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Privacy policy and cookies

Processing of personal data by Kluge Advokatfirma AS

When you use our website and/or are in contact with us in connection with registering for one of our events, receiving our newsletters or sending us an application, Kluge processes personal data about you. Our usage is in accordance with the Norwegian Personal Data Act of 2018, which implements the EU’s General Data Protection Regulation (hereafter referred to as “GDPR”).

Below you will find information regarding the personal data that is collected, why we collect it, and your rights relating to the processing of your personal data.

The data controller for the personal data we process is Kluge Advokatfirma, in the person of Managing Partner Bjørnar Alterskjær. The contact information for Kluge Advokatfirma is:

Address: PO Box 277, NO-4066 Stavanger, Norway
Telephone: +47 51 82 29 00
BRN: 913 296 117

For any questions you might have regarding our processing of your personal data, contact Ove André Vanebo |  | +47 915 49 378.

Why we collect personal data and what information we collect

We collect and use your personal data for different purposes, depending on who you are and how we come into contact with you. Here is a list of the personal data we collect for the following purposes:

  1. For marketing and sending out newsletters and information about our company: e-mail address. The personal data is processed on the basis of your consent, cf. point a of Article 6(1) of GDPR. In cases where we do not use consent as a basis for processing, we will send you the material in accordance with legitimate interests, cf. point f of Article 6(1) of GDPR. We consider the legitimate interests to be that we can inform you about our work and other relevant information which may also be of interest to you. In addition, this gives us the opportunity to generate more commercial activity.

    We also use Messenger/ManyChat to offer you tailored content. This is a “chatbot”, an application that “responds naturally” in a conversation, either by text or voice. In connection with this, we store: first name, surname and e-mail address (which are stored in Facebook). The Messenger bot sends out automatic messages and responses to users in the Facebook feed. You give your consent to receiving more content after seeing one of the bot’s messages on Facebook, cf. point a of Article 6(1) of GDPR. In practice, you will be placed on a list of individuals who wish to receive specific content. If you unsubscribe, you will automatically be deleted from the list, which you can read more about here.
  1. When you register for one of our events: name, company, e-mail address and billing information. We register and use your personal data for such purposes as to send confirmation of registration, reminders and information after the event. Personal data is processed on the basis of legitimate interests, cf. point f of Article 6(1) of GDPR. It is in our interest to get an overview of the registrants in order to plan and improve our events.

  2. When you submit an application to Start-up Help: company name, location, contact person, position, telephone number, address, e-mail address and any personal data that may pertain to the enquiry. The processing of personal data is based on a balance of interests, cf. point f of Article 6(1) of GDPR. Our legitimate interest is to stimulate connection and build a larger network of start-up businesses, while the businesses that receive help are greatly interested in our assistance.

  3. Answering enquiries that we receive: name, telephone number, e-mail address and any other personal data that may pertain to the enquiry. The processing of personal data is based on a balance of interests, cf. point f of Article 6(1) of GDPR. We consider this to often be a necessity in order to help you with your enquiry.

  4. Recruiting for new positions with us: CV, application, certificates and references. The data is sent to us via Webcruiter. Personal data is processed on the basis of either the consent that you have given (point a of Article 6(1) of GDPR) or legitimate interests (point f of Article 6(1) of GDPR). The legitimate interests are that we wish to recruit skilled employees – a process for which we require information – and that getting a job is of great importance to you.

  5. We use cookies in order to gain information about the use of our website. We process personal data on the basis of consent as required by Section 2-7b of the Norwegian Electronic Communications Act and a balance of interests, cf. point f of Article 6(1) of GDPR. We consider this necessary for us to customise the website for our users. We also use statistical data through Google Analytics to see what our users’ interests are and how the pages are used: this enables us to focus on relevant and popular content as well as simplify the pages as much as possible.

    However, we maintain your privacy by only using the data for statistics. It is not possible to identify you as an individual through these statistics. You agree to the use of cookies through settings in your browser, and you can turn these off by changing the settings.

  6. In terms of our use of images of you on the website, such use will also be in accordance with Section 104 of the Norwegian Copyright Act, i.e. we either have consent or one of the following conditions apply:

    a) The image is of public interest;
    b) The person in the image is less important than the main content of the image;
    c) The image depicts an audience, crowd, or situations or events of public interest;
    d) A copy of the image, in the usual way, is displayed as an advert for the photographer’s business and the subject does not impose a ban; or
    e) The image is used as addressed in Section 33(2) or Section 37(3) of the Norwegian Copyright Act.

As of yet, we have no instances of automated decision-making.

Disclosure of personal data to third parties

We will not disclose your personal data to others unless there is a legal basis for such disclosure. Examples of such a basis will typically be an agreement with you or a legal requirement that instructs us to pass on the information.

Kluge uses data processors to collect, store or otherwise process personal data on our behalf. In such cases, we have entered into agreements to ensure information security in all parts of the processing. Currently, we use the following data processors:

  1. Apsis, for registration and mailing of newsletters and events.
  2. Netigate, for submitting and receiving data in connection with applications for Start-up Help.

All of our processing of personal data takes place within the EU/EEA.

Cookies and web analysis

Most browsers are set to automatically accept cookies. This improves the user experience. A cookie is a text file that is added to your browser’s memory when you visit a website. Kluge’s website uses cookies. If you do not want this, you can change your browser settings so that cookies from kluge.no are not accepted. This may, however, cause the website to not work optimally.

Use of your personal data requires your consent pursuant to Section 2-7b of the Norwegian Electronic Communications Act. Consent is given in that your web browser is set to accept cookies. If you do not want the website to store cookies, you can change the settings in your web browser. For more information on this subject, please click here (in Norwegian).

IP addresses are essentially stored in such a manner that no personal data is recorded. Where we do process personal data through the use of cookies, the lawful basis is legitimate interests (point f of Article 6(1) of GDPR). Kluge’s legitimate interest is to optimise our website and services in general, and to adapt the website to the needs of each user.

Episerver CMS

Kluge.no is built on the publishing platform Episerver CMS. The system uses various cookies to control how the content is displayed and to keep track of the various users. Episerver uses the following cookies:

  1. ASP.NET_SessionId – used to allow the site to differentiate users from one another. This cookie is automatically deleted when you close your browser.
  2. .EPiServerLogin, EPiDPCKEY and .ASPXRoles – used for logging in. These cookies are automatically deleted when you close your browser.

You can find out more about Episerver here.

Google Analytics

We use Google Analytics to collect general statistics about how the website is used so that we can improve our content. Your IP address will automatically be made anonymous so that the statistics cannot be traced back to you as an individual. The following cookies are set by Google Analytics: _utma, _utmb and _utmz.

These are third-party cookies from Google Analytics. They give us information about how our website is used (statistics).

You can find out more about Google Analytics here.

Facebook pixel

Kluge has a presence on various social media channels (at present, primarily on Facebook). In order to improve the interaction between Facebook and kluge.no, we have installed the Facebook pixel. This is a script that measures traffic across Facebook’s interface and our website. The pixel collects information from cookies stored in your web browser and sends this back to Facebook, where this information is combined with data from your Facebook profile. The information gathered relates to your user behaviour or the actions you perform, such as clicking on links. The information is only available at an anonymised and aggregated level.

We use the data collected by the Facebook pixel to supply specially tailored content to individuals who visit our website and for marketing on Facebook.

You can find out more about the Facebook pixel here.


We use Hotjar in order to better understand how you use our website, so that we can improve our services based on what proves to work well, and can change things that can be improved. We analyse where users come from (at a regional or country level), how much time is spent on the various pages and which links are clicked on, and we also count the number of visitors and differentiate between and remember the various visitors.

Hotjar uses cookies called has _ga, _gid and _gat_gtag.

You can find out more about Hotjar here.

LinkedIn Insight tag

The LinkedIn Insight tag is a piece of JavaScript code that is used on kluge.no to obtain reports and insight on visitors to the website. The LinkedIn Insight tag is used to track conversions, retarget website visitors and gain insight on individuals who interact with links.

You can find out more about LinkedIn Insight here.

Storage period

We store your personal data for as long as is necessary for the purpose of collection.

This means, for example, that personal data that we process on the basis of your consent will be deleted if you withdraw your consent, provided there is no other basis for further processing. The personal data we process to fulfil an agreement with you is deleted when the agreement is fulfilled and all of the requirements arising from the agreement are met.

The information gathered about you for statistical purposes will be manually deleted when Epinova manually reviews the solution in accordance with our maintenance agreement (“health check of the solution”).

Your rights when we process your personal data

You have the right to request access to, rectification or erasure of the personal data we process about you. Furthermore, you also have the right to restrict processing, to object to processing and to claim the right of data portability. You can read more about the content of these rights on the Norwegian Data Protection Authority’s web page on the subject here.

In order to exercise your rights, you need to contact us via e-mail at . We will respond to your enquiry as soon as possible and within 30 days at the latest.

We will ask you to confirm your identity or provide additional information before we allow you to exercise your rights in relation to us. We do this to ensure that only you are given access to your personal data, and not someone passing themselves off as you.

You may withdraw your consent for our processing of personal data at any time. The easiest way to do this is to contact us by e-mail at . We will then delete the data without undue delay unless there is another legal basis for further processing.


If you believe that our processing of personal data does not match what we have described here or otherwise violates data protection legislation, we would appreciate you contacting us as soon as possible. We will try to act on your comments as well as possible, and to the extent that we believe is reasonable based on the appropriate legislation.

You may also appeal to the Norwegian Data Protection Authority. For information about how to contact the Norwegian Data Protection Authority, please visit their website: datatilsynet.no/en.


Any changes made to our services or to the regulations governing the processing of personal data may alter the information provided here. If we have your contact information, we will notify you of these changes. Otherwise, updated information will always be readily available on our website.