PERSONAL DATA POLICY
- GENERAL INFORMATION 1.1 This policy on the processing of personal data (“Personal Data Policy”) de-scribes how Skagerak Denmark A/S (“Skagerak Denmark”, “us”, “our”, “we”) collects and processes data about you.
1.2 The Personal Data Policy applies to personal data that you give us or which we collect via Skagerak Denmark’s website, www.skagerak.dk (the “Web-site”).
1.3 Skagerak Denmark is controller of your personal data. All inquiries to Skagerak Denmark can be made via the contact information set out in clause 7.
- WHICH PERSONAL DATA WE COLLECT FOR WHAT PURPOSES AND THE LEGAL BASIS FOR PROCESSING
2.1 When you visit the Website, we automatically collect data about you and your use of the Website, e.g. which type of browser you use, which search terms you use on the Website, your IP address, including your network loca-tion and information about your computer.
2.1.1 The purpose is to optimize the user experience and the functioning of the Website which also includes automatic redirection to the right country website depending on where the user is situated, and to perform targeted marketing, including retargeting via Facebook and Google. This processing of data is necessary for us to attend to our interests in improving the Website and showing you relevant offers.
2.1.2 The legal basis for the processing is point (f) of Article 6(1) of the EU Data Protection Regulation.
2.2 When you buy a product or communicate with us on the Website, we collect the information that you provide yourself, e.g. name, address, e-mail ad-dress, telephone no., method of payment, information as to which products you buy and may have returned, delivery requests as well as information on the IP address from which the order was made.
2.2.1 The purpose is that we can deliver the products you have ordered and otherwise perform our agreement with you, including that we are able to administer your rights to return products and make com-plaints. We may also process data on your purchases to comply with statutory requirements including bookkeeping and accounting re-quirements. In connection with purchases, the IP address is collect-ed with the purpose of attending to our interest in being able to pre-vent fraud.
2.2.2 The legal basis for the processing is points (b), (c) and (f) of Article 6(1) of the EU Data Protection Regulation.
2.3 When you sign up for our newsletter, we collect information about your name, e-mail address and possibly your mobile telephone number.
2.3.1 The purpose is to attend to our interest of being able to deliver the newsletter to you.
2.3.2 The legal basis for the processing is point (f) of Article 6(1) of the EU Data Protection Regulation.
2.4 When you sign up for our customer club, you are asked to state e.g. your name, address, date of birth, e-mail address, telephone no., your prefer-ences and interests etc. Apart from name, address and e-mail address, you decide yourself which data you want to give us. In addition to that, we collect data during your membership about your use of the advantages of the cus-tomer club, competitions in which you participate etc. We compare this data with other data we have on you, including data on what you have bought and what you may have returned.
2.4.1 The purpose is to be able to administer your membership and pro-vide the services and offer you the advantages that are related to membership of the customer club and to attend to our interest in be-ing able to send newsletters and perform targeted marketing.
2.4.2 The legal basis for the processing is points (b) and (f) of Article 6(1) of the EU Data Protection Regulation. In connection with signing up, you will be asked for your separate consent to electronic marketing.
- RECIPIENTS OF PERSONAL DATA
3.1 Information about your name, e-mail, telephone number and order number and specific delivery requests is disclosed to PostNord, GLS or a carrier that is in charge of the delivery of the goods purchased to you. In the case of pur-chase of non-stocked goods, the information mentioned may be disclosed to the manufacturer or the seller of the article in question who will then be in charge of the supply.
3.2 Data may be passed on to external collaborators who process the data on our behalf. We engage external collaborators for among other things tech-nical operation of and improvements to the Website, the publication of news-letters as well as targeted marketing, including retargeting as well as your assessment of our enterprise and products.The processors must not use the data for any purpose other than the performance of the agreement with us and are subject to confidentiality as regards the data. We have concluded written data processing agreements with all processors who process per-sonal data on our behalf.
3.3 Two of these processors, Google Analytics represented by Google LLC and Facebook Inc. are set up in the USA. The appropriate safeguards for transfer of data to the USA are secured via the processor’s certification under the EU-US Privacy Shield; see Article 45 of the EU Data Protection Regulation.
3.3.1 A copy of the certification of Google LLC is available here: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI
3.3.2 A copy of the certification of Facebook Inc. is available here: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
- YOUR RIGHTS 4.1 With a view to creating transparency regarding the processing of your data we must in our capacity as controller inform you of your rights.
4.2 Right of access
4.2.1 You are always entitled to ask us for information on, among other things, the information we have registered about you, the purpose of registration, the categories of personal data and recipients, if any, of data and information on where the data comes from.
4.2.2 You are entitled to receive a copy of the personal data we process about you. If you want a copy of your personal data you must send a written request to: info@Skagerak.dk. You may be asked to provide documentation that you are the person you hold yourself out as.
4.3 Right to rectification
4.3.1 You are entitled to have inaccurate personal data about you rectified by us. If you become aware that there are errors in the data we have registered about you, we ask you to contact us in writing so that the data can be corrected.
4.3.2 You can yourself correct data we have collected in connection with your signing up for our customer club by logging into your user profile.
4.4 Right to erasure
4.4.1 In certain cases, you are entitled to have all or certain of your personal data deleted by us, e.g. if you withdraw your consent and we do not have any oth-er legal basis for continuing processing. To the extent that continued pro-cessing of your data is necessary, e.g. for us to comply with our legal obliga-tions or for determining, advancing or defending a legal claim we are not obliged to delete your personal data.
4.5 Right to restrict processing to storage
4.5.1 In certain cases, you are entitled to have the processing of your personal da-ta restricted to only storage, e.g. if you believe that the data we process about you is not correct.
4.6 Right to data portability
4.6.1 In certain cases, you are entitled to receive personal data you have yourself given us in a structured, generally used and machine readable format and you are entitled to transfer such data to another controller.
4.7 Right to object
4.7.1 You are always entitled to object to our processing of your personal data with a view to direct marketing including the profiling made to target our direct marketing.
4.7.2 In addition, you are always entitled for reasons relating to your personal situ-ation to object to processing of your personal data that we carry out on the basis of our legitimate interests; see sub-clauses 2.1 and 2.3.
4.8 Right to withdraw consent
4.8.1 You are always entitled to withdraw consent that you have granted us to any given processing of personal data, including to the profiling of you as a member of the customer club. If you want to withdraw your consent you are requested to contact us at email@example.com.
4.9 Right to complain
4.9.1 You are always entitled to file a complaint with the Danish Data Protection Agency, Borgergade 28, 5th floor, DK-1300 Copenhagen K, concerning our processing of your personal data. A complaint can, among other things, be filed by e-mail firstname.lastname@example.org or by telephone +45 33 19 32 00.
- ERASURE OF PERSONAL DATA 5.1 Data collected on your use of the Website (see sub-clause 2.1) is deleted at the latest when you have not made use of the Website for 1 year.
5.2 Data collected via Google Analytics will automatically be deleted after 24 months.
5.3 Data collected in connection with your signing up for our newsletter is delet-ed when your consent to the newsletter is withdrawn unless we have a dif-ferent basis for processing the data.
5.4 Data collected in connection with purchases you have made on the Website (see sub-clause 2.2) will generally be deleted 3 years after the end of the calendar year during which you made your purchase. However, data can be stored for a longer period if we have a legitimate need for storage for a long-er period, e.g. if it is necessary for a legal claim to be determined, advanced or defended or if storage is necessary for us to comply with legal require-ments. Accounting records are stored for 5 years until the end of a financial year to comply with the requirements of the Danish Bookkeeping Act.
5.5 Data we have collected in connection with your signing up for and during your membership of our customer club (see sub-clause 2.4) will automatical-ly be deleted: (a) if you have not logged on to your user profile for 3 years, (b) if you deactivate (suspend) your membership of our customer club and do not reactivate it within the next 3 years, or (c) if you unsubscribe your membership of our customer club.
- SECURITY 6.1 We have taken suitable technical and organisational security measures against accidental or unlawful destruction, loss, alteration or impairment of personal data and against unauthorised disclosure of or access to or abuse of personal data.
6.2 Only employees who have an actual need to get access to your personal data to perform their work have access to the data.
- CONTACT INFORMATION 7.1 Skagerak Denmark A/S is controller of the personal data collected via the Website. 7.2 If you have questions or comments on this Personal Data Policy or if you want to exercise one or more of your rights described in clause 4, you can contact: Skagerak Denmark A/S Nordvestvej 31 DK-9000 Aalborg
Tel. no.: +45 99 52 52 00
- CHANGES TO THE PERSONAL DATA POLICY 8.1 If we decide to change our Personal Data Policy you will be notified of this next time you visit our Website.
8.2 If you have signed up for our customer club, you will be notified of changes to the policy via information sent to your registered e-mail address.
- VERSIONS 9.1 This is version 1 of Skagerak Denmark’s personal data policy dated 11 May 2018.