1. Introduction
This privacy policy describes how Game Addiction Norway collects, uses, stores and protects personal information.
Personal data means any information that can be directly or indirectly linked to an identifiable individual. We process personal data both electronically and on paper. The processing is in accordance with applicable data protection legislation, including the Personal Data Act and the EU General Data Protection Regulation (GDPR).
The statement applies to all processing of personal data in Game Addiction Norway, including services such as helplines, chat, self-help groups, courses, websites and associated digital solutions.
2. Data controller and contact information
Gambling Addiction Norway is the data controller for the company's processing of personal data.
The overall legal responsibility rests with the general manager:
Managing Director : Lill-Tove Bergmo
Organization : Gambling Addiction Norway
Organization number : 986 595 805
Postal address : Strandveien 10, 9060 Lyngseidet
E-mail : post@spillpendendik.no
Telephone : 477 00 200
Inquiries regarding privacy, access, correction or deletion can be directed to the contact information above.
3. What personal data we process
3.1 General information about users, members and contacts
Providing us with personal information is voluntary. In order for us to be able to offer certain services, such as participation in groups or follow-up over time, it is still necessary for us to have certain information, such as your name and contact information. If you choose not to provide such information, it may limit the services we can offer you.
For people who have contact with Gambling Addiction Norway, we may process the following information, among other things:
- name
- address
- phone number
- email address
- date of birth
- Notes about contact and call history (only what is necessary for follow-up) are encrypted and are not used for marketing or other data collection.
3.2 The helpline
When using the helpline, the following information can be recorded:
- sex
- age
- county
- topic in inquiries
- whether the inquiry is for the first time or a return enquiry
- time and duration of calls
- notes about call history and follow-up
- Notes may contain information that you choose to share, for example about gambling addiction, other health, finances and family situation.
3.3 Chat services
When using chat services, the following information may be processed:
- sex
- age
- county
- topic in inquiries
- dialogue content in chat
- IP address
- email address
The IP address is still stored to ensure security and our statutory duty to prevent danger to life and health.
3.4 Participants in groups and self-help groups
For participants in groups and self-help groups, we can treat:
- sex
- age
- county
- topic in inquiries and follow-up
- email address (optional, for contact and practical information)
IP address and technical information if the group is conducted digitally
3.5 Special categories and sensitive information
When you contact us, information may emerge that is considered special categories of personal data (sensitive information), for example:
- information about physical and mental health, including gambling addiction and any other addiction problems
- information about financial problems
- information about family situation and social circumstances
Such information is only recorded to the extent that you choose to share it, and we limit the recording to what is necessary to provide you with help, support and follow-up.
4. Purpose and legal basis
4.1 Purpose of the processing
We process personal data in order to:
- provide help, support, advice and follow-up to people who contact us
- manage and follow up participation in groups, courses and other offers
- keep in touch with people who have made contact, where this is desired and necessary
- develop, improve and quality assure our services and offerings
- prepare anonymized statistics and reports, and contribute to professional development and research
- ensure security, prevent and handle misuse of services
- fulfill statutory obligations, including the duty to prevent serious criminal acts and danger to life and health
4.2 Legal basis for processing personal data
The processing of personal data takes place on one or more of the following legal grounds:
Consent: When you have expressly consented to processing for one or more specific purposes, such as receiving information by email, or when you voluntarily share sensitive information about your own situation.
Agreement: When the processing is necessary to provide and administer services you have requested, such as follow-up via helpline, chat or participation in groups.
Legal obligation: When we are required to process or disclose information pursuant to law, for example, the obligation to prevent serious criminal acts and danger to life and health.
Legitimate interest: When the processing is necessary for purposes related to the operation, development and security of our services, and this interest outweighs the disadvantages for your privacy. This applies in particular to anonymized or severely limited use of information for statistics, reporting and quality work.
For the processing of special categories of personal data (sensitive information), we rely, among other things, on your express consent, and in situations involving a risk to life and health, on rules regarding the protection of vital interests and the duty to prevent.
5. How we collect personal data
We process personal data such as:
- you provide when contacting us, for example via helpline, chat, email, telephone, forms, groups or other services
- appears in call logs and notes from contact with our employees or volunteers
- is automatically recorded when using our digital services, such as IP address and technical information when using the website and chat
We do not collect more personal information than is necessary for the purposes described in this statement.
6. Cookies and analytics tools
Gambling Addiction Norway uses the analysis tool Piwik PRO to collect statistics about website usage. The purpose is to understand how the website is used so that we can improve content and user experience.
Piwik PRO uses cookies and processes IP addresses and other technical data. IP addresses are only processed for a short time and in a way that does not allow us to identify you as an individual.
We do not use cookies for marketing, remarketing or targeted advertising based on users' activity on the website.
The basis for the use of analytics tools is our legitimate interest in improving and securing our websites and services. You can manage the use of cookies yourself through the settings in your browser.
7. Use of data processors and disclosure to third parties
7.1 Data processors
Gambling Addiction Norway uses trusted external service providers (data processors) who process personal data on our behalf. This may include, for example:
- IT operations and systems management providers
- communication and cloud solution providers
- chat and help desk solution providers
- suppliers of statistics and analysis tools
We enter into written data processing agreements with all data processors. The agreements regulate, among other things, what information is processed, the purpose of the processing, security measures and that the information cannot be used for purposes other than those we have determined.
An updated overview of our data processors can be obtained by contacting us.
If we were to use data processors who process information in countries outside the EEA, we will ensure that the transfer takes place in accordance with applicable data protection regulations and that necessary guarantees for the protection of personal data have been established.
7.2 Disclosure to public authorities
If necessary to fulfill statutory obligations or to protect life and health, personal data may be disclosed to public authorities, such as the police.
We do not disclose personal data to other third parties unless there is a valid legal basis or express consent.
8. Storage and deletion of personal data
We store personal data only for as long as is necessary for the purpose for which it was collected, or as long as we are required to store it by law.
Retention time and deletion follow these principles:
Information processed on the basis of consent is deleted when consent is withdrawn, unless there is another valid legal basis for further storage.
Information related to services and agreements is stored for as long as necessary to fulfill the service or agreement and associated obligations, and then for a limited period if necessary for documentation purposes.
Information from helpline, chat and groups is not stored longer than is necessary to provide you with follow-up and to maintain our professional quality and security. Where possible, anonymization or de-identification is used for statistical and reporting purposes.
Messages in chat and related services may be stored in an encrypted cloud database with an external provider. When deleting a user profile, the profile will normally be removed within 48 hours after we have received and processed the request. When we no longer need the personal data, it will be deleted.
9. Your rights
As a data subject, you have a number of rights related to our processing of your personal data. You can exercise these rights by contacting us.
You have the right to:
- Information: to receive clear information about how we process your personal data.
- Access: to find out what personal data we have registered about you, and to receive a copy of this.
- Correction: to have information that is incorrect or incomplete corrected or supplemented.
- Deletion: to have information deleted that is no longer necessary for the purpose, or where the processing does not have a valid legal basis.
- Restriction of processing: to request that the processing of your information be restricted in certain situations, for example while the accuracy of information is being assessed.
- Object: to object to processing based on our legitimate interest, on grounds relating to your particular situation.
- Withdraw consent: where processing is based on consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.
We will respond to inquiries about rights as soon as possible and in line with the deadlines in the privacy regulations.
9.1 Complaint to the Norwegian Data Protection Authority
If you believe that our processing of your personal data is in violation of the data protection regulations, you have the right to complain to the Norwegian Data Protection Authority.
Before you contact the Norwegian Data Protection Authority, we encourage you to contact us so that we can attempt to clarify and correct any misunderstandings or errors.
More information about the right to appeal can be found on the Norwegian Data Protection Authority's website: www.datatilsynet.no.
10. Security, confidentiality and prevention
10.1 Information security and confidentiality
Gambling Addiction Norway has established technical and organizational security measures to protect personal data against unauthorized access, alteration, loss or destruction.
This includes, among other things:
- confidentiality agreements for employees and volunteers
- access control and role-based access to systems
- secure routines for storing, deleting and shredding paper documents
- Regular assessment of risks and security measures.
10.2 Duty to prevent and right of emergency
In the event of information about planned or ongoing serious criminal acts, or if there is an acute danger to life or health, we may be legally obliged to forward necessary information to the police or other relevant authorities. See the Penal Code Section 196 (duty to prevent) and Section 287 (duty to assist).
In such situations, considerations of life and health may take precedence over confidentiality. We will then only disclose the information that is necessary in the specific case, such as IP address and information that makes it possible to identify or assist the person concerned.
11. Automated decisions and profiling
Gambling Addiction Norway does not use automated individual decisions or profiling that have legal effects on you or similarly significantly affect you.
12. Changes to the Privacy Policy
We may update this privacy policy in the event of changes in regulations, our services or our practices. The updated version will always be available on our website.
13. Contact information
If you have any questions about this privacy policy, how we process personal data, or wish to exercise your rights, you can contact us at:
Gambling addiction Norway
Postal address: Strandveien 10, 9060 Lyngseidet
E-mail: post@spillpendendik.no
Telephone: 477 00 200 / 952 30 375
Organization number: 986 595 805
We respond to privacy inquiries as soon as possible.