Privacy- and cookie policy

Your privacy is important to Effo. That is why we have developed this privacy policy, so you can have an overview on how we collect, use, store and share your personal information.

Who are we?

Effo has a Faroese ownership.

Effo sells oil extracts to Faroese and foreign ships in the Faroe Islands in addition, Effo also sells oil extracts to Faroese and foreign ships in harbours abroad and on the open sea. Effo is also the only supplier of Jet Fuel in the Faroe Islands. To continue to take part in developing the Faroese society, Effo owns half of Sp/F Vindrøkt, which delivers energy from wind power. A part of Effo is also the stations around the country, which provide convenience goods and fuel.

Businesses, institutions, aircrafts and households are all part of our customer base, which receive oil extracts and other related services from the company. The company has oil depots in Viðarnes, Saltangará, Fuglafjørð and in Tvøroyri and these are 70 % of all oil storage in the Faroe Islands. Furthermore, Effo also owns the terminal in Fuglafjørð, Effo Bunkers, where ships from around the world bunker. Today there are 200 people in the Effo group.

All major decisions regarding privacy, data protection and other procedures for safe processing of fata on a corporate level are taken by the top management in Effo together with other appropriate personnel with responsibilities in data protection in the company.

P/f Effo, Óðinshædd 5, FO-100 Tórshavn is the data controller and functions as joint data controller for P/f Effo Bunkers, Bakkavegur 61, 530-Fuglafjørður. After this ´Effo´ means both P/f Effo and P/f Effo Bunkers. Sp/f Vindrøkt is not a part of this policy.

How and when does this privacy policy apply?

This privacy policy describes the data processing activities carried out by Effo in cases where Effo acts as a data controller, collecting the personal data of customers, suppliers or employees and deciding the purpose and means for the processing.

This privacy policy also provides information on how Effo acts as data processor, meaning how Effo engages in processing data on behalf of our corporate customers or partners based on the instructions they provide.

This privacy policy applies to all processes in Effo.

If you disagree with the actions described in this privacy policy hereinafter, unfortunately, Effo will not be able to provide you with various services.

How does Effo act as a data controller?

Effo acts as the data controller when Effo determines the purposes for which and the manner in which personal data is processed. Personal data is any information that relates to an identified or identifiable living individual.

Processing personal data is necessary for Effo to prepare for or fulfill contracts we have entered into, provide our customers with services and products, offer them discounts and personalized offers.

Why we collect your personal data?

Effo collects and processes personal data about our customers, employees, suppliers, and partners to conduct business and as a means of reaching our strategic goal to provide our customers our best services.

We collect personal data and process personal data of the following data subjects:

• Existing and potential customers

To provide services, manage our customer relations and to deliver on our promises to our existing or potential customers, Effo needs information on who you are, what is your position as a user of our services and products, and information on how to reach you or what your role is as a contact person. The reasons for processing this information are mainly as follows:

• For delivering on agreements made with customers
• Providing support to users of our products and services
• Improving continuously our services through customer feedback
• Ensuring safety and environment standards.
• Preventing misuse of our products and services
• Invoicing, processing of purchases, making payments and conducting other financial tasks.
• Providing offers on products and services to our customers
• Administrating and managing bulk orders
• Creating profiles of customers in certain cases to promote more relevant products or services for specific customers
• Managing credit enquiries for users who have applied for the Effo Customer Card that require credit assessments

To reach out to larger markets, we shall pursue our legitimate interest and process data on potential customers in direct marketing initiatives. To provide relevant content to potential customers, Effo shall process personal data of potential customers that were collected during sales negotiations or when a person had expressed interest in receiving offers from Effo.

The legal basis for the above mentioned activities is consent, contract, and legitimate interest.

• Employees

If you are an employee at Effo, we shall process your personal data to fulfil the contract with you and to comply with statutory regulations. We shall do so based on contract and legal obligation and to ensure appropriate retention periods for processing such data.

If you are looking for job opportunities within Effo, we will process your personal data to evaluate your skill relevance for the position for which you apply. We shall do so based on your consent.

You can get more information about employee data processing from the Head of HR at Effo Rebekka Danielsen.

• Suppliers and partners

We will process the personal data of individuals who are representing our suppliers and business partners on the basis of pursuing our legitimate interests of acquiring new partners and new markets, as well as to fulfill the contracts that Effo has with those parties.

• Visitors to our service stations and other establishments

In order to comply with health, safety and environment standards, and pursue our legitimate interests, protect our business secrets, employees, customers and others, we may process your personal data by deploying CCTV surveillance within our facilities and fuel stations. Individuals shall be informed via notice when such activity is taking place. CCTV surveillance hardware shall be stored for the retention period of no more than 14 days unless it is required for legal purposes.

• Legal basis

Any personal data processing is not allowed without an appropriate legal ground. Therefore, we at Effo apply one of the following legal grounds as defined in the Faroese data protection regulation to any processing of your personal data:

• Based on a clear consent from you
• If the processing is necessary for a contract, we have with you
• If the processing is necessary for us to comply with the law
• If the processing is necessary to pursue our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

We only process data about the personal identification number, if you have given us a clear consent to us or if we have a legal obligation to do so.

Sensitive personal information, for instant information about healt, are processed on these legal grounds:

• Based on a clear consent from you
• Based on employee-, health- and social obligations
• Based on public information, where you have made this public
• Based on legal obligations where the processing is necessary to reach a goal of public interest

How we collect your personal data?

In general, Effo collects your personal data directly from you, meaning you have freely provided this data to us to receive certain products or services, or to enter into contract with us.

We may have your images recorded on our CCTV camera systems.

We also use cookies and other tracking technologies in Effo branded websites to provide generic online services. We collect information that the user actively sends to us via our websites, apps and services, such as name, email and phone number. We also collect data on how our users interact with our website. In addition to this, we also collect information from your computer or device such as the IP address, the internet browser you use and language settings. This data is collected via services, such as and not limited to Google Analytics Solutions. With your consent, the apps also allow you to use location services for services such as finding a nearby Effo station.

In other cases, we may also collect information on you from other sources. These sources may vary, but usually they are Effo´s business partners, public sources, or public information from social networks from a third-party.

With whom is your personal data shared?

Intragroup data sharing:

Your personal information can be shared inside the Effo group, that is P/F Effo and P/F Effo Bunkers, if the processing is in coherence with the purpose when they were collected.

External parties:

Effo may use third party service providers to help us to administer certain activities on our behalf, such as fulfilling purchases, processing credit card payments, sending emails and post, IT development, IT operations and IT security, providing advertisements, tracking effectiveness of our marketing campaigns and analyzing usage of our websites and apps, or even allowing users to connect to their social network. As such, to execute such services we may have to share personal data about you with our business partners, but only to the extent necessary to perform the services they carry out on our behalf, and making sure that they comply with data protection rules.

Effo might share your personal information with external parties in the following cases:

• Our suppliers and business partners:
  • We may share your personal data with our business partners or suppliers if there is a legitimate interest in so doing from a business management perspective and where statutory regulations allow us to do so, or when you have consented to such exchange of data.
• Public authorities:
  • Public authorities such as internal revenue services, police, courts, or other government institutions may ask Effo to provide them with any data we hold about you. In such cases, Effo will comply with requests from public authorities and government institutions only if there is sufficient legal basis to fulfill such request.
• User communities:
  • If you engage in commenting or expressing opinions on Effo user communities or pages on social networks, where such information can be seen and used by anyone with access to such community, for purposes that are beyond the control of Effo, Effo carries no responsibility for any content you submit on such communities.

Automatic data processing and profiling tools

Effo branded websites use automatic data collection tools and Effo engages in using digital tracking technologies to collect information about your movements and interaction with our websites.

Cookies

By using Effo branded websites you consent to storing and accessing of cookies.

We use cookies on our websites to identify users as unique but anonymous individuals. It helps us to register the number of visitors and gives us statistics and information about how many users we have on our websites and what they do. We use the statistics to best be able to simplify and clarify the page and make it as user friendly as possible.

For our apps we use Identifier for Advertising (IDFA) for iOS and Google Advertising ID (AAID) for Android. All this data is collected anonymously.

Google Analytics, PostHog and reCaptcha

Effo branded websites use Google Analytics and PostHog to collect data on how our users visit and use our websites and apps. This data is mainly collected through services provided by Google Analytics whose terms and conditions apply.

To protect against inappropriate usage we may use Google Invisible reCAPTCHA that collects hardware and software information, such as device and application data and the results of integrity checks, as well as unique online identifications such as IP address, and send that data to Google for analysis.

By using this service, you are consenting to providing the personal data to Google Analytics for integrity checks and for implementing measures necessary for safe use of the webpage only.

Third-party social network cookies

Effo is active on social media. At the moment Effo has pages on Facebook, Instagram and LinkedIn.

When you interact with Effo on these pages, you make information available for Effo and the social media, for instance when you react to posts on the page, comment on these or share these, and if you “like” the page or follow Effo on the social media. In addition to this normal information about you will be processed. The purpose for the process is to market Effo.

The legal basis for the processing can be found in § 8 in the Faroese data protection regulation and our legitimate interests to market Effo on the social media.

By using these pages on social media, these social media also process your information, that are collected through the Effo page on the social media. Effo and the social media are joint data controllers for the processing of these information.

You can read more about the joint controller responsibility regarding LinkedIn here, and regarding Facebook here. We otherwise advice you to read the privacy policy for these social media.

What kind of personal data does Effo collect and process?

Effo may process the following personal data on you:

• General information and contact details like name, surname, telephone number, e-mail and address.
• Demographic data such as date of birth or gender.
• Feedback on our services and products.
• Various requests from you to our customer service center.
• Photos or videos of you recorded within our facilities, service station forecourt or convenience store premises.
• Content you upload to our websites, apps and social network pages, such as photos or videos.
• Applications to our services which are provided on a contractual basis.
• Financial information, such as your bank account information, credit card information, or credit rating.
• Tracking information actively sent to us via our websites and generic online services. This includes information such as IP address, the internet browser you use or language settings.
• Unique user information such as login ID, password, security questions.
• Shopping behavior based on your purchases in our stations using your Effo Customer Card.
• Previous employment and education information, such as title, position, responsibilities, background, interests in professional context.
• Information you have made public and have freely given away on third party-party social networks.

Regarding employees we, in addition to the above, can process information about the following:

• Name, surname, birthdate, personal identification number, telephone number, e-mail, and address.
• Information about close contact persons
• Information about salary, banking- and taxes
• Information about education and work experiences
• Travel information regarding travels on behalf of Effo
• Picture for our intranet
• Information about devices that Effo has given you, such as computer, phone, keys etc.
• Information about period of pregnancy and childbirth
• Information about breach of law/contract, warnings, employee evaluation and information about reasons for discharge and dismissal
• Information about sick leave and other relevant health information
• Information about personal- and qualification tests
• Information about possible culpable activity
• Picture for our webpage, social media or annual report if we have a clear consent from you

As a controller, Effo does not process sensitive personal data to provide you with goods and services, however in some cases processing such data is a requirement for us to comply with legal as well as ethical obligations. Sensitive personal data may mainly be collected in the following cases:

• If you are an employee who is on sick leave, we might process some sensitive personal information regarding your health life as is dictated by labour law.
• If you are an individual who have had an incident within our premises, we might be obliged to process data on your health life to comply with health, safety and environment standards, as well as to record such incident to avoid it in future.
• If you are a customer who believes health issues are caused by food poisoning or other hazard from our products, we will be obliged to process sensitive personal data.

How does Effo safeguard your personal data?

Personal data within Effo is processed in a safe and secure manner.

At Effo we do our best to make sure any IT systems that are built, integrated, purchased or in general – used in Effo – abide by the privacy by design principle to maximize safe and secure processing of personal data.

We use encryption and pseudonymization where appropriate.

We limit access to personal data to those persons who have need for it.

We have guidelines, policies, and training available for employees processing personal data in Effo.

When we need to use a processor for processing personal data we very closely evaluate the business partners we share your personal data with to make sure they comply with applicable data protection legislation. In addition, to impose the data processing standards, Effo requests those business partners acting as processors, to sign personal data processing agreements with Effo.

Personal data is not processed longer than necessary. Effo´s standard retention policy is 6 months, however the retention period may vary based on agreements, legitimate interests of Effo, or statutory requirements regulating otherwise.

Information about employees is being retained for 5 years after the financial year for which the employment ended.

Effo abides by the data minimization principle and makes sure that when providing you with products and services, only the minimum amount of personal data is collected which is needed for the execution of service or delivery of product.

When does Effo use processors?

Effo may use third party service providers as processors for personal data for different purposes, for instance for data storage, providing CCTV solutions etc. List of personal data processors can be requested from Effo.

What are your rights and how to use them?

You have the right to request access to the personal information we hold about you. We do, however, need to be sure of your identity before we release any such information.

You have the right to object to personal data processing, withdraw consent, request erasure or rectification of your personal data or object to personal data processing and rights to data portability.

If you want to exercise your rights, please contact our customer service department. See more on www.effo.fo

If you are browsing the web and if you prefer not to have any personal data processed by your visit to our web-site through cookie services, we advise you to turn on private browsing in your web browser.

Finally, you also have a right to file a complaint with the data protection authorities with regard to our processing of your personal data. See more on www.dat.fo

Push Notifications
Our app may send push notifications to your device to provide updates, reminders, or promotional content. You will be asked for consent to receive push notifications during the app setup process or when the feature is introduced.

We collect device-specific identifiers solely to enable push notifications. These identifiers are stored securely and are not shared with any third parties.

If you no longer wish to receive push notifications, you can manage or disable them at any time through your device settings.

Contact us

You may contact us by sending an e-mail to datavernd@effo.fo or sending a letter to: P/f Effo, Att: Data Protection, Óðinshædd 5, Postboks 3098, FO-100 Tórshavn.

You can also contact our customer care department directly. See more on www.effo.fo

Changes to this privacy policy

We may periodically update this statement. For visitors to our websites, an updated statement will always be available on the website.

This privacy policy is valid from the 1^st of January 2021.