Privacy policy

Privacy policy

Valid from 10/06/2021

1. In general

This privacy policy describes how Way AS processes personal data relating to users of Way's services, including the website way.no, Way student app, traffic simulator and other traffic training. The privacy statement is also aimed at anyone else who is not a user, but who is interested in knowing more about us or who are suppliers/partners of our Services. The CEO of Way AS is the data controller for the processing of personal data in Way and can be contacted at vigdis.harsaker@way.no. Please note that other companies may also act as controllers of your personal data if we disclose such personal data to third parties. In that case, such third parties will have to be considered independent data controllers and you will have to comply with their processing practices. More about the transfer of such personal data to third parties is described in section 6 below.

2. Legal basis and purpose

Way will process personal information related to you as a person in accordance with what is described in this privacy statement.

We process personal information both about you who are a customer, supplier or commercial partner, and you who are curious and want to know more about us, among other things via our website. The purposes of the treatment are as follows:

  • Processing of personal data about our users / customers
(i) fulfill the agreement we have with you to provide you with access to our Services. This will in particular apply to the administration and management of our customer relationship, including to communicate with you and your guardians if you are under 18 years of age, provide you with necessary training either by car or by using our traffic simulator, follow-up, invoicing, handling any complaints and disputes, and investigating your satisfaction. The legal basis for the data processing is the General Data Protection Regulation 2016/679 (GDPR) article 6 (1) b.

(ii) fulfill our legitimate interest in storing your personal data in order to improve us and our Services, cf. GDPR Article 6 (1) f. In the balancing of interests, we have, among other things, taken into account the nature and extent of your personal data, whether you, based on the information we have provided to you, can reasonably expect your personal information to be used in connection with our service improvement, as well as our need to use your personal information for this purpose.

(iii) send out information about offers and marketing material, and assess when it would be appropriate to send out the type of material to you in accordance with the Marketing Act § 15. Our basis for processing your personal data for this purpose is GDPR article 6 (1) f. In the balancing of interests, we take into account the same conditions as mentioned above.
(iv) fulfill our legal obligations by storing any of your personal information as required by law, e.g. iht. the Accounting Act when you use our Services, cf. GDPR Article 6 (1) c.

  • Processing of personal data about others
Personal information about others such as our suppliers and partners, including their employees, will primarily be used to manage and manage our relationship with them, including to communicate and fulfill our agreements with them in accordance with GDPR Article 6 (1) f. will in some cases also be required by law to process personal data about others such as our suppliers in accordance with GDPR Article 6 (1) c.

Where we have no established relationship or where we wish to process personal data for purposes other than the fulfillment of our agreements or legal obligations, we will consider whether we have a legitimate interest under GDPR Article 6 (1) f to do so. . In the balancing of interests, we will take into account the same conditions as mentioned above

We may also process personal data about visitors to our website, where we have obtained consent, cf. GDPR article 6 (1) a, or where we believe we have a legitimate interest pursuant to GDPR article 6 (1) f. We believe that we have a legitimate interest in processing your personal data, e.g. by using necessary cookies and to be able to respond to your inquiries, e.g. where you want a free trial lesson in the traffic simulator, where you want to sign up for Traffic Basic Course or Class B traffic training.

Furthermore, we can process personal information about you who want to work with us and who want to share your CV and job application with us. Our basis for processing during the recruitment process will be GDPR Article 6 (1) b.

3. How and what personal information is processed by Way

Way may process personal information

  • When you register a user on our website way.no and in the Way student app.
  • When you use our Services to enter/submit information by filling in forms, subscribe to notifications or alerts, change your user profile, and interact with customer support.
  • When we use cookies ;
  • When you interact with us in other ways, e.g. by phone or in person.
  • When you use our traffic simulator and we film your performance and reactions during the training.
  • When you drive a car and we record your achievements during the training.
Way AS processes the following categories of personal information about you:

Contact information

Applies to everyone who fills out a contact form on our website and on our premises, as well as all our users:

  • First name,
  • Surname,
  • Date of birth,
  • Phone number,
  • E-mail address,
  • Name, date of birth, phone number and email address of parent or guardian (if under 18)

User information

Applies only to our users:

  • Financial information, including credit card number and other card numbers, account number, social security number, address and location, payment history, and any credit checks as long as permitted by law.
  • Training information, including information on progress, performance and reflections on the training.
  • Traffic simulator information, including video of users' behavior and reactions in different traffic situations.
  • Location information, including where you want to be picked up for your driving lessons.

Website information

Applies only to those who visit our website:

  • Behavior pattern through the use of the website way.no, such as how long you have been on our website and which website you come from, and
  • IP address (es) through the use of the website way.no

Other information

Applies only to our suppliers and partners:

  • Employee contact information
  • Payment information for the delivery / partnership.

Way does not in principle process any particular categories of personal information (sensitive information), and we encourage you not to share such information with us, unless you consider the sharing absolutely necessary in order to give you access to our Services.

4. Storage period and safety

Way will not store your personal information longer than is necessary to fulfill the purposes mentioned above.

This means that we will delete, alternatively anonymise, your personal information as soon as you have terminated the customer relationship with us, unless we are required by current regulations to keep some of your personal information longer (eg under the Accounting Act).

When you ask us to delete your personal information, we will respond to your request within 30 days of receiving your inquiry.

You can request to have your personal information deleted by sending an email to post@way.no . See also point 7 below, with additional information about your rights.

We have established routines and measures at various levels to ensure that unauthorized persons do not gain access to your personal information and that all processing of the information in general takes place in accordance with current legislation. The measures include regular risk assessments, technical systems and physical procedures to ensure information security and routines for verifying access and correction requests. Further information about these risk assessments and safety measures can be obtained by contacting us.

5. Where personal data is processed

As a general rule, Way will process your personal data in Norway.

However, Way may use data processors based in countries within the EEA (Belgium and Germany). This will apply in particular to the use of the Way student app and back office system.

Where Way may use data processors or other data controllers outside the EEA ("third countries"), any transfer of personal data to such third countries will be governed by necessary provisions, such as the EU's standard data protection clauses for the transfer of personal data to third countries, or other legally binding instruments between public authorities and persons/companies/organizations.

6. Rules for sharing personal information

Except for the purposes set forth above, Way will not disclose your personal information to any affiliated third parties unless we have obtained your voluntary, specific, informed and unambiguous consent, or

  1. We have to share your personal information in order to give you access to our Services, or
  2. We have to share your personal information due to legal obligations (eg your training and driving license certificate to the Norwegian Public Roads Administration), or
  3. Where necessary to defend us against claims or other legal proceedings, or
  4. We have a legitimate interest in sharing such personal information and this interest does not exceed your need for secure privacy.
Affiliated third parties are companies and any natural persons that Way uses to provide its Services. Way has entered into binding agreements, including data processor agreements if necessary, with such third parties, who will also ensure that your privacy is safely safeguarded through their own security mechanisms. In all cases, Way will ensure that the recipients of your personal information grant you the same rights as those stated in this statement. This includes the right of access and the right to delete your personal data, see section 7 below.

Among our suppliers and partners, we use TABS, which is the traffic school's administration and booking system. We also use ProISP, which is a provider of web hosting, domains, virtual servers (VPS) and SSL certificates. Furthermore, we use Google Firebase Authentication for registration and use of our app and Stripe for payment via our app.

You can contact us at any time if you want further information about who we share your personal information with.

7. Your rights

Right of access, right to rectification, right to restriction and right to erasure of your personal data

Upon your request, Way will consider your right to access all personal data that Way has stored about you. Exceptions may exist if Way is prevented by law from providing you with such access.

If any personal data is found to be inaccurate, incomplete, undated or unnecessary, you have the right to request that the data be corrected or removed.

Where you may experience direct marketing from us, you may also object to the processing. In such cases, we will consider whether we can restrict the processing. You may also have the right to request restriction of processing in certain other cases.

Right to withdraw your consent

Where you have given us your consent to process your personal data, you will at any time be able to ask us to withdraw such consent, with the consequence that your personal data will be erased. However, as mentioned, in some cases we will be required by law to continue processing.

Right to transfer of personal data (data portability)

You have the right to obtain the personal data that you have provided to Way in a structured, commonly used and computer-readable format. You also have the right to have this personal data transferred to another controller.

Right to complain to supervisory authorities

You have the right to complain to the applicable supervisory authority (Datatilsynet) if you believe that the processing of your personal data is in conflict with your rights.

Contact information

If you have any questions regarding the stated rights or this privacy policy in general, please contact us by sending an email to post@way.no

8. Changes

Way reserves the right to change or revoke this privacy statement at any time. A new privacy statement will be published on our website and you will be informed of it by e-mail or in other visible ways, if the changes are significant for the way your personal data is processed.