We are committed to protecting the privacy of our clients and business partners.
This Privacy Policy explains how Acconor collects, uses, stores and shares personal data, as well as your rights as a data subject.

We process personal data in accordance with the General Data Protection Regulation (GDPR) and applicable Norwegian legislation.

1. Data Controller

Acconor is a shared brand that brings together services within accounting, finance, business establishment and development.
The services are provided by the following legal entities:

Acconor Accounting & Consulting AS

• Organisation number: NO 934 630 114 MVA
• Authorised accounting firm regulated by the Financial Supervisory Authority of Norway (Finanstilsynet)
• Managing Director: Viktoriya Ramanovich

Acconor AS

• Organisation number: NO 999 008 577 MVA
• Provides other services, including advisory, consulting, representation, operational and marketing services
• Managing Director: Per Bang

The data controller is the company that provides the specific service to you.
Both companies use the Acconor brand in their marketing and service delivery.

2. Purpose of Processing

We process personal data for the following purposes:

• Delivery and administration of our services
• Compliance with statutory obligations (e.g. the Accounting Act, the Anti-Money Laundering Act)
• Customer due diligence (KYC) and identity verification
• Communication with clients and business partners
• Invoicing, contract management and client administration
• IT operations, security and quality assurance
• Marketing to existing clients
• Improvement of websites and digital solutions

3. Categories of Personal Data

We may process the following categories of personal data:

• Name, address, email address, telephone number
• Date of birth, nationality, and identification number (for KYC purposes)
• Company information, ownership structure and beneficial owners
• Invoicing and payment details
• Contracts, documentation and correspondence
• Technical data from website usage (IP address, cookies, device data)

4. Legal Basis for Processing

Processing of personal data is based on Article 6 of the GDPR:

• Contract (Art. 6(1)(b)) – necessary for the performance of a contract or to take steps prior to entering into a contract
• Legal obligation (Art. 6(1)(c)) – for example, obligations under the Anti-Money Laundering Act or the Accounting Act
• Legitimate interest (Art. 6(1)(f)) – such as business operations, IT security and client communication
• Consent (Art. 6(1)(a)) – for marketing activities and the use of non-essential cookies

You may withdraw your consent at any time via our website.

5. Sharing of Personal Data

We only share personal data when necessary and lawful:

• Public authorities: such as the Norwegian Tax Administration, the Financial Supervisory Authority of Norway, and Økokrim (the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime)
• Subcontractors/data processors: for example IT operations, cloud services (Microsoft 365), and any providers assisting with mail handling or administrative services
• Other companies within the Acconor group: when necessary to deliver a service you have requested

All data processors are bound by data processing agreements and are not permitted to use the data for their own purposes.
We never sell personal data to third parties.

6. Transfer to Third Countries

As a general rule, personal data is processed within the EEA.
If personal data is transferred outside the EEA (for example through cloud services), such transfers are carried out in accordance with Chapter V of the GDPR, typically by using the European Commission’s Standard Contractual Clauses (SCCs).

7. Storage and Deletion

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law:

• Accounting data: 5 years after the end of the financial year
• KYC information: 5 years after the end of the client relationship
• Other client data: deleted or anonymised once the purpose has been fulfilled

8. Your Rights

Under the GDPR, you have the following rights:

• Right of access (Art. 15)
• Right to rectification (Art. 16)
• Right to erasure (“right to be forgotten”) (Art. 17)
• Right to restriction of processing (Art. 18)
• Right to object (Art. 21)
• Right to data portability (Art. 20)
• Right to withdraw consent (Art. 7)

You may exercise your rights by contacting us via the contact form at www.acconor.com

If you believe your personal data is being processed unlawfully, you have the right to lodge a complaint with the Norwegian Data Protection Authority (Datatilsynet).

9. Contact Information

Privacy-related enquiries may be directed to:

Acconor
c/o Acconor AS and Acconor Accounting & Consulting AS
Andersrudveien 1, 1914 Ytre Enebakk, Norway
Telephone: +47 456 72 000
Website: www.acconor.com

10. Changes to This Policy

This Privacy Policy may be updated from time to time.

The latest version will always be available at www.acconor.com

Introduction

Terms

These general terms and conditions apply, along with any individual agreements, to all tasks undertaken or performed by employees of Acconor (“Acconor”) for the company’s clients (“Client”).

Validity and Acceptance

These general terms and conditions apply to all clients and tasks. The terms are published on Acconor’s website. The client is normally informed about these terms via phone or email when a client relationship is established and is considered accepted by the client unless the client communicates to Acconor within a reasonable time that they do not accept the terms.

Scope

Unless otherwise agreed, these terms will also apply to future tasks for the same client.

Purpose

Acconor aims to promote the client’s interests and goals in the best possible way within the framework of these terms, accepted offers, supplementary agreements, and internal procedures.

Initiation and Execution of Tasks and Projects

Initiation

The task description is outlined in the confirmation (usually contained in an email) or the agreements resulting from verbal or written correspondence. If the task is changed or expanded after initiation, the agreement will apply to the entire task unless otherwise agreed.

Execution

All tasks are assigned to a responsible employee at Acconor, who may receive assistance from the company’s other employees and other affiliated consultants, advisors, lawyers, etc., for the execution of all or parts of the task.

Conflict of Interest

Before a client relationship is established, efforts will be made to clarify if there is any conflict of interest or other factors that would suggest that Acconor should not undertake the task. The client is obliged to assist in this clarification.

Information Basis

To best promote the client’s interests, Acconor depends on the client proactively providing all relevant information and clarifying the desired outcome of the task. Acconor is not responsible for verifying the accuracy of the information received from the client.

Framework

Acconor provides commercial advice and services related to international activities, establishment, presence, and activities in Norway (sporadically or permanently) and business development in general. Legal and accounting advice falls outside the scope of the task. Acconor can represent the client in Norway and, among other things, assist in communication with public authorities and entities at the client’s responsibility.

Price, Billing, and Disbursements

Billing

Unless otherwise agreed, the starting point for billing is the time spent professionally on the task. All prices are stated exclusive of VAT (value-added tax). Acconor reserves the right to change prices and hourly rates, even for ongoing tasks. Time spent is calculated from the time the first contact was made regarding the task and until the task is fully completed. Remote services and advisory services across borders are billed in Danish Kroner (DKK), unless otherwise agreed, exclusive of Norwegian VAT (value-added tax) according to reverse charge. Services provided in Norway or on the Norwegian continental shelf are billed in Norwegian Kroner (NOK) and with Norwegian VAT.

Time Unit

The smallest time unit is 1/4 hour (15 minutes). Phone calls, mail reception, emails, and similar services are normally charged with a minimum of 1/4 hour.

Advance and Interim Billing

As a general rule, Acconor will ask all new clients to pay an advance to cover ongoing fees and disbursements. Additionally, there is a reservation for billing advance or requiring prepayment for any task. Acconor can freely determine the size of such advances or interim billing amounts. Advances must be paid to the designated account at Acconor. Acconor may freely use the funds to offset unless otherwise agreed in writing. The settlement of the advance will appear on the next invoice. Once the task is completed, any excess advance amount will be refunded to the client. Earned interest belongs to Acconor.

Cost Estimates

All cost estimates from Acconor are provided solely for guidance and cannot be considered as either a fixed price or a maximum price, and are thus not binding for the company unless otherwise specifically agreed in writing. Acconor may freely revise cost estimates during the execution of the task.

Adviser’s Fee

When determining the final fee, Acconor may also exercise discretion considering the nature and complexity of the work, the size of the task, risk and value, and how efficiently the task has been performed, considering the individual advisor’s background and specialized competence. The fee should be reasonable in relation to the task and the work performed by Acconor’s employees.

Costs

The client is responsible for all disbursements incurred during the task, including but not limited to registration costs, database searches, prints, certificates, third-party costs (including but not limited to: partners, experts, and lawyers). Costs for copying, printing, courier services, and special secretary services will be billed to the client. Additionally, all expenses related to travel activities, including meals, will be billed to the client.

Joint Responsibility

In case several clients are involved in the same task, the clients will be jointly responsible for the fee and disbursements associated with the task. This applies regardless of whether the fee or disbursement is invoiced or has been invoiced to one or more of the clients for practical reasons.

Billing Interval

Unless otherwise agreed in writing, Acconor will invoice the client for larger and/or ongoing tasks on a monthly basis. A specification for the work performed, disbursements, etc., will usually follow the invoice. The invoice must be paid within 10 days unless otherwise specified. Disbursements and smaller one-off tasks can be invoiced continuously.

Disbursements

All costs and disbursements incurred by Acconor will be invoiced together with the ongoing billing. Disbursements with VAT will be invoiced in total. The client may, upon request, receive copies of receipts and is responsible for any offsetting or reimbursement. Disbursements in foreign currency will be billed at the booked exchange rate, with any transaction costs added.

Late Payment

In case of late payment, interest on overdue payments will be charged according to the Norwegian late payment interest law. All costs related to payment reminders and other collection expenses are borne by the client.

Acconor’s Responsibility

Direct Responsibility

Acconor’s liability for any loss related to a task is limited in nature and scope to the fee Acconor has received for the specific task with a maximum limit corresponding to the amount covered by Acconor’s current liability insurance.

Indirect Loss

Acconor is not liable for indirect loss, including lost profits or missed opportunities.

Third Parties

Acconor is not liable for errors made by advisors, consultants, experts, lawyers, or other third parties whom Acconor has referred to, or subcontractors to whom Acconor has delegated parts of the task, even if they were selected and/or instructed by Acconor on the client’s behalf.

Outcome

Acconor is not liable for loss arising from the task’s outcome not aligning with the judgment Acconor might have given beforehand as a possible result.

Managed Funds

Acconor is not liable for loss of managed funds due to bankruptcy or other issues on the part of the bank.

Right to Claims

The client loses the right to make claims if the client does not, without unreasonable delay after the client discovers or could have discovered the basis for the claim, submit a written complaint to the responsible employee or management at Acconor.

Handling of Information

Confidentiality

Employees at Acconor are prohibited from disclosing confidential information unlawfully. Additionally, employees are instructed to treat other information confidentially.

Sharing

Unless otherwise agreed, Acconor’s employees are allowed to share information with other employees in the company and third parties if deemed necessary for the task’s execution.

Personal Data

To the extent necessary for the performance of the task, the client consents to voluntarily provide personal data (including sensitive data). It is the client’s responsibility to instruct Acconor on how to handle the information to ensure compliance with the laws in the relevant jurisdictions (including the client’s home country) as well as the client’s internal procedures and guidelines. The information will only be provided to other parties, advisors, partners, and public authorities to the extent necessary for the performance of the task. The client has the right to access and request correction of inaccurate information and deletion after the task is completed.

Risk

Acconor points out that electronic data communication (email, cloud storage, etc.) generally has weaknesses, which means that unauthorized parties may gain access to communication under certain conditions. To the extent confidentiality is required, security measures (such as encryption and obfuscation) may be taken to prevent unauthorized access. The client’s transmission of unsecured electronic information will be considered when assessing whether confidentiality is necessary. Acconor uses email for communication. If the client has objections to confidential information being sent via email, Acconor must be notified immediately.

Reference

Unless the client explicitly objects, Acconor may use the client’s name as a reference in marketing materials.

Copyright

Acconor retains copyright to all documents, materials, etc., created in connection with task execution.

Storage

Acconor may retain copies of documents and information after the task is completed within the legal framework. Copies can be provided for a fee.

Complaint Handling

Submission

If the client is dissatisfied with the task execution or the invoicing basis, the client is encouraged to immediately bring this up with the responsible employee or management at Acconor. Complained matters will be promptly assessed by Acconor.

Deadline

The complaint must generally be submitted without undue delay and no later than 28 days after the client has discovered, or should have discovered, the reason for the complaint. If the client does not submit the complaint within this period, the client may lose the right to make claims or contest the matter.

Termination of Agreement

Termination by the Client

The client has the right to terminate the agreement at any time. However, the client is obligated to pay for all work performed up to the time of termination, including any costs and disbursements incurred.

Termination by Acconor

Acconor reserves the right to terminate the agreement with immediate effect if the client fails to fulfill their obligations or if Acconor considers the continuation of the task to be impractical due to circumstances outside Acconor’s control, including but not limited to:

1. The client’s failure to provide necessary information or support.
2. A significant change in the nature or scope of the task.
3. A breach of confidentiality obligations.

Force Majeure

Acconor is not liable for failure to perform the task if the failure is caused by circumstances beyond Acconor’s control, including but not limited to, natural disasters, pandemics, wars, strikes, or other unforeseen events.

Governing Law and Dispute Resolution

Applicable Law

The agreement between Acconor and the client shall be governed by and construed in accordance with the laws of Denmark, unless otherwise agreed.

Dispute Resolution

In case of any disputes arising from this agreement, both parties agree to seek a resolution through negotiation. If a resolution cannot be reached, the dispute will be resolved by arbitration or mediation in accordance with the rules of the Danish Arbitration Institute. The venue for arbitration shall be Copenhagen, Denmark.

Final Provisions

Amendments to Terms

Acconor reserves the right to amend these general terms and conditions. Any amendments will be communicated to the client in advance, and the new terms will apply to any ongoing or future assignments.

Severability

If any provision of these terms and conditions is deemed to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect.

Entire Agreement

These terms and conditions, along with any individual agreements, constitute the entire agreement between Acconor and the client. Any previous agreements or oral representations are superseded by this written agreement.