Privacy notice

Translation. This is an English translation of the Norwegian original. The Norwegian version is the binding version and prevails in the event of any discrepancy between the Norwegian and the English text. CIRON AS is a Norwegian company, and the agreement is governed by Norwegian law.

Draft. This document has not been legally reviewed. It describes how the service actually works, and is intended as the basis for the lawyer's review — not as a finished agreement. This notice will be removed once the review has been completed.

Field	Content
Controller	CIRON AS, org. no. 922 148 759, for data about the customer relationship
Processor	CIRON AS, for the content the customer enters in Nirona
Contact	support@nirona.app
Last updated	5. september 2026
Version	0.9 — utkast til juridisk gjennomgang (draft 0.9, pending legal review)
Language	Norwegian is the authoritative language version

Contents

Two roles, and why the distinction matters
The content the customer enters
Data CIRON is responsible for
Lawful basis for processing
Where the data is stored
Security
Processors
Retention periods
Your rights
Cookies
In the event of a breach

1Two roles, and why the distinction matters

CIRON has two different roles in Nirona, and which one applies determines whom you should contact.

For the content of the cases, CIRON is a processor. The customer — that is, the organisation that has ordered the service — decides what is entered and why. We process it only on the customer's instructions. If your enquiry concerns a case you have reported, or data about you that your colleagues have entered, you should contact your employer.

For the customer relationship, CIRON is the controller. This covers data about the customer's contact persons, agreement documents and invoicing. There you may contact us directly.

2The content the customer enters

As processor, we process what the customer enters in the service:

Cases: title, description, category, priority, timestamps
Messages in the case dialogue, and internal notes
Attachments the customer uploads
Users: name, email address, role
Help articles the customer publishes
A log of who did what in the system

We do not use this for anything other than delivering the service. It is not used to train models, nor for product development, and it is not shared with anyone other than the processors listed in section 7.

The customer decides for itself how long the content is retained, and may at any time export it or request that it be deleted.

3Data CIRON is responsible for

Contact persons at the customer: name, email address, telephone number, role. Used for contract management, notifications and invoicing
Agreement documents and correspondence concerning the customer relationship
Operational data: which organisations exist with us, whether they are open, and technical information about the state of the service

We do not use third-party tracking tools, advertising networks or analytics tools on nirona.app.

4Lawful basis for processing

Processing	Basis
Content of the cases	Data processing agreement with the customer. The customer is responsible for its own basis
Contact persons at the customer	Contract, see Article 6(1)(b)
Security log and audit trail	Legitimate interest in being able to document what has been done, see Article 6(1)(f)
Invoicing and accounting	Legal obligation, see Article 6(1)(c)

5Where the data is stored

All storage and processing take place within the EU. The data stores are created with EU jurisdiction, not merely with a region setting — the difference is that it is enforced by the platform, not documented by us.

Transfers to countries outside the EEA do not take place as part of normal operation. Should this become relevant, the basis will be the EU Standard Contractual Clauses (SCCs), and the customer will be notified in advance.

6Security

A separate data store per customer. No shared tables containing customer data. There is no query in the system that can read across customers
A separate encryption key per customer. Content is encrypted before it is stored. A ciphertext moved to another customer's store is unreadable, even with the correct key
No standing access. See section 6 of the Terms of Service
Hash-chained audit trail. Each entry is bound to the previous one, so that a removed or altered entry breaks the chain
Isolation tests at every release. If one fails, the release is stopped. A customer is not opened until the test has passed and the data processing agreement has been signed
External security test before the first external customer, and annually thereafter

7Processors

Supplier	Purpose	Location
Cloudflare, Inc.	Operation, storage and delivery of the service	EU

We do not use other processors for the customer's content. If a new one is engaged, the customer will be notified in advance and may object to it.

8Retention periods

What	How long
Content of the cases	For as long as the customer decides. The default is 36 months, and the customer may change it
Contact persons at the customer	For as long as the customer relationship lasts, and thereafter for up to 12 months
Invoicing records	5 years, pursuant to the Norwegian Bookkeeping Act (bokføringsloven)
Audit trail	Retained when a customer is deleted. Contains only internal identifiers, not content

9Your rights

You have the right of access, rectification, erasure, restriction and data portability, and the right to object to processing.

If your enquiry concerns the content of the cases, it should be directed to your employer. We are the processor there, and cannot respond on the customer's behalf. If we receive such an enquiry, we forward it to the customer and let you know that we have done so.

If it concerns the customer relationship, you may contact us at support@nirona.app. We respond within 30 days.

You may lodge a complaint with the Norwegian Data Protection Authority (Datatilsynet).

10Cookies

We use only cookies that are necessary for sign-in to work. No analytics, no tracking, no advertising — and therefore no consent dialogue to click away either.

Cookie	Purpose	Duration
`__Host-nirona_sesjon`	Keeps you signed in	8 hours
`__Host-nirona_sso`	Holds the state during sign-in with Microsoft or Google	10 minutes

Both carry the __Host- prefix. This means that the browser refuses them a domain attribute, and that they technically cannot be shared between two customers' addresses — not even through a fault in our own code.

11In the event of a breach

If we discover a personal data breach affecting a customer, we notify that customer without undue delay, and no later than 24 hours after becoming aware of it.

The notification goes to the individual customer. We do not send collective notifications to several customers in the same message — a recipient list would in itself reveal who our customers are.

The customer is the controller and decides for itself whether the Norwegian Data Protection Authority (Datatilsynet) is to be notified. We give the customer what it needs to make that assessment.

Contact

CIRON AS · Trondheim · support@nirona.app