Last updated September 2019
This Policy covers Empower’s treatment of personal data in its capacity as asset manager of Empower Invest AS (“Empower Invest”), a limited liability company incorporated in Norway for the sole purpose of raising funding for carrying out renewable energy projects in emerging markets. As such, this Policy applies only to Empower and does not apply to affiliated or linked companies or websites.
1 Data Controller
Empower collects data either for itself or on behalf of Empower Invest. Both Empower and Empower invest are data controllers in that they determine the purposes for and the means by which personal data is processed. However, Empower acts as the processor in that it processes data on behalf of itself or Empower Invest. The relationship between Empower as the processor and Empower Invest as a controller is governed by a Data Processing Agreement.
The person responsible for the processing and treatment of such data within Empower is the Information Officer.
2 What information we collect
Information collected from investors, partners and clients
Empower collects either for itself or on behalf of Empower Invest personal data from its investors, partners and clients, which may include:
Names, title, address, mobile, and email addresses
Financial statements and annual accounts
Copies of passports or driver’s license or company registration or certificate
Articles of association, shareholding agreements, certificate of registration or similar, and certified copy of utility bill or tax return
Empower may collect additional personal data that is necessary for the delivery of agreed upon services or the implementation of the specific agreement entered into with Empower or Empower Invest.
Information collected from website users
Empower uses Google Analytics on our website to track visitor behavior. This information is used to get information on the number of visitors view the website and to better understand how such website visitors find and use the Empower website, and how such visitors navigate the pages on the Empower website.
From your accessing of the Empower website, Google Analytics stores information about your geographical location, device, browser, and operating system. Empower receives this information in aggregated form, so it cannot be used to track your behavior or usage individually. Google Analytics also collects your IP address, but this is anonymous and cannot be used by Empower to identify you.
3 How we collect your information
Most of the data we collect is provided directly by you. We store the personal data you have submitted to our website or sign up forms or to any of our employees or representatives with regards to entering into and implementing an agreement with Empower or Empower Invest.
Empower may also receive your data indirectly from third party electronic sources including company registries or other websites.
4 Why we collect your information
Legitimate interest. Empower collects your information to be able to implement and execute agreements entered into with Empower or Empower Invest.
Legal requirements. Empower is an unauthorized Alternative Investment Fund Manager (“AIFM”) of Empower Invest and registered with the Financial Supervisory Authority of Norway (“Finanstilsynet”). To register as an AIFM, Finanstilsynet requires us to collect certain personal data from our investors to fulfill the requirements related to Anti Money Laundering (AML), Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA).
Additionally, in order to comply with its Integrity and Know-Your-Customer (KYC) Policy, Empower will conduct checks on all those persons or entities with which it enters into a business relationship.
5 Where we store your information
6 Sharing personal information with third-parties
Empower will share with Empower Invest all personal data necessary for the implementation and fulfilment of its agreements with partners, investors and clients. In addition, Empower will also share such personal data and information with its professional advisors and consultants and actual and potential investors for the purpose of carrying out due diligence checks and Know-Your-Customer and other integrity checks.
Beyond this, Empower will not share or sell or in any other way transfer personal data to other parties, unless we legally obliged to do so.
Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit the Empower website, we may collect information from you automatically through cookies or similar technology. For further information, please visit allaboutcookies.org.
The information we collect using cookies is aggregated data on visitor behavior, so the data collected cannot be used to identify you or track your movements individually.
Empower does not treat information obtained through cookies or similar technology as personal data. To the extent that the IP address or similar indicators are seen as personal data, we will treat these indicators as personal data. Similarly, to the extent that non-personal data is combined with personal data, we will treat the combined data as personal data.
Most browsers are set to automatically accept cookies. If you do not want this, you can change the settings of your browser so that it blocks cookies from empowernewenergy.com. Please be aware that this may affect the functionality of our website.
Empower would like to send you newsletters with information about our company, projects and partners that we think might be of interest to you. If you have agreed through an opt in arrangement to receive our newsletter, you may always choose to unsubscribe at a later date.
You have the right at any time to stop Empower from contacting you for marketing or communication purposes.
If you no longer wish to be contacted for marketing purposes, please send an email to firstname.lastname@example.org.
9 Your rights concerning your personal information
We treat your personal data in accordance with the Norwegian Personal Data Act and all applicable regulations as may be updated from time to time.
Should you have a complaint against Empower in the way in which your personal data is being handled by Empower, please contact The Norwegian Data Protection Authority (“Datatilsynet”) to report your complaint.
Please note your rights, which include the following:
You have the right to request from Empower copies of your personal data held by Empower. We may charge you a small fee for this service.
You have the right to request that Empower corrects any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
You have the right to request that Empower erases your personal data, under certain conditions.
You have the right to object to Empower’s processing of your personal data, under certain conditions.
You have the right to request that Empower transfers the data that we have collected to another organization, or directly to you, under certain conditions.
10 Data retention
Information obtained by Empower is stored in our systems for as long as you or your company continue to have a relationship with Empower and/or Empower Invest.
Empower’s website uses https for encryption which provides safe communication between our server and your computer. The encryption ensures that only our server can read what you submit to our website, and only your computer can read what is sent by the server. To check if a website is encrypted with https, look for https instead of http in the url.
12 Contacting us
Should you have any questions or enquiries, please contact us using one of the two methods below.
By Post or in Person: Empower New Energy AS, Snarøyveien 20, 1360 Fornebu, Oslo, Norway