PRIVACY POLICY – Greenland Ruby

Introduction
At Greenland Ruby we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Greenland Ruby RubyCloud™ website or the Greenlandruby.gl website, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Website”). Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the site.

Data Controller
“Greenland Ruby” (referred to as “we”, “us”, “our” or “Greenland Ruby”) in this policy primarily refers to Greenland Ruby and other entities over which Greenland Ruby exercises management control. Greenland Ruby is the “data controller” of all personal information that is collected and used by Greenland Ruby.

Application
Greenland Ruby is a group of companies with operations globally. This Privacy Policy applies to the personal information collected by any legal entity controlled by Greenland Ruby.
Greenland Ruby’s head office is in Nuuk, Greenland, while its sales and marketing offices are in New York, NY and Paris, France. Additional operations are based in Bangkok, Copenhagen, and Mo I Rana, Norway. The mine site operator in Aappaluttoq is LNS Greenland A/S, a sister company of Greenland Ruby. Greenland Ruby and LNS Greenland are a part of the larger LNS Group, a Norwegian, family-owned company that handles mining contracts, road projects, bridges and tunnels in arctic regions.

Policy of Compliance
It is Greenland Ruby’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy shall guide the activities of Greenland Ruby. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions. This Privacy Policy has a limited scope and application and the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

What is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).
What Personal Information We Collect and How We Use It
We will only use your personal data when the law allows us to do so. We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data
Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you register with the Site or when you choose to participate in various activities related to the Website, such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Financial Data
Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We store only very limited, if any, financial information that we collect

Mobile Device Data
Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Third-Party Data
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.
Data From Contests, Giveaways, and Surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

Why Do We Collect Personal Information?
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:
• Conduct due diligence
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Create and manage your account.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.
• Email you regarding your account or order.
• Facilitate communication.
• Fulfill and manage purchases, orders, payments, and other transactions related to the Site.
• Generate a personal profile about you to make future visits to the Site more personalized.
• Increase the efficiency and operation of the Site.
• Monitor and analyze usage and trends to improve your experience with the Site.
• Notify you of updates to the Site.
• Offer new products, services, mobile applications, and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Site.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• Solicit support for the Site.
• With your permission, send you a newsletter (including sweepstakes, promotions, and contests).

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. 

Legal Basis for Processing

The legal basis for processing personal information is that it is necessary for running our business and sometimes we process personal information in order to achieve our legitimate interest in ensuring the purposes mentioned above.

Further, we process personal information based on consent.

When Do We Disclose Your Personal Information?

We will not share your personal information with third parties except for in circumstances where such sharing is necessary to provide our services or achieve our business objectives as further described in this Policy.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Online Postings

When you post comments, contributions or other content to the Website, your posts may be viewed by all users and may be publicly distributed outside the Website in perpetuity.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Website. These companies may use information about your visits to the Website and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Other Third Parties

We may share your information with investors for the purpose of conducting general business analysis.

We use external third-party service providers for delivering services on our behalf and on our instructions as set out in a data processing agreement with the relevant service provider. In such instances, we may share your personal information with such parties to the extent necessary to perform such services or to fulfil terms within a contract with you.

In addition to using cookies and related technologies, we also may permit certain third party companies to help us tailor advertising that we think may be of interest to our registered users. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons.

Transfer of Personal Information

When sharing personal information to other parties as described above, we sometimes need to transfer personal data to a country outside the EEA in order to be able to fulfil one of the purposes set out in this Policy.

How is Your Personal Information Protected?

We endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification, destruction or disclosure and all other unlawful forms of processing.

We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with EU law on data protection.

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

How Long is Your Personal Information Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, we endeavor to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimize over time the personal data that we use, and if we can anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

Your Rights as a Data Subject

You have the right to request access to and rectification of any information we have collected about you. To help us keep your personal information updated, we advise you to inform us of any changes or discrepancies. In some circumstances, we may not agree with your request to rectify your personal information and will instead append an alternative text to the record in question. You will be notified both when information is rectified and when not, and if so what the reason is for not obeying to your request.

You also have the right to erasure and restriction of processing in some instances. You may have a right to receive personal data concerning you in a machine-readable format and to forward the data to another party (data portability), provided that certain conditions are met.

You also have the right to object to the processing, including if the processing is for marketing purposes. In order to object to processing, please contact Greenland Ruby.

Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

To exercise your rights as a data subject, or if you wish to make a complaint regarding our compliance with this Policy, please contact Greenland Ruby. Prior to fulfilling your request, we may request specific information from you to enable to confirm your identity and right to access as well as to search for and provide you with the personal information we hold about you.

You have a right to complain to Greenland Ruby regarding violations of your rights under applicable data protection law. Further, you have a right to complain to the supervisory authority competent to resolve such concerns according to applicable law, but we encourage you to first contact us before filing such complaint.

Contact Us:

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Revisions to this Policy

Greenland Ruby may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the way we deal with your personal information.

We will communicate any revised version of this Privacy Policy. Any changes to this Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change.

This Privacy Policy was last reviewed May 1, 2021. 

Interpretation of this Policy

This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’. This Privacy Policy does not create or confer upon any individual any rights, or impose upon Greenland Ruby any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual’s personal information. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.