Privacy Policy

Last updated: 13.09.2024

1. Introduction

This Privacy Policy for Inspiring® explains how personal data is processed by Euron Connect AS (“Euron Connect“, “we” or “us”) as the Controller, which is a subsidiary of Euron Venture Group AS.

\This privacy policy applies to processing of personal data when you as the data subject visit our website inspiring.no and when you use. Our products, like the Inspiring®, that enables you to track your lifestyle choices and the quality of your sleep through our Inspiring® or other physical device (“Inspiring® Device“) and the Inspiring® mobile application app (“Inspiring® App“). 

2. Why do we process your personal data?

We explain the categories of personal data we collect and process, as well as the reasons we do so, such as to provide you with services when you visit our website, make purchases on our website, and use your Inspiring® Device and Inspiring® App. You will also find information on our legal basis for processing your data, and our data sources.

Euron Connect collects and processes the personal data of Inspiring® Device & Inspiring® App Users (“Users“) only for the following purposes:

  • To provide Inspiring® services

We process personal data to provide Inspiring® services and app features, such as to provide you with daily insights about your readiness and sleep.

  • To provide customer service

We process personal data for the purpose of providing customer service and managing our customer communication. If you contact our support with questions regarding your app data, we may use the provided information to answer your questions and for solving any issues you may have.

  • To develop our products and services

We process data regarding your use of the Inspiring® and platform to improve our services and features, such as in the Inspiring® App. When possible, we will do this using only pseudonymized, aggregated, or non-personally identifiable data.

  • To market our products and services

We process marketing-related data to provide online advertising and Euron Connect marketing communications. For example, as explained more fully in our Cookie Policy, we use cookies on our website for different purposes such as strictly necessary cookies, marketing cookies in order to create targeted audiences for online advertisement, functional cookies to improve your experience of the website and statistical cookies. You may provide consent for each purpose other than strictly necessary cookies, and you can always withdraw a given consent for such purpose. We will only send you our newsletter if you have requested it.

  • To enable third party integrations

We process data to provide Users who request that we share their data with certain third parties, such as research partners. This is only done with your express consent.

  • To comply with statutory obligations

In certain cases, we must process certain data when it is required by applicable laws and regulations. Such statutory obligations are related, for example, to accounting and tax requirements, legal claims, or other legal purposes.

3. Legal basis for processing

Data protection law in Norway as well as EU member states requires a “lawful basis” for collecting and retaining personal information from residents of the European Economic Area (“EEA“). Our lawful basis for processing your data depends on the particular processing purposes, including:

Contract: When processing personal data for the purpose of providing Inspiring® services we process it on the basis of an agreement such as Terms of use or other end user contract, which is formed when you create your account in the Inspiring® App and accept our terms and conditions in such agreements. 

By using the Inspiring® App or Inspiring® Device to provide us with access to your personal health data, you are deemed to have given your explicit consent according to GDPR Article 9 nr. 2 letter a) for us to process your personal data through our services if you use the Inspiring® App or Inspiring® Device. We must process such personal data to fulfil our contract with you as user of the Inspiring® App or Inspiring® Device.

Consent: We use consent as legal basis for different purposes such as sending you or newsletter on e-mail or using cookies other than strictly necessary cookies. In some cases, you can provide your consent to us for processing your data through your actions, such as by inserting specific health data into your notes connected to the Inspiring® Device or Inspiring® App, or by adding health related tags in the Inspiring® App.

Legitimate Interest: We process your personal data based on our legitimate interests when we process it for the purposes of marketing our products and services within the Norwegian Marketing Act, providing security improvements to prevent unauthorized use of any Inspiring® Device or Inspiring® App or by when anonymization of personal data before we use such data to improve our products and services. When choosing to use your data based on our legitimate interests, we carefully weigh our own interests against your right to privacy, in compliance with applicable law.

Legal obligation: Euron Connect must process certain information to comply with statutory obligations which may vary in each country. For example, such obligations can relate to consumer protection laws or tax laws.

4.  Data sharing and disclosure

4.1 Personal Data Sharing

Euron Connect does not sell or rent your personal information, and only shares your personal data with certain trusted service providers so that we can provide you with our services and operate our business. Whenever we share data with third-party service providers, we require that they use your information only for the purposes we’ve authorized, and for the limited reasons explained in this Privacy Policy. We also require these service providers to protect your personal information to at least the same standards that we do.

Euron Connect uses service providers for purposes such as:

  • Providing and administration of our online service platform on the website.
  • Storing our users’ data.
  • Providing customer services.
  • Managing and organizing our marketing activities. Euron Connect only shares website usage data with our advertising network partners for the purposes of analyzing and optimizing our marketing. Euron Connect does not share the Inspiring® app data with third party advertisers.
  • Analyzing information regarding the use of our online service to improve our service quality and security.

Euron Connect stores personal data primarily within the geographic region where it is collected. In cases where personal data is processed outside of the area in which it was collected, we always ensure your personal data is protected with appropriate safeguards in accordance with applicable privacy laws. We also use industry standard data protection measures to safeguard all international transfers of personal data through data protection agreements with our service providers.

We use the following data processors to provide you with the Inspiring® App and Inspiring® Device, and we have a valid data processor agreement with each data processor and has restricted data to be processed in countries within EEA:

  • AWS: Storage of data on the cloud service Amazon Web Service (data will be stored in a country within the EU/EEA, and we have chosen Sweden).
  • Colliflow AS: Storage and logistic services, including payment and transport services, of the Inspiring® Device and our online shop for products you may purchase through our website.
  • Studio X AS: Development of custom apps and platform systems such as the source code to be used in the Inspiring® App and the Inspiring® Device.
  • Link Mobility AS: The service SMS Gateway.
  • Snorre Data: Our local IT supplier.
  • Maksimer AS: Online shop and website services.

4.2 Personal Data Disclosures

We also reserve the right to disclose personal information under certain specific circumstances, including:

  • When we have your express consent to do so.
  • When it is reasonably necessary for our legitimate interests in conducting our business, such as in the event a merger, acquisition, or sale.
  • To protect Euron Connect legal rights and property.
  • To comply with the law or law enforcement.

Otherwise, your personal information is never shared with any individual or other organization.

5. Safeguarding your personal data

We have implemented an internal control system regarding processing of personal data. 

Euron Connect uses technical and organizational safeguards to keep your data safe and secure. Where appropriate, these safeguards include measures such as anonymization or pseudonymization of personal data, strict access control, and the use of encryption to protect the data we process.

We also ensure that our staff receives adequate training to ensure personal data is processed only in accordance with our internal policies, consistent with our obligations under applicable law. We also limit access to your sensitive personal data to personnel that have specifically been granted such access.

We update the Inspiring® App and the Inspiring® Device firmware regularly. We recommend that you make sure that you always have the latest app and firmware versions installed to maximize protection of your data.

6. Data Retention

The retention period for your personal data generally depends on the duration of your Inspiring® account lifecycle. Your personal data will be deleted when it is no longer needed for the purpose it was originally collected, unless we have a legal obligation to retain data for a longer period of time. For example, your measurement data regarding your sleep and readiness is stored only so long as your Inspiring® account is active.

Euron Connect AS also has legal obligations to retain certain personal data for a specific period of time, such as for tax purposes.

These required retention periods may include, for example, accounting and tax requirements, legal claims, or for any other legal purposes. Please note that obligatory retention periods for personal data vary based on the relevant law.

If you wish, you may request deletion of your Inspiring®
account by contacting privacy@inspiring.no.

7. Your rights as a data subject

Whenever Euron Connect processes your data, you have certain rights that enable you to control how your personal data is being processed. This section provides you with information about each of those rights. If you wish to exercise your rights as a data subject, please contact privacy@inspiring.no with your request to do so.

7.1 Right to access data

You have the right to know what personal data is processed about you. You may contact us to request access to the personal data we have collected about you, and we will confirm whether we are processing your data and provide you with information about the personal data we have collected and processed about you.

Please note that by using the Inspiring® App, you can easily access the sleep and readiness data that we process about you

7.2 Right to erasure

You have the right to request the deletion of your personal data in certain circumstances. We will comply with such requests unless we have a valid legal basis or legal obligation to preserve the data.

7.3 Right to rectification (of inaccurate data)

You have the right to request correction of any incorrect or incomplete personal data we have stored about you.

Please note that you can correct and update some of your basic information via the Inspiring® App.

7.4 Right to data portability

You have the right to request receipt of the personal data you have provided to us in a structured and commonly used format. The right to data portability only applies when we process your personal data for certain reasons, such as by contract or by your consent.

7.5 Right to object to processing

You have the right to object to the processing of your personal data under certain circumstances. In the event that we do not have legitimate grounds to continue processing such personal data, we will no longer process your personal data after we have received and verified your objection. You also have the right to object processing of your personal data for direct marketing purposes at any time.

7.6 Right to restrict processing

You have the right to request that we restrict processing of your personal data under certain circumstances. For example, if you contest the accuracy of your data, you can make a restriction request that we do not process your data until Euron Connect has verified the accuracy of your data.

7.7 Right to withdraw consent

If we have requested your consent to process your personal data for a specific purpose, you have the right to withdraw your consent for such processing covered by such purpose at any time. It should be noted, however, that withdrawing your consent may lead to issues or restrictions on your ability to fully utilize Inspiring® services.

Please note that you can always unsubscribe from receiving our newsletter and other marketing emails by using the ‘Unsubscribe’-link provided in the emails you receive from us.

Euron Connect strives to address your privacy concerns. If you have contacted Euron Connect about your issue and are still unhappy with our response, subject to applicable law, you may contact your local supervisory authority regarding your issue. However, we urge you to first contact us at privacy@euronconnect.no so that we can more quickly resolve your issue before escalating the issue.

7.8 Complaints

You have the right to lodge complaints with the Data Protection Authority in the country you are a citizen. As a Norwegian company we adhere to the guidelines from the Norwegian Data Protection Authority, see Contact us | Datatilsynet (Kontakt oss | Datatilsynet) We encourage you to try to find answers to your questions by contacting us before you contact any Data Protection Authority Kontakt oss | Datatilsynet.

8. MAPSDK Integration

The integration of the third-party map SDK by Inspiring® aims to provide users with the functionality to create outdoor workout route and calculate workout distance. To ensure smooth operation, we request users’ permission for both location access and background location tracking. If permission is not granted, the App will be unable to provide outdoor workout route planning and distance calculation features

8.1 Background Location Permission.

The background location permission allows the Inspiring® App to continue tracking your workout location even when running in the background This ensures the App can map your workout route and calculate distance without affecting the usage of other applications. Additionally, it optimizes battery usage by providing Inspiring®’s workout features efficiently when your phone screen is off. The Inspiring® device and App is developed with privacy by design and privacy by default. The user can enable ‘allow tracking location’ themselves, which will be considered as consent as long as the user has such permission enabled on their mobile when using the Inspiring®app.

8.2 AMAP Android Map SDK

(1) Collected Personal Information and Purposes

  • SDK Type

○ Android Map SDK

  • Types of Personal Information Collected

○ Location information (latitude, longitude, precise location, rough location)

○ Inspiring® Device information (e.g., IP address, GNSS information, WiFi status, WiFi parameters, WiFi list, SSID, BSSID, base station information, WiFi signal strength, Bluetooth information, sensor information, device signal strength, external storage directory)

○ Inspiring® Device identification information (IDFA, OAID), current app information (app name, app version)

  • Purposes of Collection

○ Collecting location information to provide user location feedback, display user locations on the map, and facilitate Inspiring® in offering workout route services based on user location.

○ Collecting device information to assist Inspiring® in providing accurate positioning, aiding in location, and supplying Inspiring® with more precise user location information.

○ Collecting device identification information to ensure accuracy and success rates in providing location services, map and search services, tracking, troubleshooting, diagnosing, and statistical services for various issues, ensuring the normal and secure operation of products and services.

(2) Inspiring® Device Permissions

  • System Version

○ Android

  • Location Permissions

○ Depending on user authorization (precise location, rough location) for providing Inspiring® with accurate or approximate user location information and offering workout route services based on the user’s location.

  • Background Location Permission

○ Used to provide the application with user location information in the background, enabling Inspiring® to offer workout route services based on the user’s location.

  • Storage Permission

○ Used to read cache information, track, troubleshoot, diagnose, and provide statistical services for problems, ensuring the secure and normal operation of products and services.

  • Permission Request Timing

○ Determined by Inspiring®, and permissions are requested when AMap services are initiated.

(3) Official Website Link

https://lbs.amap.com/

8.3 Google Android Map SDK

(1) Automatically Collected Data

  • Data

○ Metadata such as device metadata (operating system version, name, model, brand, physical specifications), Maps SDK for Android build and version information, returned result count.

○ Stack trace crash indicators, IP address, Maps SDK identifier.

  • Collection Purposes

○ Collecting request metadata to maintain and improve Google services.

○ Collecting stack trace during SDK code crashes to enhance SDK stability and improve Google services.

○ Collecting IP addresses to understand SDK usage and improve Google services.

○ Generating and collecting Maps SDK unique anonymized identifiers to measure daily active SDK users and improve Google services.

(2) Data Collected Based on Your Usage

  • Data

○ Map interaction events.

  • Collection Purposes

○ Collecting interaction data (e.g., panning and zooming the map using the Map Camera API) to enhance Google services.

(3) Official Website Link

https://mapsplatform.google.com

9. Controller contact information

Euron Connect is the data controller of user personal data processed as described in this Privacy Policy. Please find our contact details below:

Inspiring® – company name: Euron Connect AS
Address: Ensjøveien 18, 0661 Oslo, Norway
Data Protection Officer: privacy@inspiring.no 

10. Changes to this Privacy Policy

This Privacy Policy is effective as of September 16, 2024. We reserve the right to update this Privacy Policy from time to time at our sole discretion, but if we do, we’ll let you know about any material changes either by notifying you on the website or by sending you an email or push notification. If you keep using Inspiring® services after a change, your continued use means that you accept any such changes.