Privacy Policy
Privacy Policy
Embedded Files
Last updated: 11.09.2025
1. OVERVIEW
This Privacy Policy ("Privacy Policy") is prepared by Stormy AS ("Stormy", "we", "our" or "us"), incorporated
under the laws of Norway, to ensure that you receive the information we are required to provide to you, and
which is necessary for you to exercise your rights under the General Data Protection Regulation (the "GDPR") and
the Norwegian data protection legislation (together "Data Protection Legislation").
This Privacy Policy describes how we process personal data about you, the purpose of our processing activities,
and the legal basis for our processing activities when you use the Stormy platform (the "Platform"). Furthermore,
this Privacy Policy provides you with information about your rights under applicable data protection legislation
and other relevant information relating to our processing of your personal data.
2. CONTACT INFORMATION
The data controller for the processing of your personal data is Stormy. If you have any questions about this
Privacy Policy, including how we process personal data, or would like to submit a request to exercise your rights,
please contact us at:
Stormy AS
Svingen 5, 0196 Oslo
3. WHAT IS PERSONAL DATA?
Personal data means any information relating to an identified or identifiable natural person (a "Data Subject").
Your name, phone number, address and e-mail address are examples of information that generally is regarded
as personal data. Depending on the circumstances, IP-addresses and similar identifiers may also constitute
personal data.
4. WHAT PERSONAL DATA DO WE PROCESS?
The list below stipulates the categories of personal data that we process and the purposes these personal data
are processed for:
➢ Personal details and contact information. For example, name, email address, username, gender etc.
We process these personal data to allow you to register an account with us and to provide you with
access thereto.
➢ Correspondence. When you contact us we will process your account information such as your name
and username and any information you provide us with in the correspondence. We process this
information to ensure that we are able to respond to your inquiry and improve our services as relevant.
➢ Views and opinions. Where you share your views and opinions about us either directly with us or by
publishing this publicly, we will process this information. We process this information to improve our
services.
➢ Content information. Where you share personal data such names, location, metadata, photos, videos
or other personal data on the Platform we will process this information as it is stored on the Platform
and in our database. Where you choose to do so, this may include special categories of personal data
such as information about religious beliefs, political views, health and sexual orientation. Please be
mindful at all times of what information you choose to make publicly available to ensure your own safety
and to protect your private life.
➢ Information others share about you. Where other users comment on your content, share photos of
you or otherwise provide information about you, we will also process this personal data.
➢ IP-addresses, meta data and similar identifiers. We process these personal data to generate
statistics, analysis and reports in order to improve the functionality and performance of our services.
This will also include processing information about your interaction with the Stormy website and app.
However, the personal data will not be used to analyse user behaviour at an individual level.
➢ Diagnostics provider. We use Google Crashlytics to collect technical information about app errors and
crashes. This is necessary to identify and fix problems, and to improve the stability and security of the
Platform. Crash reports may include device information such as model, operating system version, and
technical details at the time of the crash. For more information, please see Google Privacy Policy.
➢ Marketing and personalisation of content. We process personal data in order to personalise the
content you see on the Platform and the communication you receive from us. To do so we analyse your
behaviour and interaction with our Platform, the pages you visit to tailor the content you receive. This
helps us ensure that the information and offers you receive are relevant to your interests. To improve
the effectiveness of our marketing efforts, we use market segmentation. This involves dividing our
customer base into distinct groups based on various criteria such as demographics, interests, and
behaviours. By doing so, we can create targeted marketing campaigns and personalisation of content
and recommendations that resonate with specific segments, leading to more efficient and impactful
marketing. We may also utilise other digital marketing tools such as TikTok, Snapchat and Instagram to
reach and engage with our audience (for more information on how we use social media accounts see
Section 10 below). Marketing on behalf of third parties is based on your consent. If you do not consent
to personalised marketing as described above, or if you withdraw your consent, you will still see
advertisements on the platform – however these will not be tailored to you.
This personal data will be processed with the use of artificial intelligence system(s) to ensure that we are
able to offer content that is of interest to you.
Our aim with providing the Platform is to provide you with a social media platform that is both engaging
and better for you. The Platform is therefore based on an ethical and algorithm that prioritizes use-
centric experiences. It is designed to be inclusive and supportive, ensuring a mindful and responsible
approach to social media interactions.
Mindfulness in our approach means that we continuously evaluate the impact of our algorithm on users,
making adjustments to enhance their overall experience. We are committed to responsible practices,
ensuring that our technology respects user privacy and data security.
➢ Ensuring safety and security. We may process personal data to verify accounts and activity so that we
may combat harmful conduct, detect spam an ensure that our Platform is used in compliance with our
safety and security standards.
Depending on the circumstances, we may also process other categories of personal data, and/or the above listed
personal data for other purposes. For example, processing of personal data can be necessary for book keeping
purposes or to defend Stormy's interests in case of a litigation or legal claim.
You may at any time request confirmation and/or information regarding the personal data which we process
about you by contacting us as described above.
5. FROM WHERE DO WE OBTAIN PERSONAL DATA?
We collect the personal data described in Section 4 above from the following sources:
➢ You, when you register and use your user account. You will also provide us with information when you
publish content on the Platform.
➢ Other users of the Platform, who share information about you.
6. WHAT IS OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA?
We base our processing of personal data on the legal bases set forth below.
We base our processing of personal data primarily on legitimate interests pursuant to article 6 (1) (f) of the GDPR.
The legitimate interests are further described below:
➢ Correspondence. We have a legitimate interest in processing your personal data so that we can respond
to your inquires or to provide you with necessary information.
➢ Views and opinions. We have a legitimate interest in processing your personal data to ensure that we
can respond to your views and opinions as relevant and improve our services.
➢ Content information and information others share about you. We have a legitimate interest in
processing your personal data to ensure the proper functioning of our Platform.
➢ IP-address, meta data and other identifiers. We have a legitimate interest in using these personal
data to simplify the use of our services and to generate statistics about the use of our services and
content therein, in order for us to develop and enhance our services further.
➢ Behavioural and preference data. We process personal data regarding your behaviour on the
Platform, in line with our legitimate interests in providing you with our services and improving and
expanding our service offerings pursuant to article 6(1)(f) of the GDPR. Where any such processing
requires your consent, we will have collected your consent pursuant to article 6 (1) (a) of the GDPR.
➢ Marketing and personalisation of content. Where you are an existing customer, we process personal
data to provide you with direct marketing communications based on our legitimate interest in providing
you with information about our services. Otherwise, we process personal data for marketing based on
your consent pursuant to article 6 (1) (a) of the GDPR.
We also base our processing of personal data on our contract with you pursuant to article 6 (1) (b) of the GDPR,
for processing:
➢ Personal details and contact information. To ensure that we are able to provide you with access to
our platform we use your contact details to provide you with access to our services.
We may also process personal data based on your consent pursuant to article 6 (1) (a) of the GDPR, for processing:
➢ Personal details. We may process personal data such as name, location, age and other relevant
personal data to provide you with more relevant marketing. This may be marketing provided through
the Platform or through electronic communication from us. Where you have consented to any such
processing you may revoke your consent at any time.
We also base our processing of personal data on your explicit consent pursuant to article 9 (2) (a), for processing:
➢ Content information. Where you choose to upload personal data which falls within a special category
of personal data such as health, sexual orientation, race, political views and religious beliefs, the act of
you uploading such personal data to the Platform shall constitute your consent to us processing the
relevant personal data.
We may process personal data based on necessity to comply with legal obligation to which we are subject article
6 (1) (c) of the GDPR, for processing:
➢ Personal details. Where relevant, and where we have a legally binding obligation to do so, we may
disclose your personal data to ensure compliance with legal obligations, for example to public
authorities or courts of law. Where relevant, we will only provide personal data in such cases where we
have a good-faith belief that the law requires us to provide the personal data and that the requirement
is consistent with internationally recognised standards.
➢ Content information and information others share about you. Where relevant, and where we have
an obligation to do so, we may share your personal data to ensure compliance with legal obligations.
7. OUR USE OF COOKIES
Cookies are small pieces of text used to store information on web browsers and apps. They are widely used to
store and receive information to make websites and apps work, or work more efficiently, as well as to provide
information to the owners of the site and app. Please find more information on our use of cookies and how you
manage your cookie settings here. For information about processing of personal data through cookies for
marketing purposes, please see section 9 below.
8. ADJUSTMENTS TO THE PRIVACY SETTINGS
You may also use the settings of the Stormy app to adjust the personal data that is processed about you. You
can do this by accessing the settings in your profile, located in the top right corner.
9. TO WHOM DO WE DISCLOSE PERSONAL DATA?
We use the following service providers in connection with the processing of personal data:
➢ Marketing partners. Where we have a legitimate interest in the processing or you have provided us
with consent thereto, we will share your personal data with our marketing partners. To provide
personalised marketing, we use real-time bidding, an automated auction for ad space on Stormy. This
allows advertisers to bid for the opportunity to display relevant ads based on criteria like demographics
and browsing behaviour. For this purpose, we may use services such as Google AdMob.
➢ Suppliers. Our suppliers may process personal data on our behalf in order for them to provide us with
their services and for us to be able to provide you with the Platform.
➢ Law enforcement and governmental bodies. Where we have a legal obligation to provide law
enforcement with personal data, we may do so.
➢ Successors and acquirers. In the event of a merger, acquisition, or transfer of assets, personal data
may be disclosed to potential or actual successors, acquirers, or assignees.
Where we share personal data with our suppliers, we will have entered into data processing agreements with
them as our processors which inter alia obligates the data processor to implement technical and organisational
measures to ensure an appropriate level of security, confidentiality and integrity of the personal data, as well as
to only process the relevant personal data in accordance with data protection legislation.
We will not disclose your personal data to any other third parties than the third parties described above, unless
we are required to do so under applicable law, or if it is necessary to establish, exercise or defend legal claims.
10. USE OF SOCIAL MEDIA
Stormy has, or may in the future have, corporate accounts on several social media platforms such as X (formerly
Twitter), Instagram, Snapchat, TikTok and LinkedIn, and the processing of personal data on these platforms is
subject to the terms of use and privacy policies applicable to each platform. We use these accounts to promote
and improve our products and services, and the legal basis for this legitimate interest is based on GDPR Art.
6(1)(f). If you contact us via one of these accounts or wish to share any of the content we publish, we will be able
to see basic account information such as name and email address. We will respond to you on the same platform
and process personal data in connection with such communication.
You are free to stop following our accounts or delete your comments and messages. Please note that even if you
stop following our accounts, this does not result in the deletion of your personal data. Also, note that these
providers have international data transfers to the USA. We encourage you to read their privacy policies to learn
more about their processing of your personal data.
11. DO WE TRANSFER PERSONAL DATA TO THIRD COUNTRIES?
The Platform is a global platform and we, therefore, process personal data globally. This may involve the
processing of personal data in countries where data protection laws are not as comprehensive as in your country
of residence. We do, however, take steps to ensure that your personal data is protected at all times.
If you reside in the EU/EEA your personal data may therefore be sent or processed in a country outside the
European Economic Area ("EEA"). The country may not be on the list of countries deemed as adequate by the
European Commission. However, whenever we transfer personal data to countries outside of the EEA, we take
appropriate measures, in compliance with Data Protection Legislation, to ensure that your personal data remains
protected. Such measures include the use of Standard Contractual Clauses to safeguard the transfer of data
outside of the EEA.
Where we use sub-processors with headquarters outside of the EEA, we always aim to utilise the respective
European data centres for such processing. We enter into data processing agreements with these data
processors to ensure that they process personal data in accordance with Data Protection Legislation.
To request more information or to obtain a copy of the contractual agreements in place, please contact us by
using the contact information above.
12. THE PROCESSING OF CHILDREN'S PERSONAL DATA
Stormy has an age restriction for access to the Platform. The Platform is not directed to children who:
➢ are under the age of 13 years;
➢ are at an age which makes it illegal to process their personal data, or
➢ requires parental consent to process their personal data.
We do not knowingly collect or use personal data from children under the applicable age limit. If you are under
the age limit, do not use the Platform, and do not provide any personal data to us.
If you are a parent of a child under the age limit and become aware that your child has provided personal data
to Stormy, contact us using the contact information listed above.
13. FOR HOW LONG DO WE PROCESS PERSONAL DATA?
As a general rule, we will delete or anonymise personal data when they are no longer necessary in relation to the
purposes for which they were collected or otherwise processed. If we process personal data to comply with our
legal obligations, we will delete or anonymise the personal data when it is no longer necessary to process the
data to comply with the relevant legal obligations.
Generally we will process your personal data and account information for as long as you have an account with
us. If you choose to delete content or your account this will be deleted permanently. Any such deletion may take
up to 3-months to ensure that the content and account information is deleted from our servers.
Do note that where others publish personal data relating to you, for example, a photo of you, this personal data
will not be automatically deleted upon deletion of your account. We note that you can use your right to be
forgotten should you wish to have personal data published about you deleted. Please see more information
about this in Section 14 below.
If any of your personal data includes financial transactions that we are required to process for bookkeeping
purposes, we will process this for up to 5 years in order to comply with our legal obligations. Where there is a
legal dispute we will keep this information for as long as required to administer and handle the legal dispute.
For information about the processing time for processing related to the use of cookies, please see our cookie
policy here.
14. SECURITY
As a controller, we are responsible for the security and confidentiality of the personal data we process. We are
furthermore responsible for implementing appropriate technical and organisational measures to ensure an
appropriate level of security for the processing.
We are, for security reasons, not entitled to disclose detailed information on the security measures which we
have implemented. However, we have implemented measures, policies and routines to ensure the security of
our processing. Some of the measures we have implemented include:
➢ Access control. Data stored in our system can only be accessed by individuals whose job duties require
data management. User authorisations are assigned based on specific job descriptions, ensuring that
access is limited to relevant data.
➢ System protection. Stormy's systems is safeguarded from external threats, with servers protected by
firewalls. Communication within the system is conducted using encrypted connections, adding an extra
layer of security.
➢ Data backup and storage. Application data is backed up at least once daily, and database data and
backups are stored in multiple physically separate locations. Backup copies are always encrypted and
protected using various technical measures to prevent unauthorised access.
These security measures are in place to provide a high level of protection for your data. We are committed to
maintaining the confidentiality and integrity of your information and continuously improving our security
practices to meet evolving threats and industry standards.
15. YOUR RIGHTS
You have the following rights when we process personal data about you:
➢ Access. You may contact us if you want to obtain confirmation with respect to whether or not we are
processing your personal data, as well as access to and further information regarding our processing of
your personal data. You may also request a copy of the personal data we are processing about you.
➢ Correcting personal data (rectification). You may ask us to rectify any errors in your personal data.
➢ Erasure (the right to be forgotten). You may ask us to erase your personal data, which request we will
respect and comply with.
➢ Restriction. You may ask us to restrict the processing of your personal data.
➢ Object. You are entitled to object to certain processing activities. You are furthermore, on grounds
relating to your particular situation (for example, a specific need for protection of your identity), entitled
to object to processing of personal data based on legitimate interests, which we will comply with, unless
there exists compelling legitimate grounds for our processing which override your interest, or if our
processing is necessary for the establishment, exercise or defence of legal claims.
➢ Data portability. You may ask us to provide you or others with your personal data in a structured,
commonly used and machine-readable format.
➢ Withdrawing consent. If we are processing your personal data based on your consent, you have the
right to withdraw that consent at any time.
Please note that the above rights may be subject to further exceptions and limitations in accordance with the
data protection legislation.
You may contact us if you wish to exercise any of the above rights. Please note that we may request additional
information from you if such information is necessary to confirm your identity.
16. QUESTIONS AND COMPLAINTS
If you have additional questions on how we process personal data, or are dissatisfied with our processing, you
are welcome to contact us. Please find our Contact Information above.
You may also lodge a complaint with the relevant supervisory authority. Please click here to access the contact
information to the Norwegian Data Protection Authority. The contact details for all EU Supervisory Authorities
can be found here.
Further details on your rights are available in the Data Protection Act and the General Data Protection Regulation
(GDPR), which can be accessed by clicking here.
17. CHANGES
We may update the Privacy Policy from time to time. The Privacy Policy will, for example, be updated to comply
with any legislative amendments or if we make changes to our processing of personal data.
The most recently updated version of the Privacy Policy will always be available at www.stormyapp.io/privacy.
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