COOKIE- & PRIVACY POLICY We respect the privacy of our clients & website visitors 19. Apr, 2021 Privacy Policy Welcome to Cookie Information A/S’s privacy notice. Cookie Information A/S and its subsidiaries, (collectively, the “Cookie Information Group” or “we” or “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website, register to use our products and services, or to attend events, and tell you about your privacy rights and how the law protects you. For the purposes of this privacy notice, the term, “Websites”, shall refer collectively to www.cookieinformation.com as well as the other websites that the Cookie Information Group operates and that link to this privacy notice. Who is data controller? The data controller for the processing described in this notice is: Cookie Information A/S Kristen Bernikows Gade 4, 1105 Copenhagen K, Denmark CVR 38758292 If you have questions regarding this Privacy Notice or about the Cookie Information Group’s privacy practices, please contact us by email at privacy@cookieinformation.com. INFORMATION we collect and how we collect it In the following we will tell you which types of personal data we may collect about you and how we collect it. In section 3 we have in a table explained the purposes for which we process your personal data and the lawful basis we rely on. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data includes name, username, title and identity of the organisation you represent. Contact Data includes email, telephone numbers and address (most often the address of the organisation you represent). Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Usage Data includes information about how you use and interact with our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Our products and services are mainly offered to businesses and other professional organisations. Financial data and transactional data will in consequence only rarely qualify as Personal Data as it relates to the organisation you represent and not you. In most situations the information is collected directly from you when you register to use our products and services, request marketing from us or otherwise communicate with us. As you interact with our website or services, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. We may receive Identity and Contact Data from the organisation you represent if you are authorized to log into and utilize our products and services in connection with your organisations account. The purposes and the lawful basis We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract, we are about to enter into or have entered into with you or the organisation you represent cf. GDPR Article 6 (1) (b). Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests cf. GDPR Article 6 (1) (f). Where we need to comply with a legal or regulatory obligation cf. GDPR Article 6 (1) (c). Where you have provided your consent cf. GDPR Article 6 (1) (a). We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer or as contact person for the organisation you represent (a) Identity (b) Contact i. Performance of a contract with you ii. Necessary for our legitimate interests to perform a contract with the organisation you represent To manage and perform the contract with you or the organisation you represent including: (a) enable you to access and use the Services, (b) to provide customer service and support (c) Manage payments, fees and charges (d) Collect and recover money owed to us (e) to send you technical notices, updates, security alerts, and support and administrative messages (a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical data (f) Profile i. Performance of a contract with you ii. Necessary for our legitimate interests to perform a contract with the organisation you represent iii. Necessary to comply with a legal obligation (Bookkeeping, Accounting and Tax) To enable you to participate in events (a) Identity (b) Contact (a) Performance of a contract with you To send you newsletters or other marketing (a) Identity (b) Contact (c) Marketing and Communications (a) Your consent to receive e-marketing (b) Necessary for our legitimate interests to send you relevant marketing To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (d) Usage (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security and to prevent fraud To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage a) your consent(s) to our use of cookies for one or more purposes b) Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical a) your consent(s) to our use of cookies for one or more purposes b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@cookieinformation.com. SHARING OF INFORMATION COLLECTED Third-Party Service Providers: We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites and Services, application development, backup, storage, payment processing, marketing, analytics, and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for any other purpose than in connection with the services they provide to us. We have entered into data processor agreements with all of our data processors. Compliance with Laws and Law Enforcement Requests; Protection of Our Rights: In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as otherwise required by law. Testimonials: From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent cf. GDPR art 6(1)(a) to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@cookieinformation.com. Cookie Information Group Sharing: We may share information, including personal information, with any member of the Cookie Information Group, and they will use that information only for the purposes already described in this privacy notice. Business Transfers We may assign or transfer your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to handle your personal information in accordance with this privacy notice. Transfer to third countries We will not transfer your personal data to recipients outside EU or EEA unless we have ensured compliance with GDPR Chapter V. Some of our third-party service providers are established outside the EEA, including in the US so their processing of your personal data will involve a transfer of data outside the EEA. However, to ensure that your personal information receive an adequate level of protection we have ascertained that sufficient safety measures have been implemented to allow for the transfer either by an adequacy decision made by the European Commission or by use of standard contractual clauses approved by the European Commission which give personal data the same protection it has in Europe. You may request more information on our current data processors established outside the EEA and the safety measures in place to allow for the transfer of personal data– please send your request to us at privacy@cookieinformation.com. DATA RETENTION We retain the personal information we collect where we have an ongoing legitimate business need to do so. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. Identity, Contact, Financial and Transaction Data is saved to demonstrate the agreement we have/have had and for book keeping and tax purposes for up to five full fiscal years after the expiry of the year in which you or the organisation you represent cancel the Service Account. Your consent to receive e-marketing will be saved for two years after the last time we relied on your consent to send marketing. We will stop sending you e-marketing when you withdraw your consent. Technical and Usage Data will be deleted 3 months after you or the organisation you represent cancel the Service Account. Data may be retained for longer period if we are legally obliged to do so, or if retention is necessary to establish, exercise or defend legal claims. HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations: Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to privacy@cookieinformation.com. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. Request the transfer of your personal information to another party (also known as data portability). Where our processing is solely based on your specific consent you have the right to with-draw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. If you wish to exercise any of the data protection rights that are available to you then please send your request to privacy@cookieinformation.com and we will action your request in accordance with applicable data protection laws. You have the right to complain to your local data protection authority if you are unhappy with our data protection practices. In Denmark you can lodge a complaint with Datatilsynet at [https://www.datatilsynet.dk/databeskyttelse/klage-til-datatilsynet]. CHANGES TO THIS PRIVACY NOTICE This privacy notice may be updated from time to time to reflect changing legal, regulatory, or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices. If there are any material changes to this privacy notice, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. If you do not accept any changes made to this privacy notice, please discontinue the use of the Websites and the services. Cookie Policy DPO Contact information Att.: Data protection officer Kristen Bernikows Gade 4, 1105 Copenhagen K, Denmark privacy@cookieinformation.com About us Cookie Information is a Privacy Tech company specialized in developing software that helps you and your company making your websites and mobile apps GDPR and ePrivacy compliant. 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