Privacy

DN Media Group AS is the responsible Controller for your personal data

Revised 10.02.2025 with some clarifications on purposes and lawful bases.

[For norsk versjon, se her .]

This privacy policy applies to all our end users. We want you to have as much control over your personal data as you possibly can, and over how they are treated. You’ll find information on this in this privacy policy. You will also find contact information if you have questions about our processing of personal data. You may at any time change your privacy preferences via My page on the different publications' websites when you are logged in. Your personal data is safe with us, and we only use data for purposes that are described in this document.

1. About DN Media Group AS, the Services and registrants

1.1 Who are we?

DN Media Group AS, company registration no. 927 810 921 is a group of companies. DN Media Group AS and its subsidiaries will hereinafter be called «The Group». We publish several products and services that are delivered by DN Media Group and our subsidiaries. This privacy policy is valid when The Group process personal data about you. We process data about our users across all our products and services for different purposes – hereunder deliver the best possible services to our users and customer. We depend on your trust in how we process your personal data. This privacy policy explains why The Group gathers information about you, how that information is used, and how The Group takes your privacy into account.

1.2 The Services

The privacy policy explains how The Group and The Group's partners collect and use personal data when you register with and use our web sites and other services. The Group delivers web sites, mobile applications, newsletters and alerts, physical newspapers, conferences, network memberships, loyalty programs and job sites. Hereinafter together these are called «the Services».

Personal data used for journalistic purposes are controlled by the individual publications.

Europower has defined independent purposes for its advertising and marketing solutions activities, and personal data processed in connection with this is controlled by Europower AS, company registration number 916 055 137.

Contact information for the responsible legal entity is found on the publications’ web sites – e.g. tradewindsnews.com or upstreamonline.com. Please note that processing personal data for journalistic purposes are exempt from legal obligations in the GDPR such as rights of information, deletion and legal basis for processing.

This privacy policy also explains your privacy-related rights towards DN Media Group AS and our partners. The Services are owned and run by DN Media Group. Its registered address is Christian Krohgs gate 16, 0186 Oslo, mailing address P.O. Box 1182, 0107 Oslo, Norway. If you wish to contact the controller with any concerns you may send an email here . You can also email the privacy officer via this link .

1.3 Whose personal data we process

The Group has several categories of end users. If you visit or use the Services, you will belong to one of those categories.

The General Data Protection Regulations (“GDPR”) defines you as a «registrant» when you are an end user and an identifiable individual with personal data processed, and we use the same term here in our privacy policy.

The type of personal data we process for which users will be further described in chapter 4.

Subscribers

The Group processes the most personal data on active subscribers, those who have a subscription where they or their employer pay for the Services, and they actively use the Services. A subscriber is an active user with a DN ID, who is paying for a subscription to one of our Services.

Passive subscribers (previous subscribers)

If you have cancelled your subscription for one of The Group's Services and more than 12 months have passed since you cancelled it, you are considered a passive user. In that case, we will keep some personal data for a certain period, for exampe to facilitate re-activating the subscription easier. After that, we will keep some data as regulated by law. Other data and purposes, for example to enable sending marketing messages we will ask for your consent to store and process further.

Registered users

You can also be a registered user without having a subscription on our services. This will be the case if you are

• registered to receive newsletters
• registered for a trial access to the Services
• registered for any other service that does not require a payment.

Unregistered users

Unregistered users are those who visit any of the Services but neither register nor pay for using them. The Group processes little personal data about this category of users. In most cases this data is not tied directly to you as a person, unless you register with a user account on one of the Services.

Conference delegates or network members

If you register for a conference or network membership organized by The Group, we process data in connection with the registration for and participation at the conference or network meetings. Conferences or network meetings include digital events as webinars or networking events.

Job applicants

When you submit a job application or create a job alert throught the Jobs or Career services, you will be registered in the Service with your email address. We will also store information related to your person that you register when creating a user account.

2.2 Personalise the Services for you:

We also use data about you to be able to personalise the Services to your user profile, for example customising some of the content that is shown to you. Profiling means that we create a profile on your user, based on information we have about you and your use of the Services. Through profiling we can personalise the content, adverts and marketing of The Groups Services, for example by removing articles you already have read and to make the content more useful and interesting for you.

The lawful basis here is Legitimate interest. As a logged-in user you may at all times manage your privacy preferences and opt out of profiling if you so wish.

2.3 Ensure legal use compliant with our terms and conditions:

Data about you is also used to prevent misuse of the Services. Misuse may be attempts at logging on to other people’s accounts, trying to swindle people, “spamming”, hate messages, harassment, and other acts that are forbidden according to relevant legislation and our terms and conditions. We link to these terms and conditions in the footer of all publication pages and they apply all use of the Services.

The lawful basis we apply here is Legitimate interest.

2.4 Further develop our products and services:

The Group uses data about you and your use of the Services to make sure you get an optimal user experience, and to learn more about how we can and should develop the Services further. We do this by analyzing data about how our readers use the Services. Such aggregated data gives us insight into our readers preferences, and makes it possible to measure the effect of our product developments.

The lawful basis here is Legitimate interest.

2.5 Communicate with you regarding your subscription, editotial content and relevant offerings:

We use data about you and your use of the Services for direct communication and marketing purposes through channels like our digital platfoms, email, text messaging, push notifications, social media channels, letters and telephone calls,  unless you have opted out from such communication or in other ways have withdrawn your consent. We use behavioural data to offer products and services within our portfolio that we think will be useful for you, and to offer corporate customers an optimal level on their subscription seats.

We rely on Legitimate interest for lawful basis for this type of communication.

Please note that you cannot opt out of some types of communication. Typical examples are when you have signed up for a subscription or another product that we need to communicate with you about, for instance delivery, invoicing or payments.

The lawful basis for such communication is Agreement.

2.6 Deliver, optimise and measure the effect of advertising and other marketing solutions:

The Group is partly financed by advertising revenues and is therefore dependent on delivering, personalizing, and measuring the effect of adverts and other marketing solutions in the Services. This is done within the Group and in collaboration with third parties, as described in more detail in chapters 4-6.

Europwer AS is part of DN Media Group, but commercial activities in the field of advertising and other marketing solutions are managed independently by the subsidiary. Some processing activities are therefore to be considered as a transfer of personal data between controllers, e.g. DN Media Group AS and Europower AS. This processing consists of normal marketing activities, for example targeted advertising and information about relevant conferences, webinars and podcasts.

We also use data based on our users' behaviour to create marketing segments. This data is used by both us and our advertisers for marketing purposes on our Services. We also wish to measure the effect of the advertising and to develop new and targeted advertising products. These segments will not contain directly identifiable data on you, but enables personally optimised adverts based on demography, behaviour, the context it is shown in and technical information from your device.

Some of these adverts are based on so-called «programmatic advertising». This is an automated purchase- and supply process of digital advertising via an exchange where we make our ad impression inventory available, and the advertisers can place bids on the impressions based on their criteria. When all criteria match, the adverts will be served automatically in real-time.

We will ask for consent to store cookies that enable such automated advertising technologies, and you may change your settings at all times via a link that you will find at the bottom of all our web pages.

3. Overview of DN Media Group's legal basis for processing of personal data

Any processing of personal data requires a legal basis. This means that before The Group starts processing your personal data, we must ensure that we are entitled to carry out that processing (that The Group has a valid lawful basis). That basis may come directly from you for instance in the form of an agreement with us (for instance our subscription and user terms), or in the form of an active consent (for instance if you have accepted receiving offers via email from us while being a non-subscriber). Here is an explanation of what bases we use to process personal data and when we use them.

DN Media Group neither can, nor will we, process other personal data about you than what is expressly stated, and neither can, nor will we do it in other ways than those described in this policy.

3.1 Agreement

If you are a subscriber to or a registered user without subscription for the Services, we process personal data about you to be able to fulfil the user agreement with you. It is only the processing that is necessary for meeting the Groups obligations under the agreement that is carried out with this processing basis.

What processing is necessary to fulfil the agreement will depend on the user agreement between you and DN Media Group. The user agreement will either be “Subscription and user terms and conditions” or “Terms for using DN ID”. The agreement will vary somewhat for end users, based on what kind of subscription is agreed upon. Your user agreement will be available, and you should read it before you accept the agreement. The user agreement will also be accessible via My page and on subscription information pages on the websites.

One example of processing based on an agreement: If you have a subscription with The Group for delivery of a newspaper, The Group needs to know the address the paper should be delivered to. Another example is that we must process personal data in order to have the correct invoice sent out and make sure it is paid.

3.1.1 Newsletters and notices

We offer newsletters and alerts from our editorial teams and commentators. You may receive these if they are part of your subscription or if you opt in to receive them. Opting in may be subject to either a paid subscription and/or that you register with us to receive a newsletter and accept relevant terms and conditions. You control the sign-up, and in the event you want to unsubscribe, including to newsletters that are included in the subscription, you can cancel it freely yourself via the footer in newsletter itself.

3.2 Legitimate interest

Moreover, The Group has a legitimate interest in some forms of processing, such as advertising purposes, marketing purposes etc. Such processing based on a legitimate interest applies to users with a registered profile or a subscription, or passive users (former subscribers) as described in chapter 1.3).

For users with a user profile, your privacy settings will show that the processing of your data that The Group has a legitimate interest in carrying out, are “switched on”.

You have a right to «opt out», which means that you are allowed to reserve yourself against the processing, as described in chapter 8. This means that you can choose to switch off this processing in the privacy settings page, that can easiest be accessed via My page through the publication specific webpages, if you do not want us to carry out the processing. Alternatively, you can always contact us via the contact pages you will find at the same place.

The Group does not have any terms and conditions linked to opting out, but we would like to make it clear that the user experience of the Services may be affected for those who use their right to opt out or withdraw consent.

If you want to read more about the assessment DN Media Group has made, the balance test of your privacy weighed against The Group's legitimate interesst, the measures implemented to reduce the risk of processing, and the conclusion on legitimate interest, you will find it here .

3.3 Consent

You are free to use the Services without giving us your consent to process your personal data. Consent can also be managed by you in your privacy settings, where you will get the opportunity to give consent, see what consents you have given before, and withdraw consents if you change your mind.

You may also use forms available on the Services to contact us directly, or contact us by other means of communication. If you choose to use an online form to contact us, we will as a minimum process your name and email address and any other information you provide directly in the form. By sending in the form, we consider that you have given consent to this processing, in the context of handling your request.

We might ask for your consent be able to send you good offers when you are no longer considered to be an active user or subscriber.

3.3.1 Cookies

We use information that we gather from our own and third parties’ cookies, tracking pixels and other tracking technology integrated into the Services. This processing applies to all groups of end users of the relevant Services.

When you access and start using the Services, you are consenting to the Group and the Group's partners processing data about you, as described in this privacy policy. With the exception of strictly necessary cookies, we will ask for your consent before cookies are set and utilized by the Services. Please find more information in our Cookie Policy .

Strictly necessary cookies are necessary for the website to function and cannot be switched off in our systems. These cookies do not store any personally identifiable information.

Statistical cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.

Functional cookies enable the website to provide enhanced functionality on our websites, for example remembering your credentials from session to session.

Marketing cookies may be set through our site by our advertising partners. They do not store directly personal information about you, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will still see ads, but they will not be customized to your user.

3.4 Legislation

We are required by law to carry out certain processing of personal data, for instance any personal data that the Group must process in order to comply with its accounting and book-keeping obligations.

4. The data that is processed

4.1 Data that is processed about everyone using the Services:

4.2 Data that is processed in addition for various end-users:

In addition to the information mentioned in 4.1, we may process personal data about the various end-users as described here:

4.2.1 Subscribers

We may also process additional information collected directly from you, or in some cases collected from third parties – for example Dun&Bradstreet whom we use to verify address information. In some cases we may also process information such as birth date, gender, employer, housing type, industry, professional position, and membership number from partners such as Eurobonus.

4.2.2 Registered users

If you register without signing up for a paid subscription, we will connect information described above to your user. For registered users we will also process data such as name, address, mobile number, email address and which newsletters you subscribe to.

In some cases we also process additional information collected directly from you. This might be information about birthdate, gender, employer, industry, and professional position.

4.2.3 Registered users with jobs and careers sites

If you register a user on one of our job sites, we will gather information such as email address, name, mobile number, profile information, job applications and consents for the specific service.

4.2.4 Conference delegates and network members

If you register for one of our physical or digital events or a network membership, we process basic profile information as name, address, mobile number, as well as information about your employer and your professional position. In addition we must process payment information and other necessary information needed to organise the conference or network meeting.

5. Where the information is gathered from

The Group processes your personal data which you yourself have given to us or through your use of the Services; to which The Group gets access to from the unit on which you use the Services; and which The Group collects from third parties as described in this privacy policy. We may also have received data from your employer or any other entity that pays for one of your Services.

We may utilise generative AI technologies to enhance the user experience when analysing and categorising content, for instance for editorial summaries and recommendations. We ensure that no personal data collected by DN Media Group is used in any processing using generative AI-based tools and we are committed to maintaining transparency about how AI-generated content is ceated and used.

6. Our relationship with third parties

6.1 Who helps us in processing your personal data?

To provide you with the Services The Group uses several services delivered by third parties. This means that some of these third parties process data about you on our behalf. Third parties who process personal data on behalf of the Group are called data processors.

The Group has data processor agreements with third parties that process personal data on our behalf in accordance with current legal requirements. Some of these data processors have owning companies located outside the EU or other approved third countries. The Group has implemented measures such as storing data within the EU, encrypting data, controlling access and so fourth, and considers the risk for the registrants or data subjects in this case to be low.

DN Media Group is the controller for all commercial activities in the Group. The company has departments and subsidiaries on several continents, and depending on the function, personal information may be shared across these. The entire Group operate in the same systems and under the same strict security measures.

6.2 Who will The Group pass on personal data to?

We use several services provided by third parties who process information about our users without linking such information to you as an individual. The Group's implementation of such services ensures that only deidentified personal data about you is processed or transferred by The Group. Those DN Media Group shares such data with are not allowed to use your personal data to enrich their own profile sets. We offer you the possibility to control third party cookies via our consent management platform, which you can access in the footer on each page.

The Group uses third parties to supply, personalize and measure the effect of adverts in the Services. To ensure that information used in connection with this is deidentified, we follow Google’s Best practices to avoid sending Personally Identifiable Information (PII) . For further information on Google’s services, technology and use of data, click here . You are in control of cookies set on your device through our cookie consent platform.

The Group controls which third parties that can purchase or take part in the purchase process for digital ads through so-called programmatic ad exchanges on our websites (read more about programmatic advertising in chapter 2). You will find an overview of our approved Adtech providers here .

The Group does not link information from said third party services to you as a person and has implemented these with consideration of your privacy. If you have a separate user account with said service providers and are logged in on such user accounts when using the Services, these service suppliers can in certain cases link information about your use of the Services to your user account with them. The service provider is responsible for the processing in such cases and their terms and conditions apply. You can change the user settings linked to Google here . Google has also explained how you as the end user can remove unwanted ads on Block off certain ads .

Active interaction with such Services, for example by clicking on ads and links, can transfer you to sites, applications or services not owned by DN Media Group. You should familiarize yourself with how third parties use cookies by checking the third party’s cookie policy, and also note that in such cases other terms and conditions apply, not those of DN Media Group.

In the event a subscription is paid by another entity, for example an employer, we may in some cases share basic usage data such as recent log-in frequency, to enable the payor to optimise the accounts they are paying for.

7. Deleting and storing your personal data

Your personal data will only be stored for as long as we have a legal basis for it, in compliance with this privacy policy and other current legislation. When there is no longer any legal basis for processing, the data will be deleted or anonymized.

The Group automatically deletes all personal data stored about you after the customer relationship has ceased, and we no longer have legal basis to process your data. We will keep your data further only if you have given your consent for us to do so.

In general we will keep data and user accounts with personal settings for our subscribers and registered users for up to three years after a subscription has stopped or the last activity on the Services is registered. We do this for security reasons and for the purpose of improving the user experience when reactivating a subscription or other service. Data about financial transactions will be kept for 5 years according to legal requirements.

8. Your rights

You can at any time withdraw the consent you have given under this privacy policy or in some other way to The Group. We make it just as easy for you to withdraw your consent as it is for you to give it. Your privacy settings are managed through your privacy settings that are accessed via My page on the publication specific website.

Such withdrawal can also be done by cancelling any customer relationships you have with us where you ask us to have your user account deleted. To delete anonymized information on your use of the Service, you also have to delete cookies on the unit/your browser. Withdrawal of consent does not affect the legality of the processing based on consent before the consent was withdrawn.

You can also get in touch with The Group via My Page if you want insight into the personal data The Group has stored, and if you want to have these personal data transferred to you or to have the data deleted or corrected.

Likewise, you can contact The Group if you want to limit The Group's processing of your personal data or if you want to protest against The Group's processing of your personal data. If you wish to contact the controller with any concerns you may send an email here . You can also email the privacy officer via this link . You are also entitled to file a complaint against our treatment to the Data Protection Authorities (Datatilsynet), which is the supervisory authority if you believe our processing is in violation of the legislation. Please note that processing personal data for journalistic purposes are exempt from many legal obligations in the GDPR, for instance the right to have your information deleted.

We make use of profiling, limited to such purposes as those stated in chapters 2 – 4 above.

You can choose yourself to remove our access to your unit’s location data by switching off the location tools on the unit, or by refusing sharing of such data through your unit’s settings.

The Group will inform you about major changes and updates on this privacy policy.

9. Safety and security

The Group has technical and organisational safety measures, including procedures for internal control and information security in accordance with the current privacy legislation in Norway.

It is safe to use the Services. The Group handles personal data in an encrypted and safe manner, for instance by using HTTPS communication for transferring your data safely and securely. Read more about our technical and organisational measures to protct your personal data.

DN Media Group will not sell, replace, or disclose your personal data to third parties other than that which is stated in this privacy policy.