PROCESSING PERSONAL DATA
When you sign up for, log into, or otherwise access or use the Platform or Platform Functionality/Services, We may collect and otherwise process, as described below, personal data that you provide in doing so. We, respectively, may process such personal data for the purposes of providing, maintaining and improving the Platform or Platform Functionality/Services, and for other purposes described below. Except as indicated below, We will process such personal data as data controller and, in turn, We determine the purposes for and means of processing such personal data.
Where We transfer personal data as data controller to another data controller for purposes and means determined by the data controller receiving the personal data, that data controller is an independent data controller for the personal data transferred and shall bear all responsibilities of a data controller towards the data subjects of the personal data transferred. Conversely, We are an independent data controller when We receive personal data from another data controller to process for Our determined purposes and by Our determined means. In both such cases, each independent data controller acknowledges and agrees that each is responsible for ensuring that it has a legal basis for its processing of personal data, as required under applicable data protection laws, including, but not limited to, documenting and demonstrating compliance with applicable data protection requirements, informing data subjects of the transfer and processing of their personal data, handling complaints and data breaches and implementing appropriate security measures.
Where in relation to some services, We also may process on your behalf personal data that you as data controller of that personal data input into the Platform or Platform Functionality/Services (or otherwise provide to Us), you are the data controller of such personal data. We will process such personal data on your behalf as a data processor in accordance with a separate data processing agreement which may be incorporated by reference within and linked to the Platform-Terms Landing Page (and defined therein as the “Platform Data Processing Agreement”), or executed separately.
If you would like additional information about the personal data that We process, please contact Us at firstname.lastname@example.org.
CATEGORIES OF PERSONAL DATA AND PURPOSES OF PROCESSING
We, respectively, collect and otherwise process the following categories of personal data for the following purposes:
- Your contact information and other basic personal data that you actively input into Our online platform(s), e.g. name, phone number, e-mail/physical address, name of employer, work title, payment or location details containing personal data, etc. We, respectively, may process such personal data to provide you secure access to and to operate, maintain, market and improve the Platform and Platform Functionality/Services or other services that We may provide, and to deliver an enhanced user experience, legal basis GDPR article 6 (1) (b), (f) and (a), where applicable. We also may process your personal data to handle orders, deliver services, process payments and communicate with you about the Platform or Platform Functionality/Services or other services that We, respectively, may provide, as well as to provide and analyze functionality and performance and to correct any errors in functionality or performance. Please note that, should you choose not to provide certain requested information, your access to/use of all or parts of the Platform or Platform Functionality/Services may be limited.
- Other personal data that you actively input into Our online platform(s), if applicable. If, in the context of accessing/using the Platform or Platform Functionality/Services, or Our respective other applications, websites or other online platforms, you input personal data beyond your contact information and other basic personal data of yours, you shall control its collection or management, as data controller, and We shall process same on your behalf, as data processor and in accordance with the data processing agreement incorporated by reference within the Platform-Term Landing Page, or executed separately, if applicable. We do not intend to collect, manage or otherwise process special category data, and, if you choose to input such data, We shall not be responsible for same.
- Personal data We receive from third parties, e.g., search engine providers, social media platforms, etc. If you use such services to interact with Us, including, without limitation, through Our respective applications, websites or other online platforms, or Our respective social media pages, We may collect and otherwise process your personal data provided by such services, e.g., information regarding your specific interests, usage, background information, “likes”, etc. If you want to restrict the information that such third parties share with Us, please do so directly with such third parties, e.g., via their respective applications, websites and other online platforms. We strongly recommend that you read carefully the privacy policies and practices of such third parties on their respective applications, websites, other online platforms, and otherwise.
We may combine the personal data that We receive from third parties with personal data that you provide to Us or that We automatically collect. Doing so enables Us to personalize Our marketing materials to your specific interests and preferences.
We may use automated decision-making in processing your personal data, such as, for example, as part of Our fraud prevention and detection efforts for Our respective online platforms. You may request information about the applicable decision-making methodology by contacting email@example.com.
ACCESS TO PERSONAL DATA
We may use data processors to process personal data on Our behalf pursuant to Our instructions. In such cases, We will implement or cause to be implemented appropriate safeguards to secure personal data.
Certain personal data that We process, respectively, may be accessible by Our Affiliates worldwide and We may actively share certain personal data among Our Affiliates on a need to know basis. In addition, We sometimes use external service providers for hosting and operating Our digital platforms, services and offerings and personal data that We process may be accessed and processed by such service providers on Our behalf.
Please be informed that the level of personal data protection currently applied and enforced in countries outside the European Union may not conform to the level of personal data protection currently applied and enforced within the European Union. Any transfer of data between/among Our Affiliates will be subject to the European Commission’s Standard Contractual Clauses. Similarly, We may engage third party service providers that will have access to and process personal data that We process. When such third-party service providers process such personal data outside of the EU/EEA, any related transfer of personal data will be subject to the European Commission’s Standard Contractual Clauses, combined with supplementary measures, where appropriate. You can request a copy of any agreements covering the transfer of your personal data by contacting firstname.lastname@example.org.
STORAGE AND SECURITY OF PERSONAL DATA
We may store personal data, such as your name, e-mail address and other contact information needed to operate and provide you with access to/use of the Platform and Platform Functionality/Services without disruption, for the Retention Period defined in the Platform-Terms Landing Page, unless We are required under applicable law to keep your personal data for a longer or shorter period of time. No personal data shall be kept for longer than what applicable law requires beyond the Retention Period, whereafter it shall be automatically deleted or returned to you, where applicable.
Under applicable law, We may be required to be able to document that you have provided consent to receive marketing materials. We, therefore, may keep personal data needed to demonstrate compliance, which personal data We shall keep for up to five years after consent has been revoked or the personal data no longer is needed for the purposes for which it initially was processed.
All personal data shall be processed in a manner that ensures appropriate security, integrity and confidentiality thereof, including, for example, protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures, such as encryption protocols and software, pseudonymization/anonymization, where applicable, access controls, authentication mechanisms and physical, operational and information security.
RIGHTS OF THE DATA SUBJECT UNDER GDPR
Under GDPR, data subjects have certain rights regarding Our processing of their respective personal data, including the rights described below. If you want to exercise those rights, please contact email@example.com.
Right of access
You have the right to obtain access to the personal data that We process about you, as well as certain additional information regarding Our processing.
Right to rectification
You have the right to obtain rectification of inaccurate personal data that We process about you.
Right to erasure
In certain cases, you have the right to obtain erasure of your personal data, before any general obligation on Our part to erase your personal data arises.
Right to restriction of processing
In certain cases, you have the right to obtain restriction of the processing of your personal data. Where the processing has been restricted, such personal data shall, with the exception of storage, be processed only with the data subject’s consent, for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
Right to object
In certain cases, you have the right to object to Our lawful processing of your personal data. You shall also have the right to object to a processing of your personal data for direct marketing purposes.
Right to data portability
In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and the right to transmit such data to another data controller without hindrance.
The right to withdraw your consent
When processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing carried out prior to your withdrawal of the consent.
If you have any complaints about Our processing of your personal data, you may contact the Danish Data Protection Agency (or other relevant supervisory authority). You can find their contact information here.
PROVISIONS FOR RESIDENTS OUTSIDE THE EU
If you are not a resident of a European Union Member State, local data privacy laws also may apply to you. Some of those local data privacy laws are addressed below.
SPECIFIC DATA PRIVACY DISCLOSURES AND NOTICES FOR CALIFORNIA RESIDENTS
If you are a California citizen or resident, the California Consumer Privacy Act and other California law may provide you with specific rights regarding Our use of your personal data. To learn more, click here: https://ramboll.com/legal-information/disclosures-and-notices-for-california-residents.
Summary of changes
6th April 2021