PRIVACY POLICY

This privacy policy sets out how Vakaheim AS, the legal owner of this site torsteinworren.com (in the following referred to as "we") uses and protects any information that you give when using this website.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1st April 2025.

TORSTEINWORREN.COM - DATA LINKED TO YOU

When you subscribe to email lists, book a coaching session or purchase a product on our website, we may collect the following information:

your name and / or nick-name
contact information including email address and mailing address
demographic information such as location, postcode / zipcode, preferences and interests
other information you provide in the custom field you may fill out when booking a session.

WHAT WE DO WITH THE INFORMATION WE GATHER

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Internal record keeping.
We may use the information to improve our products and services and to customise the website according to your interests.
We may periodically send promotional emails (if you have given us your email address or bought a product from us) about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
You always have the right to opt-out of receiving these emails.
You always have the right to delete your account and request for information from your account to be removed from our records.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

HOW WE USE COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. We also use cookies to reward affiliates whose link you may have used to get to our website. We offer affiliates a commission of any successful sale of products from our website. This is a way to support our Gene Keys Guides & Network Partners, while also sharing the teachings far and wide.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email protected]
We will not sell, distribute or lease your personal information to third parties.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to [email protected]
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at [email protected]. We will promptly correct any information found to be incorrect.

GDPR WEBSITE POLICY

Vakaheim AS (“we,” “us,” “our”) is committed to protecting your personal data and respecting your privacy. This policy explains how we adhere to the General Data Protection Regulation (GDPR) and related standards, including ISO 27001:2013 and PCI DSS, to safeguard the personal data of individuals visiting or using our website. It complements our Privacy Policy and outlines our practices regarding data collection, processing, security, and user rights.

APPLICABILITY

This GDPR Website Policy applies to all individuals residing in the European Union (EU) and the United Kingdom (UK) who interact with our website, regardless of their nationality or location.

DATA PROTECTION PRINCIPLES

We adhere to the following data protection principles:

Lawfulness, Fairness, and Transparency: Processing data lawfully, fairly, and in a transparent manner.
Purpose Limitation: Collecting data for specified, explicit, and legitimate purposes.
Data Minimization: Ensuring data is adequate, relevant, and limited to what is necessary.
Accuracy: Keeping personal data accurate and up to date.
Storage Limitation: Retaining data only for as long as necessary.
Integrity and Confidentiality: Protecting data against unauthorized access, loss, or damage.
Accountability: Being responsible for and able to demonstrate compliance with these principles.

DATA COLLECTION AND PURPOSES

We collect only the personal data that is necessary to provide you with our products and services, process your orders, and ensure a smooth user experience. Specifically, we may collect the following personal data when you interact with our website or place an order:

Identification and Contact Details: Such as your name, email address, dob, laction, billing address. These details are essential for processing orders, delivering products, providing customer support, and communicating updates about your purchase.

Legal bases for processing

Under GDPR, we rely on the following lawful bases for processing your personal data:

Contractual Necessity (Article 6(1)(b)):
Identification and Contact Details: Processed to fulfill orders, provide customer support, and communicate updates.
Payment Information: Processed to complete transactions securely under PCI DSS Compliance.
Legal Obligations (Article 6(1)(c)):
Order-Related Data: Retained for up to seven years to meet tax and accounting requirements.
Consent (Article 6(1)(a)):
Marketing Communications: Processed when you explicitly opt-in to receive marketing emails or newsletters. You can withdraw this consent at any time by contacting us at [email protected]

THIRD-PARTY DATA SHARING AND TRANSFERS

We may share your personal data with trusted third-party service providers who assist us in operating our website, conducting our business, or providing services to you. These third parties are obligated to protect your data and are restricted from using it for any other purposes.

International Data Transfers

All personal data is stored and processed on servers belonging to GoHighLevel Inc.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your browsing experience, analyze site usage, and provide personalized content. Cookies may be essential for website functionality or used for analytics and marketing purposes.

You can manage your cookie preferences through your browser settings. For more detailed information, please refer to our Cookie Policy.

ANONYMIZED ANALYTICS AND SITE USAGE DATA

We may collect anonymized usage data from our website to help us understand how users interact with our site, improve our services, and enhance the user experience. This anonymized data cannot identify you personally and therefore does not fall under the scope of GDPR. No personal data is used for analytics purposes, and no data subject rights are impacted by these purely anonymized metrics.

DATA MINIMIZATION AND ACCURACY

We adhere to GDPR’s principles of data minimization and accuracy. This means we:

Collect only the personal data we need to fulfill your order, comply with legal obligations, or send you marketing communications if you have consented.
Keep your personal data as accurate and up-to-date as possible.
Offer you the opportunity to correct or update your information at any time by contacting us.

DATA RETENTION

We retain personal data only as long as is necessary to fulfill your order, meet our legal obligations, or provide requested services. For example, we may keep order-related data for up to seven years to meet tax and accounting requirements. When your personal data is no longer needed for these purposes, we securely delete or anonymize it.

DATA SECURITY MEASURES

We take data security seriously and implement technical and organizational measures to protect your personal data from unauthorized access, misuse, alteration, or loss. These measures include, but are not limited to:

Encryption: Encryption of sensitive data, such as payment information, during transmission.
Access Controls: Ensuring that only authorized personnel can access personal data.
Regular Security Audits and Testing: Identifying and addressing potential vulnerabilities.
ISO 27001:2013 Alignment: Ensuring our information security management system follows internationally recognized best practices.
PCI DSS Compliance: Secure handling of payment card information.

All personal data is stored on secure servers belonging to our service provider GoHighLevel Inc. We do not transfer personal data to other providers. In the event of a data breach affecting personal data, we will notify the appropriate supervisory authority and any affected individuals in accordance with GDPR requirements.

DATA BREACH NOTIFICATION PROCEDURES

In the event of a data breach affecting personal data, we will:

Assess the Breach: Determine the nature and scope of the breach.
Contain the Breach: Implement measures to prevent further unauthorized access.
Notify Authorities: Inform the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach.
Inform Affected Individuals: Communicate with individuals affected by the breach without undue delay if the breach is likely to result in a high risk to their rights and freedoms.
Review and Improve: Analyze the breach to prevent future incidents and update security measures accordingly.

YOUR GDPR RIGHTS

Under GDPR, you have several rights regarding your personal data. You may:

Right of Access: Request information about whether we hold personal data about you and obtain a copy of that data.
Right to Rectification: Ask us to correct inaccurate or incomplete personal data.
Right to Erasure (“Right to be Forgotten”): Under certain conditions, request the deletion of your personal data.
Right to Restrict Processing: Request that we limit how we process your data in specific circumstances.
Right to Data Portability: Receive your personal data in a machine-readable format and ask us to transfer it to another controller, where feasible.
Right to Object: Object to specific data processing activities, including receiving direct marketing communications.

Exercising your GDPR Rights

To exercise any of your GDPR rights, follow the steps listed below. We will acknowledge receipt of your request within five business days and respond within one month to confirm the actions taken or provide further information.

Requesting Data Export: Contact us at [email protected]

Requesting Data Deletion: Contact us at [email protected]

MARKETING COMMUNICATION

We will only send marketing emails or newsletters if you have explicitly agreed to receive them. You can unsubscribe at any time by using the “unsubscribe” link in the email or by contacting us at [email protected]. Withdrawing consent does not affect the lawfulness of any processing carried out before you withdrew it.

Obtaining and Managing Consent

When you opt-in to receive marketing communications, you do so through clear and affirmative actions, such as checking an opt-in box. We record your consent and provide options to manage your preferences at any time. To withdraw consent, you can use the “unsubscribe” link in our emails or contact us directly at [email protected]. Upon withdrawal, we will cease processing your data for marketing purposes promptly.

NO LEGITIMATE INTERESTS OR AUTOMATED DECISION-MAKING

We do not rely on “legitimate interests” as a separate lawful basis for processing your personal data. Additionally, we do not engage in automated decision-making or profiling that would produce significant legal effects for you.

Automated Decision-Making and Profiling

We do not engage in automated decision-making or profiling that affects your legal rights or significantly impacts you. Our data processing activities for analytics are limited to improving user experience and do not involve profiling individuals.

ANONYMIZED ANALYTICS AND SITE USAGE DATA

CHILDREN'S PRIVACY

Our website is not intended for use by children under the age of 16. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data without parental consent, we will take steps to delete such information promptly.

ACCOUNTABILITY AND GOVERNANCE

We maintain records of our data processing activities. We demonstrate accountability and uphold the principles of GDPR, ISO 27001:2013, and PCI DSS.

We have procedures for responding to data breaches. These procedures ensure a swift and effective response to any incidents, minimizing potential harm and ensuring compliance with GDPR requirements.

RELATED POLICIES

For more information on how we handle cookies and other tracking technologies, please refer to our Cookie Policy above. To understand the terms and conditions of using our website and services, please review our Terms of Service.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Gene Keys. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

POLICY UPDATES

We may update this policy to reflect changes in our data handling practices, services, or legal requirements. Updated versions will be posted on our website, and we encourage you to review this policy periodically.