Privacy Policy for Customers of HAE Koncern

As a data controller, data protection is very important to us. We safeguard the personal data we process and ensure that we comply with data protection legislation.

We provide the individuals whose data we process (“data subjects”) with information about our data processing activities and about the rights they have as data subjects.

In this privacy policy, we describe our processing of information relating to customers.

You can find the contact details of the data controllers of the individual companies on their respective websites.

Our processing of personal data

Categories of personal data

The information we process about you may include:

• General personal data, including
  
  • Identification details, including name, address, telephone number, and email
  • Purchase history
  • Payment history and payment details
  • Information included in our correspondence with you

• CPR number
  
  • CPR number in connection with credit assessments, loan establishment, and signatures on documents

• Recording of calls
  
  • We record all incoming and outgoing telephone calls. The legal basis for this is found in the Danish Security Services Act as well as a statement from the Danish Data Protection Agency.
    
    Emergency calls handled as front-line or back-up services are processed via DJK, which is an approved control centre. This approval requires that all telephone calls are stored for six months as documentation of the course of events.
    
    Alle telefonsamtaler opbevares på en lukket, sikker portal og slettes som beskrevet efter 6 måneder.
    
    
• All telephone calls are stored in a secure, closed system and deleted after six months as described.
  

  • Recording of calls for training purposes.
    We record telephone calls for training purposes if consent has been given. You may withdraw your consent at any time. Recordings are stored in a secure, closed system and deleted after 31 days.

Purpose and legal basis
Our processing activities serve the following purposes:

• Administration of the customer relationship, maintenance and development of customer relations, and ongoing transactions
• Statistical purposes: Analysis of transactions and reporting based on general customer data collected

Legal basis for processing

• When processing personal data in connection with fulfilling your orders and purchases, including delivery, credit, and payment, the legal basis is Section 6(1) of the Danish Data Protection Act and Article 6(1)(b) of the GDPR, as processing necessary for the performance of a contract.

• When we register information required under the Bookkeeping Act or for reporting to tax authorities, the legal basis is Section 6(1) of the Danish Data Protection Act and Article 6(1)(c) of the GDPR, as processing necessary to comply with a legal obligation.

• The legal basis for collecting and registering other personal data is Section 6(1) of the Danish Data Protection Act and Article 6(1)(f) of the GDPR, as processing necessary for legitimate interests that are not overridden by the interests of the data subject. The legitimate interest is promoting DJK A/S’s business and offering customers the best service and good offers.

• Disclosure of your information may take place in accordance with data protection legislation and other Danish legislation. In each case, we assess whether your explicit consent is required or whether disclosure can take place on another legal basis.

• If we share general customer information with other companies in the group for marketing purposes, we will comply with legal requirements, including giving you the opportunity to object. Disclosure will take place under Article 6(1)(f) of the GDPR, based on the legitimate interest in promoting DJK A/S’s business and offering our customers the best service and good offers.

• The legal basis for processing solely for statistical and scientific purposes is Section 6(1) of the Danish Data Protection Act and Article 6(1)(e) of the GDPR, as processing necessary for a task carried out in the public interest. Only data necessary for the study is used and not for other purposes.

Data minimisation

We only collect, process, and store personal data necessary to fulfil our stated purposes. Legislation may also determine which types of data are required for our business operations. The type and extent of personal data we process may also be necessary to fulfil a contract or another legal obligation.

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Categories of recipients

We disclose or entrust personal data to the following categories of recipients:

• Banks in connection with payment administration
  Debt collection agencies and credit reference agencies in case of loan default and for credit assessments
• Tax authorities and other authorities for legally required reporting
• Other companies within the group for marketing activities in compliance with applicable rules
  Our data processors under data processing agreements

Security

We have implemented appropriate technical and organisational measures to prevent accidental or unlawful deletion, disclosure, loss, degradation, unauthorised access, misuse, or other unlawful processing of your data.

Deletion

We delete your information when it is no longer necessary. HAE Koncern generally follows the retention period required under the Bookkeeping Act. To ensure proper handling of recurring customer relationships, potential complaints, warranty obligations, and compliance requirements, we have assessed that it is necessary to retain data for up to five years plus the current year after the business relationship has ended.

Your rights

Under the law, you have several rights in relation to our processing of your personal data.

You can exercise your rights by contacting us. Our contact details are listed at the top of this policy.

We will respond to your request as soon as possible and no later than one month after receiving it.

• Right of access
  You have the right to access the data we process about you.
  
  
• Right to rectification
  You have the right to have inaccurate data corrected.
  
  
• Right to erasure
  In certain cases, you have the right to have data deleted before our general deletion time.
  
  
• Right to restriction of processing
  In certain cases, you have the right to restrict the processing of your data.
  
  
• Right to data portability
  You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to have it transferred to another data controller.
  
  
• Right to object
  You have the right to object to our processing of your data, including for marketing purposes.
  
  
• Right to be informed about new purposes
  If we wish to use your data for a purpose other than those previously stated, you have the right to be informed beforehand.
  
  
• Right to withdraw consent
  If our processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

If you are not satisfied with our response, you may lodge a complaint with the Danish Data Protection Agency (Datatilsynet). Contact details are available at www.datatilsynet.dk

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Last updated: 17-01-2024