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Privacy policy

This Privacy Policy was last updated on October 5, 2026

Table of contents

1. About this policy

ITX Norge AS and its subsidiary, ITX Nordic AB (collectively, “ITX,” “we”) are committed to protecting personal data. This policy explains how we process personal data as a data controller—that is, when we determine the purposes and means of processing personal data.

ITX Nordic AB is the data controller for personal data regarding its own customers, prospects, suppliers, partners, and job applicants. ITX Norge AS is the data controller for all other processing described in this policy.

Important distinction: When you use the ITX platform as an employee or customer of an ITX customer, ITX processes that data as a data processor on behalf of our customer, who is the controller. That processing is governed by the Data Processing Agreement between ITX and the relevant customer, not by this policy. If you are an end user or customer of a business that uses ITX, please contact that business to exercise your rights.

This policy applies to:

    • Visitors to itxuc.com and our other public websites
    • Prospective customers and people who contact us
    • Contact persons at our customers, suppliers, and partners
    • Job applicants
    • Visitors to our facilities
    • People who report security vulnerabilities to us

2. Data controller and contact details

Category What it is for
Controller
ITX Norway AS
ITX Nordic AB
Organization number
998 024 986
559605-2174
Address
Borgeskogen 4, 3160 Stokke, Norway
Svärdvägen 212, 182 33 Danderyd, Sweden
Email
support@itxuc.com
support@itxuc.com
Telephone
+47 236 80 400
+46 8 557 600 70
Privacy inquires
dpo@itxuc.com
dpo@itxuc.com

3. What we process, why, and on what legal basis

3.1 Website visitors

Category What it is for
Personal data
IP address, browser and device type, operating system, referring URL, pages visited, time and duration of visit, language preference, cookie identifiers.
Purpose
Operating and securing the website; measuring and improving content; marketing
Legal basis
Strictly necessary cookies and server logs: legitimate interest (GDPR Art. 6(1)(f)) in operating a secure and functional website. Analytics and marketing cookies: consent (Art. 6(1)(a)), cf. the Electronic Communications Act § 3-15
Rentention
Server logs: 12 months. Cookie lifetimes vary by cookie and are listed in our Cookie Policy

Note: The technologies used to collect this data on your device, and how you control them, are described in our Cookie Policy.

3.2 Inquiries, demo requests and sales dialogue

Category What it is for
Personal data
Name, employer, job title, email, telephone number, and the content of your inquiry.
Purpose
Responding to enquiries, arranging demonstrations, preparing offers, and following up potential customer relationships
Legal basis
Steps taken at your request prior to entering into a contract (Art. 6(1)(b)), or legitimate interest in responding to business inquiries (Art. 6(1)(f)).
Rentention
24 months from the last contact, unless a customer relationship is established.

3.3 Marketing and newsletter

Category What it is for
Personal data
Name, employer, email address, and statistics on whether emails are opened and which links are clicked
Purpose
Sending newsletters and information about our services; measuring the effect of our marketing.
Legal basis
Consent (Art. 6(1)(a)), cf. the Marketing Control Act § 15. For existing customers, we may send information about similar services based on the existing customer relationship, cf. the Marketing Control Act § 15 third paragraph.
Rentention
Until you withdraw your consent or unsubscribe. Every message contains an unsubscribe link.

3.4 Contact persons at customers, suppliers and partners

Category What it is for
Personal data
Name, employer, job title, work email, work telephone, role in the contractual relationship, correspondence, and — for platform administrators — login identifier and activity logs in administrative interfaces.
Purpose
Administering the contractual relationship, delivering and supporting the service, invoicing, account management, and service notifications.
Legal basis
Legitimate interest in administering a business relationship with a legal person (Art. 6(1)(f)); legal obligation for accounting records (Art. 6(1)(c)), cf. the Bookkeeping Act.
Rentention
For the duration of the contractual relationship plus 3 months. Accounting documentation is retained for five years after the end of the financial year, cf. the Bookkeeping Act § 13.

3.5 Support requests

Category What it is for
Personal data
Name, contact details, employer, and any information you include in a support request — including screenshots, log extracts and system data.
Purpose
Investigating and resolving reported issues, and improving the service.
Legal basis
Performance of the contract with the customer (Art. 6(1)(b)) and legitimate interest in providing effective support (Art. 6(1)(f)).
Rentention
24 months from case closure.

Note: Where a support request contains personal data belonging to a customer’s own data subjects, ITX processes that data as a processor under the relevant Data Processing Agreement.

3.6 Job applicants

Category What it is for
Personal data
Name, contact details, CV, application letter, education and employment history, references, and any results from interviews or assessments.
Purpose
Assessing applications and administering recruitment processes.
Legal basis
Steps taken at the applicant’s request prior to entering into an employment contract (Art. 6(1)(b)) and legitimate interest in a documented recruitment process (Art. 6(1)(f)).
Rentention
Deleted 3 months after the position is filled, unless you consent to us retaining your application for future opportunities. Open applications sent to karriere@itx.no are retained for 6 months

3.7 Visitors to our premises

Category What it is for
Personal data
Personal data Name, employer, host, time of arrival and departure.
Purpose
Physical access control, security, and emergency evacuation
Legal basis
Legitimate interest in securing our premises and information assets (Art. 6(1)(f)).
Rentention
3 months.

3.8 Security vulnerability reports

Category What it is for
Personal data
Name, contact details, and the content of the report, where provided
Purpose
Receiving, assessing and responding to reported vulnerabilities
Legal basis
Legitimate interest in maintaining the security of our services (Art. 6(1)(f))
Rentention
24 months after the case is closed.

Note: Reports may be submitted anonymously. See our Vulnerability Disclosure Policy.

4. Cookies and similar technologies

We use cookies and similar technologies on our websites. Under the Electronic Communications Act § 3-15, we may only store information on, or access information in, your device only where you have given prior consent that meets the requirements of the GDPR. This does not apply to technologies that are strictly necessary to deliver a service you have requested.

Our Cookie Policy sets out which cookies and similar technologies we use, who provides them, what they are used for, and how long they remain on your device. You can change or withdraw your consent at any time via the cookie settings icon in the left footer of every page.

Where cookies result in the processing of personal data about you, that processing is described in section 3.1 above.

5. Who we share personal data with

We do not sell personal data. We disclose personal data to:

    • Data processors who process personal data on our behalf under a data processing agreement, including providers of consent management and marketing automation:
        • Consent Management provided by CookieYes Limited, 3 Warren Yard, Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom.
        • Marketing automation provided by Make AS, Sandakerveien 116, 6th floor, 0484 Oslo, Norway. NO 993 555 002.
        • Team messaging and collaboration provided by Slack Technologies Limited, One Park Place, Hatch Street Upper, Dublin 2, Ireland.
          Our workspace is configured for data storage within the EU/EEA.

        • Accounting and ERP (ITX Norge AS) provided by Tripletex AS, Karenslyst allé 56, 0277 Oslo, Norway. NO 914 286 018.
          Data is stored within the EU/EEA.

        • Accounting and ERP (ITX Nordic AB) provided by Fortnox AB, Bollgatan 3B, 351 06 Växjö, Sweden. SE 556469-6291.
          Engaged directly by ITX Nordic AB. Data is stored within the EU/EEA.

        • Human Resources Management provided by Simployer AS, Kalnesveien 5, 1712 Grålum, Norway. NO 986 419 454.
          Data is stored within the EU/EEA.

        • Cloud productivity and collaboration platform provided by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.
          Our tenant is configured for data storage within the EU/EEA.

        • AI assistance provided by Anthropic PBC, San Francisco, California, USA. Used to support drafting, summarization, and analysis in our internal work. Data disclosed to this provider is not used to train its models and is subject to the safeguards described in section 6.

    • Public authorities, where we are legally required to disclose information.
    • Advisers, such as auditors and legal counsel, when necessary.

6. Transfers outside the EU/EEA

We seek to keep personal data within the EU/EEA. Where personal data is transferred to, stored in, or accessible from a country outside the EEA, we establish a lawful basis for the transfer under Chapter V of the GDPR before the transfer takes place:

    • Adequacy decision (Art. 45) — where the European Commission has determined that the country in question ensures an adequate level of protection.
    • Standard Contractual Clauses (Art. 46(2)(c)) — the clauses adopted by the European Commission, supplemented where necessary by additional technical, organizational, and contractual measures identified through a documented transfer impact assessment.
Category What it is for
Recipient
Country
Transfer basis
CookieYes Limited
United Kingdom
Adequacy decision
Anthropic PBC
United States
Standard Contractual Clauses, with supplementary measures

For transfers to the United States, we have conducted and documented a transfer impact assessment. In addition to the Standard Contractual Clauses, we rely on contractual restrictions on the purposes for which the recipient may process the data, a contractual exclusion of special categories of personal data, access restrictions, and confidentiality obligations applicable to the recipient’s personnel, the recipient’s obligations under the Standard Contractual Clauses in the event of a request for access by a public authority, and our own internal restrictions on what personal data may be submitted to the service.

You may request a copy of the safeguards applied to a transfer by contacting dpo@itxuc.com.

7. Security

We have implemented technical and organizational measures to protect personal data against unauthorized access, alteration, deletion, and loss. These include least-privilege access control, encryption of data in transit, logging and monitoring, secure development practices, supplier assessments, and regular personnel training. Our information security management system is built on ISO/IEC 27001.

8. Your rights

Where we act as controller, you have the right to:

    • Access — obtain confirmation of whether we process personal data about you, and a copy of that data.
    • Rectification — have inaccurate or incomplete data corrected.
    • Erasure — have data deleted where the conditions are met.
    • Restriction — request that processing be limited.
    • Object — object to processing based on legitimate interest, including direct marketing.
    • Data portability — receive data you have provided in a machine-readable format, where processing is based on consent or contract.
    • Withdraw consent — at any time, where processing is based on consent. This does not affect the lawfulness of processing carried out before withdrawal.

To exercise your rights, contact us at dpo@itxuc.com. We will respond without undue delay and in any event within one month. We may ask you to verify your identity before we act on a request.

9. Complaints

If you believe we are processing your personal data unlawfully, we would like to hear from you first so we can address the issue. You also have the right to file a complaint with the Norwegian Data Protection Authority:

Norway: Datatilsynet
P.O. Box 458 Sentrum, 0105 Oslo
postkasse@datatilsynet.no
www.datatilsynet.no

Sweden: The Swedish Data Protection Authority (IMY)
P.O. Box 8114, 104 20 Stockholm
imy@imy.se
www.imy.se

10. Changes to this policy

We may update this policy as our services and our processing activities change. The current version is always available at itx.no. Where changes are material, we will notify affected individuals directly where practicable.