Privacy Policy
Last updated: July 30, 2026
Effective from: May 17, 2026
Version 3.0
1. Introduction
ClearNord AS respects your privacy and is committed to protecting personal data.
This privacy policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how long we retain it, and what rights you have.
ClearNord processes personal data in two different roles:
As the person responsible for treatment: When we determine the purpose and means of processing personal data. This applies to website visitors, individuals who contact us, individuals who book meetings, business contacts, suppliers, contractors, and customer representatives.
As a data processor: When we process personal data on behalf of a client. This can happen when a client sends us documents or information for translation, linguistic compliance review, AI governance consulting, or related services. In these cases, the client remains the data controller, and ClearNord acts as a data processor.
This statement primarily describes our activities as a data controller. Our activities as a data processor are summarized in point 11.
2. Who We Are
ClearNord AS
Business Address: Karl Johans gate 25, 0159 Oslo, Norway
Organization number: 936 547 435
Data Protection Contact Person: privacy@clearnord.no
General contact: info@clearnord.no
ClearNord AS is the data controller for the processing described in this statement, unless otherwise stated.
3. What personal data we collect
We only collect personal data that is necessary for the purposes described in this statement.
Website visitors
When you visit clearnord.no, we may process:
IP address
Network type and device information
Visited pages
Referrer URL
Time and date of visit
Cookie Consent Choice
Basic security logs for the website
We use a self-hosted Matomo installation on clearnord.no for website analytics. Matomo is configured without cookies for analysis, and IP addresses are masked by removing the last two bytes before the address is stored. We use Complianz to manage cookie preferences. More information can be found in section 6 and in our cookie policy.
Contact forms, email, and meeting bookings
When you contact us or book a meeting, we may process:
Name
Email address
Organization
Role or title
Telephone number, if provided
Message content
Date, time, and time zone of the meeting
Information you provide in the booking form
We use Cal.eu for meeting booking. Meetings are held through Microsoft Teams. We use Microsoft 365 services for email, meetings, documents, collaboration, and internal operations.
Checklist and email updates
When you request to have a checklist sent to you or sign up for email updates, we may process:
• Email address
• Name, if provided
• Business, if you provide it
• Which form or resource the registration applies to
• Date and time of registration and email confirmation
• Consent, subscription, and unsubscribe status
• Technical information related to the registration, such as IP address, approximate country or timezone, and browser or device information
• Delivery status, returns, complaints, opens, and link clicks, if such tracking is enabled
We use MailerLite for embedded forms, double email confirmation, recipient list management, and email campaigns. You only become an active recipient after you have confirmed your registration via email.
If you request the checklist without consenting to professional updates, we will use the information only to deliver the resource and manage your request.
Business contacts and potential customers
We can process:
Name
Work email address
Work phone number, if provided or publicly available
Employer and role
LinkedIn or public professional profile, if relevant
Notes from meetings or conversations
Communication History
This information may come directly from you, official professional sources, referrals, events, or general business communications.
Customers and customer contacts
For customers and customer representatives, we can process:
Name
Work email address
Work phone number
Role or title
Organization details
Contract and Project Information
Invoice details
Communication History
Service Delivery History
Personal data found in customer documents is handled in our capacity as a data processor, as described in section 11.
Suppliers and contractors
For suppliers, contractors, proofreaders, consultants, and service providers, we can process:
Name
Contact Information
Role or company
Contract information
Invoice and payment information
Communication History
Job seekers
If we recruit employees or contractors, we may process application-related information such as CVs, applications, contact details, references, interview notes, and related recruitment documents. We may provide a separate privacy statement for applicants in connection with recruitment.
4. Why we use personal data
We process personal data for the following purposes:
- Operating, securing, and improving our website
- Responding to inquiries
- To schedule meetings
- To deliver services to customers
- Customer relationship management
- To prepare contracts, offers, and invoices
- Managing suppliers and contractors
- Fulfilling accounting, tax, legal, and regulatory obligations
- To safeguard our rights and defend against legal claims
- Managing cookie consents and preferences
- Understanding basic website use through privacy-neutral analysis
- Sending resources you requested, like ClearNord's checklist
- Managing double email confirmation and recipient lists
- Sending updates on the regulatory map
- Sending professional updates where you have consented to this
- To document consent, unsubscription, and communication preferences
- Preventing misuse of the forms
- To check delivery and understand the use of the shipments, if such measurement is enabled
We do not sell personal information.
We do not share personal data with advertising networks.
We do not use customer data to train AI models for general resale.
5. Legal basis for processing
We process personal data on the basis of the following provisions in the General Data Protection Regulation (GDPR):
Agreement or Pre-contractual Measures When we respond to inquiries, prepare quotes, deliver services, manage meetings, or collaborate with suppliers and contractors.
Legal obligation When we need to store accounting documentation, respond to legal orders, or comply with tax and regulatory requirements.
- Consent When you request to have the checklist sent to you, sign up for updates on the regulatory map, or consent to other professional email updates.
- Legitimate interest When we protect the forms against misuse, control the delivery of mailings, and store the necessary documentation of consent and unsubscribes.
You may withdraw your consent at any time by using the unsubscribe link in an email or by contacting us at privacy@clearnord.no. Withdrawal does not affect the lawfulness of the processing already carried out.
6. Analytics and Cookies
6. Analytics and Cookies
ClearNord uses Matomo to understand basic usage of clearnord.no, including page views, time of visits, referral address, and browser and device type. The information is used only to improve the website's content, usability, and technical operation. We do not use analytics data for advertising, behavioral profiling, or cross-site tracking.
Matomo is self-hosted in ClearNord's web environment at clearnord.no. Matomo is configured without cookies for analytics. IP addresses are masked by removing the last two bytes before the address is stored in Matomo.
Analytics data is not sent to Matomo Cloud or other external analytics services. We do not share analytics data with third parties for their own purposes. Hostinger processes data only to the extent necessary to provide hosting and technical infrastructure, as described in section 7. Analytics data is not transferred outside the EEA.
Raw analytics data at the individual visit and action level is automatically deleted after 12 months. Aggregated statistical reports that do not show individual visits are retained for long-term comparisons.
Complianz is used to manage and remember choices related to cookies. Matomo sets no cookies for analytics. The opt-out function itself may store a necessary first-party cookie to remember your choice. This is not used for analytics.
– Opt out of Matomo analytics
You can choose at any time to exclude your visits from the Matomo statistics by using the control below. The choice applies to the browser and device you are using. If you clear your browser data or use a different browser or device, you may need to opt out of the analysis again.
You can choose to prevent this website from collecting and analyzing the actions you take here. This will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.
Details about cookies and how to manage your choices can be found in our cookie policy.
7. Service Providers
We use trusted service providers to operate our website and business.
These include:
| Supplier | Purpose | Notes |
| Microsoft 365 | Email, Microsoft Teams meetings, SharePoint, Microsoft Lists, Microsoft Forms, Power Automate, OneDrive, document management, collaboration, and internal operations | Our Microsoft tenant is configured with Norway as the data region |
| Cal.eu | Meeting booking | Used for scheduling only. Meetings are held in Microsoft Teams |
| Hostinger | Website hosting and technical infrastructure, including the operation of the self-hosted Matomo installation | Processing and storage take place within the EEA |
| Complianz | Cookie Consent Management | Consent documentation is stored locally on our website |
| Hostinger | Website hosting and technical infrastructure, based in the EU | Used to operate clearnord.no |
| Accounting, legal, and consulting services | Business management, legal assessment, bookkeeping, and professional advice | Used where necessary for business operations |
| MailerLite Limited | Embedded forms, double email confirmation, recipient lists, automations, and email broadcasts | Processes subscriber information on behalf of ClearNord. For customers in the EEA, the contracting party is established in Ireland. |
Where required, these vendors are bound by agreements that restrict how they can process personal data.
We do not sell personal data. We do not share personal data with advertising networks. We do not use customer data to train AI models for general resale.
8. International data transfers
ClearNord's standard approach is to use services based in or configured for the EU/EEA where practically possible.
Our Microsoft 365 tenant is configured with Norway as the data region. Cal.eu is used for meeting booking, and Microsoft Teams is used for conducting the meetings. The self-hosted Matomo installation and analytics database are hosted in ClearNord's web environment at clearnord.no. Analytics data is not sent to Matomo Cloud or other external analytics services, and analytics data is not transferred outside the EEA. Complianz consent documentation is stored locally on our website.
MailerLite Limited is established in Ireland. MailerLite states that data for the new MailerLite service is stored in a Google Cloud data center in the Netherlands. MailerLite may use sub-processors and involve processing or technical access from other countries. Any transfers outside the EEA shall be covered by valid transfer mechanisms, including adequacy decisions or EU standard contractual clauses. MailerLite Limited is established in Ireland. MailerLite states that data for the new MailerLite service is stored in a Google Cloud data center in the Netherlands. MailerLite may use sub-processors and involve processing or technical access from other countries. Any transfers outside the EEA shall be covered by valid transfer mechanisms, including adequacy decisions or EU standard contractual clauses.
Some service providers may be part of international groups or involve user support, technical access, or processing from locations outside the EEA. If personal data is transferred outside the EEA, we will use appropriate safeguards in accordance with Chapter V of the GDPR, such as adequacy decisions, EU Standard Contractual Clauses, the EU-U.S. Data Privacy Framework where applicable, or other lawful transfer mechanisms.
9. Data Security
We use technical and organizational measures designed to protect personal data.
This includes:
Access control
The principle of least privilege
Multi-factor authentication where supported
Encryption in transit
A Microsoft 365 tenant configured with Norway as the data region
Microsoft Teams for meetings
SharePoint, Microsoft Lists, Microsoft Forms, Power Automate, Outlook, and OneDrive for controlled operational workflows
Controlled document management
Internal access restrictions
Evaluation of Service Providers
Backup and restore procedures
Incident Management Procedures
If we become aware of a personal data security breach that is likely to result in a risk to the rights and freedoms of individuals, we will handle the incident in accordance with the requirements of the GDPR, including notification to the Norwegian Data Protection Authority and the affected individuals where required.
10. How long we store personal data
We store personal data only as long as it is necessary for the purposes described in this statement, unless a longer retention period is required by law.
Typical storage periods include:
- Website security logs: Up to 90 days
Raw analysis data in Matomo: Automatically deleted after 12 months
Aggregated statistical reports from Matomo: Retained for long-term comparisons and does not show individual visits
- Cookie Consent Documentation Up to 2 years
- Inquiries and meeting documentation: Up to 2 years from last contact
- Business contacts: Up to 3 years from last meaningful contact, unless you object to the processing earlier
- Customer contracts and accounting documentation: According to the requirements of Norwegian accounting and bookkeeping legislation
- Supplier and contractor documentation: As long as it is necessary for contractual, accounting, and legal purposes
- Recruitment Documentation: Normally up to 6 months after the hiring process has concluded, unless you consent to longer retention
- Unconfirmed subscribers in MailerLite: Up to 30 days
- People who have only requested the checklist: Up to 90 days after delivery
- Email update recipients: Until consent is withdrawn, or normally up to 24 months after the last meaningful activity
- Delivery and engagement data: Normally up to 24 months
- Unsubscribed recipients: Necessary reservation information may be stored for as long as necessary to ensure that the person is not signed up again without a valid basis. Other information is deleted or anonymized when it is no longer necessary.
The customer's project data is handled in accordance with the relevant contract and data processing agreement.
11. Customer Documents and the Role of the Data Processor
When ClearNord processes customer documents or project information on behalf of a customer, the customer is normally the data controller and ClearNord is the data processor.
This may include documents sent to us for:
AI Governance Consulting
Implementation Planning for Responsible AI
Review of linguistic compliance
Pilot projects for translation workflow
Human quality-assured translation
Terminology or quality review
Related consulting services
In this role:
Do we only act according to the customer's documented instructions
Are we only using the data to deliver the agreed-upon service
Are we not using customer data to train AI models
Are we limiting access to people who need it for the mission?
Are we using Microsoft 365 services for controlled document management, including Microsoft Forms, SharePoint, Microsoft Lists, Power Automate, Outlook, Teams, and OneDrive where appropriate?
Is our Microsoft tenant configured with Norway as the data region
Do we delete or return customer data in accordance with the contract and the data processing agreement?
Do we assist the customer in answering inquiries from registered users when required?
The detailed terms and conditions are set out in the data processing agreement signed with the customer before processing commences.
If your personal data appears in documents sent to ClearNord by a customer, you should normally contact that customer to exercise your rights. We will assist the customer as needed.
12. How we use AI
ClearNord specializes in AI-powered translation, language workflows, and management consulting. We take a cautious approach when personal data is involved.
Our principles are:
We do not use public consumer AI tools to process customer documents containing personal data. Any exceptions will require customer written instructions, a legal assessment, documented security measures, and appropriate contractual terms.
We do not allow customer data to be used for AI model training.
We use human quality assurance for translations and language-related deliverables where quality, context, tone, legal meaning, or risk associated with public communication is of importance.
We do not make decisions based solely on automated processing, which have legal or similarly significant effects on individuals.
Given that AI processing can pose a high risk to individuals, we are considering whether a Data Protection Impact Assessment (DPIA) is necessary.
Our AI tools, infrastructure, and sub-processors may change as ClearNord evolves. We will update this statement and our customer agreements as needed.
13. Your Rights
You have rights under the GDPR and the Norwegian Personal Data Act.
Depending on the situation, you may be entitled to:
Request access to your personal data
Correction of incomplete or incorrect information
Cancel delete
Limit treatment
Objecting to processing based on legitimate interests
Withdraw consent
Data portability
Object to direct marketing
Do not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you
- All email updates include an unsubscribe link. You can use this link to stop future mailings without contacting us directly. You can also contact privacy@clearnord.no for access, correction, deletion, or other privacy-related requests.
To exercise your rights, contact us at:
privacy@clearnord.no
We normally reply within one month. If a request is complex, we may extend the response period in accordance with GDPR.
We may ask you to confirm your identity before we answer your request.
14. Complainant
If you believe we have not handled your personal data correctly, you can contact us at:
privacy@clearnord.no
You also have the right to complain to the Norwegian Data Protection Authority.
15. Data Protection Contact Point
ClearNord has not appointed a formal Data Protection Officer (DPO) at this time. Based on our current size, services, and processing activities, we assess that a formal appointment of a Data Protection Officer is not mandatory at present.
We consider this on an ongoing basis as our services, customers, and processing activities evolve, especially if we start processing sensitive personal data or special categories of personal data on a larger scale.
Privacy issues are handled by:
Adam Taha, General Manager
privacy@clearnord.no
16. Barn
Our website and services are not directed at children. We do not knowingly collect personal information from children through our website or our contact forms.
If you believe a child has provided personal data to us, please contact us at privacy@clearnord.no.
17. Changes to this statement
We may update this privacy policy when our services, tools, suppliers, or legal obligations change.
The latest version will always be available at clearnord.no. The «Last updated» date shows when the declaration was last changed.
In the event of significant changes that affect customers or ongoing services, we will provide notice where required.
18. Contact
ClearNord AS
Karl Johans gate 25
0159 Oslo
Norway
Organization number: 936 547 435
Data Protection Contact Person: privacy@clearnord.no
General contact: info@clearnord.no
Regulatory authority The Data Inspectorate
Website datatilsynet.no
