1. Key Points
1.1 We are committed to safeguarding the privacy of our customers,visitors,employees and clients; in this policy we explain how we will handle your personal data.
1.2 Our company ensures personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
1.3 Our company incorporates privacy and security controls to ensure your data is not accessible by unauthorized persons.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process your personal data that are provided in the course of the use of our services (“service data”).The service data may include (name,contact information, company information, financial records). The source of the service data will be you or your employer. The service data may be processed [for the purposes of operating our services, ensuring the security of our data and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our services and business.
2.3 We may process [information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.
2.4 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include [your contact details, your bank details and the transaction details].] The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
2.5 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.6 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.8 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3.2 We may disclose personal data to third parties insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3.4 We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.6 All correspondence data can be expected to be held, secured and processed under the rules and rights mentioned in this document by our data controller Hovmark Data ApS (Cvr: 39588072). Correspondence data held by Hovmark Data ApS will be kept for the length mentioned under 5.3e. In rare cases other data may be shared with Hovmark Data ApS in the interest of security or improving services, such data will be also processed by the same rules and rights designated in this document. Please do not hestiate to contact our Hovmark Data ApS with any questions or concerns.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We may occasionally have to export data outside the EU to meet a specific business function. Transfers to these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain and delete your personal data as follows:
(a) Employee data will be kept during the period of employment and for a 12 month period after in the case of legal or financial disputes.
(b) Job Applications will be kept until a final decision is made, unless specified otherwise, all data of unsuccessful candidates will be deleted, data of successful applicants will follow regulations set in 5.3 (a).
(c) Customer data will be kept a maximum of 24 months after the last transaction
(d) Visitor data will be kept a maximum of 90 days.
(e) Contractor and third party data will be retained for 12 months following the last activity.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time, please inform yourself frequently to stay up to date with any changes.
6.2 We may notify you of changes to this policy via email or telelphone.
7. Your rights
7.1 In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us including a copy of your government photo ID.
8. How we secure your data
8.1 We take every precaution to ensure the data in our possession is secured to the best possible standard from unauthorized access, this is done the following ways:
(a) Annual security audits from trained professionals
(b) Using industry standard information assurance practices and policies.
8.2 Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those necessary.
8.3 Any and all breaches will be reported to both those effected and the Danish data protection agency.
9.1 It is our policy never to knowingly collect or maintain information about anyone under the age of 18.
9.2 In the unlikely case data is collected be about a child, we will always ensure verifiable consent is given by the legal guardian and proper protocol is followed.
10. Our details
10.1 We are registered in Denmark under registration number CVR-nr 39633078
11. Data protection officer
11.1 Our data protection officer’s contact details are:
Hovmark Data ApS
Gionathan Armando Reale