn AS’s security infrastructure, the review of the Services, and for responding to security incidents.
3. Access Control and Privilege Management. FutureOn AS’s and Customer’s administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services.
4. Internal Data Access Processes and Policies – Access Policy. FutureOn AS’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. FutureOn AS designs its systems to only allow authorized persons to access data they are authorized to access based on principles of “least privileged” and “need to know”, and to prevent others who should not have access from obtaining access.  FutureOn AS requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; a need-to-know basis; and must be in accordance with FutureOn AS’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity.
Data Center and Network Security
1. Data Centers.

1. 1. Infrastructure. FutureOn AS has AWS, GCP and Azure as its data centers.

1. 1. Resiliency. Multi Availability Zones are enabled on AWS, GCP and Azure and FutureOn AS conducts Backup Restoration Testing on regular basis to ensure resiliency.

1. 1. Server Operating Systems. FutureOn AS’s servers are customized for the application environment and the servers have been hardened for the security of the Services. FutureOn AS employs a code review process to increase the security of the code used to provide the Services and enhance the security products in production environments.

1. 1. Disaster Recovery. FutureOn AS replicates data over multiple systems to help to protect against accidental destruction or loss. FutureOn AS has designed and regularly plans and tests its disaster recovery programs.

1. 1. Security Logs. FutureOn AS’s systems have logging enabled to their respective system log facility in order to support the security audits, and monitor and detect actual and attempted attacks on, or intrusions into, FutureOn AS’s systems.

1. 1. Vulnerability Management. FutureOn AS performs regular vulnerability scans on all infrastructure components of its production and development environment.  Vulnerabilities are remediated on a risk basis, with Critical, High and Medium security patches for all components installed as soon as commercially possible.
2. Networks and Transmission.

1. 1. Data Transmission. Transmissions on production environment are transmitted via Internet standard protocols.

1. 1. External Attack Surface. AWS, GCP, Azure Security Group which is equivalent to virtual firewall is in place for Production environment on AWS, GCP, Azure.

1. 1. Incident Response. FutureOn AS maintains incident management policies and procedures, including detailed security incident escalation procedures. FutureOn AS monitors a variety of communication channels for security incidents, and FutureOn AS’s security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.

1. 1. Encryption Technologies. FutureOn AS makes HTTPS encryption (also referred to as SSL or TLS) available for data in transit.
2. Data Storage, Isolation, Authentication, and Destruction. FutureOn AS stores data in a multi-tenant environment on AWS, GCP, and Azure servers. Data, the Services database and file system architecture are replicated between multiple availability zones on AWS, GCP, Azure. FutureOn AS logically isolates the data of different customers. A central authentication system is used across all Services to increase uniform security of data. FutureOn AS ensures secure disposal of Client Data through the use of a series of data destruction processes.

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