Privacy Policy for Fish Pool ASA

Fish Pool is licenced as an exchange by the Norwegian Ministry of Finance. It is crucial that we enjoy the confidence and trust from our customers and the outside world. Therefore, we are committed to safeguard your privacy.

Fish Pool is responsible for the processing of personal data by the organization. This privacy policy contains information that you are entitled to when you use our webpages as well as general information about how we treat personal data.

Fish Pool saves information under different legislations:

  1. Fish Pool saves information related to placing orders and entering trades under the Norwegian Exchange Act and associated regulations for a minimum period of 5 years.
  2. Fish Pool saves information related to accounting under the Norwegian Accounting Act and associated regulations for a minimum period of 5 years.
  3. Fish Pool saves contact details and history about a person for as long as a the company the person works with is a member of Fish Pool or a Fish Pool employee keeps in contact with the person. Fish Pool deletes contact details and history associated with a non-member person 2 years after visible contact with the person in the CRM system.

Fish Pool saves other information connected to a person under GDPR (General Data Protection Regulation) for a maximum period of two years.

Fish Pool does not collect or save sensitive information.

Fish Pool webpages

Fish Pool runs two webpages: www.fishpool.eu and www.salmonprice.com. It is voluntary for those who visit the web sites to provide personal information related to services, such as receiving newsletters. The treatment basis is the consent of the individual, unless otherwise specified.

Oslo Market Solutions is Fish Pool’s data processor and is our supplier for site development and maintenance. Information collected in connection with site operation is stored on servers operated by the service provider. Only Fish Pool and Oslo Market Solutions have access to the information collected. Separate data-processing agreements between Fish Pool and Oslo Market Solutions regulates what information the providers have access to and how data should be processed.

Cookies

Cookies are small text files that are placed on your computer when you download a webpage, used for statistics and to support you as a user. By using www.fishpool.eu, you agree that cookies are stored – since most browsers are set up to accept cookies automatically. If you do not accept our use of cookies, you may withdraw your consent by changing your browser settings. Please note that this may mean that our website will not function properly.

You can reserve yourself against using cookies from Google Analytics here.

Home page www.fishpool.eu

Web Analytics

Fish Pool collects data about visitors to www.fishpool.eu using Google Analytics. The purpose of this is to produce statistics to improve and develop the website. An example of what we use the statistics for is how many people visit different pages, how long the visit lasts, which sites users are coming from and which browsers are used. The data are processed in anonymised and aggregated form. This means we cannot track the data we collect back to the individual user.

Search

Fish Pool may store which key words users apply in the search field at www.fishpool.eu. The purpose is to improve our website. The information is stored in a separate database, and only saved in aggregated form. Only the key words are saved and they cannot be linked to other information about the users, such as the IP address.

Trading system www.salmonprice.com

My Page

At My Page all users of www.salmonprice.com can see the main information Fish Pool have saved about you. The minimum information Fish Pool needs to create a user is your email address. The purpose is to be able to send you the password you need to log in. If you choose to terminate your account, the personal information about you will be deleted within one year unless other laws/regulations require Fish Pool to save the information further.

Weekly reports

Fish Pool sends two weekly reports. For this purpose, you must register your e-mail address. The e-mail address is stored for as long as you continue to receive the weekly reports. The e-mail address will be deleted when you have unsubscribed. To unsubscribe please follow the link in the email containing the weekly report or send your request to info@fishpool.eu.

Reporting to the authorities

Fish Pool is obliged to upload daily and weekly reports about companies trading and holding positions in the financial instrument to Norwegian and European financial authorities under MiFID II. Fish Pool must also present necessary information to Norwegian financial authorities when requested. This includes information about the person who entered an order or executed a trade.

In the authority reports, Fish Pool must include information about the persons that have placed orders or entered trades on behalf of companies trading at the exchange. Fish Pool must therefore store the required information about all persons with authority to place orders and enter trades and/or decide that an order or trade shall be placed/entered. Fish Pool name such authority Trader, Responsible Person and/or Decision Maker.

Fish Pool stores national, personal identification code for Traders, Responsible Persons and Decision Makers. The code is stored for as long as a person is authorised on behalf of a member of Fish Pool.

Fish Pool also stores information about the orders and trades a person have been involved in as Trader, Responsible Person and/or Decision maker at Fish Pools market. This information is stored for at least 5 years after settlement of the final month in each contract.

Communication and CRM system

E-mail

At Fish Pool we use e-mail and telephone as a large part of our daily work. Relevant information arising from telephone conversations and e-mail dialogues might be stored in our CRM system. Various types of personal data are stored in these systems. This is information such as name, telephone number, e-mail address, job title and other relevant information as stated in the inquiry. The retention period for this information varies, depending on the type of inquiry. Personal contact information is stored for as long as the company is member at Fish Pools market or for as long at a Fish Pool employee keeps in touch with the person. Fish Pool deletes personal contact information two years after last visible contact with a non-member person.

In addition, Fish Pool’s employees use e-mail in general dialogue with internal and external contacts. The employee is responsible for deleting messages that are no longer relevant, and at least annually review and delete unnecessary content in the e-mailbox. The maximum retention period for e-mails stored in the employees e-mailbox are ten years. Upon resignation, e-mail accounts are deleted.

Information you send by e-mail may be sent unencrypted. We therefore urge you not to send confidential or sensitive information via open e-mail without sufficient security measures, such as transport encryption, password protected files, etc.

Telephone

Information regarding telephone calls (telephone number and time of the call) to Fish Pool are logged in our telephone system and voice recording system.

Fish Pool undertake voice recording of telephone calls to and from all Fish Pool employees. Internal access to such recordings are limited to the employee in the call and one administrative user with full access to all recorded phone calls. In addition, Fish Pools employees may update a white list of phone numbers without recording and may mark a phone call as private. Fish Pool has issued separate internal routines and guidelines for taped telephone calls. The voice recordings are automatically deleted after five years.

Chat services and SMS

Fish Pool uses chat services and SMS for daily contact with the market. We save information from these services when you enter orders and/or trades in our CRM system.

Members of Fish Pool and other contractual agreements

Fish Pool processes personal information for the purpose of providing service and keeping in touch with new potential clients. Additionally, we process personal information to administer and carry out obligations in relation to any agreement you may have with us.

When entering into a contract or agreement with us, you may be asked to submit personal information about yourself in order to receive or use our services or products. This information include, but is not limited to, your name, address, telephone number, job title and e-mail address. The personal information is collected only to the extent it is necessary to provide you with Fish Pools product or service. Fish Pool will keep the information as long as the membership, contract or agreement is valid. Upon termination of the contract or agreement, the information is stored for 10 years.

Market Surveillance

Fish Pool shall, pursuant to section 18 of the Exchange Regulations and Fish Pool Rulebook, carry out market surveillance. If Fish Pool suspects breach of legislation and regulations, such data may be subject to submission to the Financial Supervisory Authority of Norway in accordance with Fish Pool Rulebook. Fish Pool saves all documents and reports, including personal information, relevant in a suspected breach of legislation and regulations for 10 years or for as long as the authorities require.

List of seminar participants

When you register for a Fish Pool seminar, we need your personal information to know who is coming and to be able to contact you before and after the seminar. Fish Pool uses Oslo Børs’ IT-system provided by Pindena, where you can register for seminars by providing your name and email address.

Oslo Børs is responsible for the processing of personal information for the administration and registration of participants at Fish Pools courses. Pindena deletes the personal data one month after the course is held. Fish Pool may download the name and firm of the attendees and store this as an excel spreadsheet. Fish Pools processing of personal data in connection with this service is to fulfill an agreement with the participant.

Recruitment

Fish Pool process personal information relevant to the recruitment processes to identify and evaluate candidates for potential employment.

Fish Pool is responsible for the processing of personal information for the administration and registration of job applicants. Fish Pool uses Oslo Børs’ recruitment system and all job applications are recorded here. The system is managed by the data processor, HR Manager AS. HR manager AS shall use the information for the sole purpose of handling data in connection with administration of the recruitment system.

For Fish Pool to process the personal data in this regard you will be asked to provide a freely given, specific, informed and unambiguous consent to this. The data are automatically deleted after a period of two years. We may desire to retain the personal data to consider candidates for future employment opportunities. In such case, we will seek your consent to retain the data for two additional years.

Security

Fish Pool takes appropriate technical and organizational security measures in order to protect personal data against loss, misuse, alteration and destruction. These include arrangements to prevent unauthorized access to our systems as well as arrangements ensuring personal data are stored in physically secure accommodation.

Access, correction and deletion

Data subjects have a right to access, correct and delete personal data processed by Fish Pool related to the data subject in some cases. If you wish to access your personal data, or have your data corrected or deleted, please send your request via e-mail to info@fishpool.eu with a description of the relevant processing activity, related personal data and the basis for your request.

The right to access, correct and delete personal data processed by Fish Pool does not apply to data which is required to keep secret for the purpose of prevention, investigation, disclosure and prosecution of criminal offenses, or data which by law or in accordance with law is subject to confidentiality.

Where Fish Pool process personal data, based on consent, data subjects can withdraw the consent at any time. To do so, please send your request via e-mail to info@fishpool.eu with a description of the relevant processing activity, related personal data and the basis for your request.

Access by third parties

Fish Pool will not disclose information about you to third parties without your consent, unless such disclosure is statutory or necessary to fulfill an agreement with you.

Questions

Should you have any questions about this privacy policy, or any questions regarding how Fish Pool processes personal data, please contact us via e-mail info@fishpool.eu.