This Privacy Policy describes the Personal Information (defined below) we collect, use, store, disclose, and otherwise process through our website and app, collectively referred to as the “Service”. References to “we,” “us,” and “our” refer to Variable AS.

1. EXCLUSIONS

This Privacy Policy does NOT apply to Personal Information that is collected by any third party through our Service (except as otherwise provided below). For example, the Service contain links to third party websites that collect and use your Personal Information in accordance with their own privacy policies, which you should read and agree to their terms. We have no control over, and are not responsible for, the privacy practices or content of these third parties.

2. PERSONAL INFORMATION COLLECTED

We collect a limited set of data to facilitate use of our Service, including Personal Information. “Personal Information” means information that relates to an identified or identifiable natural person. The categories of Personal Information we collect are listed below. Certain types of Personal Information may fall under more than one category.

Identifiers: We collect your first and last name, email address, Internet Protocol address, software, hardware, and device identifiers, and online identifiers.

Internet or other similar network activity: We collect information about your interaction with the Service (e.g., your internet service provider, referral pages, the content you view on the Service, the dates you access that content, and the length of time you view that content).

Geolocation data: We collect your location based on your IP address.

We may also collect information that does not generally identify you but may become associated with your account. We may use non personal information for any permissible business purpose under applicable law.

3. SOURCES OF PERSONAL INFORMATION

Personal Information that is collected directly from you

We collect Personal Information when you provide it to us directly. For example:

• When you create or update your account, we collect your name, email address, profile picture, and role/title.

• When you register or login into the Service using certain third party social media platforms, such as Google (each, an “Authentication Service”), we may collect your first name, last name, profile picture, and email address.

• When you contact us or report a problem with the Service, we may collect records and copies of your correspondence.

• When you respond to a survey or questionnaire, we may collect the information provided.

Personal Information that is collected by automated means

We may collect Personal Information automatically as you use our Service. For example, we may collect Personal Information as you browse our Site, such as the time you visited our Site and what pages you visited. For more information about our use of cookies and similar technologies and certain choices we offer you with respect to them, please see Section 4 below.

4. COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small data file identifiers that are transferred to your computer or mobile web browser that allow us and third parties to recognize your browser or mobile device and transfer information about you and your use of our Service in order to improve your experience of the Services.

Our cookies: We do not use first-party cookies in our service.

Third Party Cookies: We do use analytics services that make use of cookies. This Privacy Policy applies does not apply to the use of cookies or similar technologies by third parties.

5. PURPOSES OF COLLECTION

To provide or improve the Service: We may use your Personal Information to process your requests to access the Service and to generally provide and improve the Service.

To administer the Service: We may use your Personal Information for any lawful business purpose in connection with administering the Service. For example, if you reach out to us with a customer service inquiry, we may use your Personal Information to respond to you or to troubleshoot an issue you reported having with the Service.

6. YOUR PRIVACY RIGHTS

Depending upon your location and in accordance with applicable laws, you may have the right to:

Access personal information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party.

• Request Correction of your personal information where it is inaccurate or incomplete.

• Request Deletion of your personal information, subject to certain exceptions prescribed by law.

• Request Restriction or Object to Processing of your personal information.

• Not be Discriminated Against by us for exercising your privacy rights.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to submit your request via your account.

7. Data Retention

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8. Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

Contact us:

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

Variable AS
Osterhaus' gate 16B
0183 Oslo
Norway

hello@variable.co

Last updated: 18 January 2023