Processing of personal data about customers etc. at Ajos

Ajos will on a continuous basis electronically/automatically process various personal data about you. We are therefore under obligation to notify you of the personal data we collect, record, disclose or otherwise process about you.

1 INTRODUCTORY REMARKS

1.1 Purpose 

1.1.1 Ajos (hereinafter referred to as ‘the Company’) will on a continuous basis electronically/automatically process various personal data about you. We are therefore under obligation to notify you of the personal data we collect, record, disclose or otherwise process about you. 

1.1.2 When you use the Company’s website or otherwise contact or interact with us, the Company acts as data controller and processes various personal data about you. 

1.1.3 The purpose of processing your personal data is generally the management of our customer relationship with you, including as it relates to agreed services, obligations etc. 

1.1.4 This Privacy Policy contains information about how we process personal data about you when you use www.ajos.dk, when you subscribe to a newsletter, when you enter into a contract with us, when you contact us and when we receive information about you from a third party. All these personal data are processed in compliance with the guidelines and frameworks set out by data protection legislation. 

1.1.5 Our website also uses cookies and similar technologies to collect and process data about our visitors’ use of our website and services. If you should wish to find out more about our use of cookies and similar technologies, please read our Cookie Policy which can be found here: www.ajos.dk/om-ajos-cookiepolitik.aspx

1.1.6 You are always welcome to contact us at ajos@ajos.dk if you have questions about our processing of personal data. See also point 8 below in which we describe your rights and provide further contact details.

2 PROCESSING OF PERSONAL DATA IN OUR RELATIONSHIP WITH CUSTOMERS ETC.

2.1 Company representative

2.1.1 When you enter into a contract with or are an existing customer, partner, supplier, etc. with the Company, we create a file on you and the company you represent in our IT system. We record a range of different personal data which as a rule you yourself have provided. 

2.1.2 We record identification data, including your name, job title, work as well as your contact details, including work telephone numbers, work e-mail addresses or other personal data with which you may provide us.

2.1.3 The legal basis for processing your personal data is our legitimate interest in being able to fulfil the contract that we have entered into with the company you represent, including being able to contact you and supply the products/services on which we have agreed. Similarly, we may use your contact details when invoicing the company you represent. The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation (EU) 2016/679 of 27 April 2016). 

2.1.4 The information in the system can be combined with information about other customers, partners, suppliers, website visitors etc., e.g. to generate various forms of statistics and calculations.

2.1.5 The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation. Our legitimate interest is the potential optimisation of our current services or the development of new services which the processing attempts to achieve. 

2.2 Customer relationship as a private individual

2.2.1 When you enter into a contract with or are an existing customer with the Company, we create a file on you in our IT system. We record a range of different personal data which as a rule you yourself have provided. 

2.2.2 We record identification data, such as your name, your contact details, including work telephone numbers, address, e-mail address or other personal data with which you may provide us. We likewise record applicable payment details. 

2.2.3 The legal basis for the processing of your data is the fulfilment of the contract that we have entered into with you, cf. Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para b of the General Data Protection Regulation. 

2.2.4 The information in the system can be combined with information about other customers, e.g. to generate various forms of statistics and calculations.

2.2.5 The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation. Our legitimate interest is the potential optimisation of our current services or the development of new services which the processing attempts to achieve. 

3 PROCESSING OF PERSONAL DATA IN OTHER CONTEXTS

3.1 Enquiries

3.1.1 When you contact us by e-mail or otherwise contact us, your enquiry will sometimes contain personal data, e.g. contact details, your association with a certain company or other personal data with which you may provide us. We process these data in order to process and respond to your enquiry.

3.1.2 The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation. Our legitimate interest is our processing of and response to your enquiry. 

3.2 If you contact us as a private individual as part of an existing customer relationship with us, the legal basis may instead be the fulfilment of the agreement we have entered into, cf. Sec-tion 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para b of the General Data Protection Regulation.  

3.2.1 We may also use your enquiry and thereby the personal data contained therein as part of the optimisation of our current services or for the development of new services, e.g. by preparing statistics on enquiries received or applying anonymisation of enquiries received in order to use them at a later date.

3.2.2 The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation. Our legitimate interests are the potential optimisation of our current services or the development of new services which the processing attempts to achieve. 

3.3 Customer portal (smartBYG)

3.3.1 When you are registered in our customer portal, certain personal data about you are processed, e.g. your contact information, your association with a certain company or other personal data that you or others may give us. We process these data in order to allow you to use our customer portal.

3.3.2 If you are a representative of a company, the legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation. Our legitimate interest is the fulfilment of the agreement we have entered into with the company you represent, including giving you user access to and allowing you to use our customer portal. If you are a private individual the legal basis is the fulfilment of a contract, cf. Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para b of the General Data Protection Regulation.  

3.3.3 We may also use data related to your enquiry and thereby the personal data contained therein and data about your use of our customer portal as part of the optimisation of our current services or for the development of new services, e.g. by preparing statistics on enquiries received or applying anonymisation of enquiries received in order to use them at a later date.

3.3.4 The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation. Our legitimate interests are the potential optimisation of our current services or the development of new services which the processing attempts to achieve.

3.4 Newsletters

3.4.1 If you subscribe to our newsletter, we register your e-mail address and other contact details, if applicable, which may constitute personal data, in order to send you our newsletters and offers. In some instances, we also register other data with which you may specifically provide us.

3.4.2 We use these additional data in order to customise the offers and news we send you. 

3.4.3 The legal basis for the above processing is the consent you give when you subscribe to our newsletter. The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para a of the General Data Protection Regulation. 

3.4.4 You are entitled to withdraw your consent at any time. You can do this e.g. by contacting us using the details provided in point 8.1 below. We usually process your personal data until you withdraw your consent to receiving our newsletters.

3.5 Cookies

3.5.1 Our website uses cookies and similar technologies to collect and process data about our visitors’ use of our website and services. If you should wish to find out more about our use of cookies and similar technologies, please read our Cookie Policy which can be found here: www.ajos.dk/om-ajos-cookiepolitik.aspx.

3.5.2 The legal basis is your consent given pursuant to the Cookie Regulation (Regulation no. 1148 of 9 December 2012 on requirements for information and consent in the storage of or access to information in the end user’s terminal equipment).

4 INFORMATION RECEIVED FROM THIRD PARTIES

4.1.1 Sometimes we may receive personal data about you from third parties, e.g. your employer or your colleagues. These data may include your contact details and information about your as-sociation with your employer. Sometimes we may register the data we receive from a third party about you in our IT system or elsewhere as a potential lead or representative of a company so that we can contact you with information about and offers for our services as well as contact you about our on-going customer relationship with the company you represent.

4.1.2 Our authority to process data as described in point 4.1.1 is the pursuit of our legitimate interests. Our legitimate interests are (i) the potential sale of our products and/or services and (ii) our interest in being able to contact you in your capacity as a contact, if applicable, for the company you represent. The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation.

4.1.3 We may also use data received from third parties and thereby the personal data contained therein as part of the optimisation of our current services or for the development of new services, e.g. by preparing statistics on enquiries received or applying anonymisation of enquiries received in order to use them at a later date.

4.1.4 Our authority to process data as described in point 4.1.3 is the pursuit of our legitimate interest. Our legitimate interest is the potential optimisation of our current services or the development of new services which the processing attempts to achieve. The legal basis is Section 6, sub-section 1 of the Danish Data Protection Act, cf. Article 6, sub-section 1, para f of the General Data Protection Regulation.

5 RECIPIENTS AND DISCLOSURE ETC.

5.1 Recipients

5.1.1 Some data are stored with our data processors as part of the operational and IT security work (e.g. backup, website hosting etc.) that we outsource. Storage of date with external partners (our data processors) is subject to the provisions contained in the General Data Protection Regulation and the Danish Data Protection Act. Data processing agreements with data processors have been entered into in order to ensure that your information is not disclosed to unauthorised parties.

5.1.2 We do not as a rule disclose personal data under this policy to third parties without your con-sent unless we are under obligation to do so pursuant to the law or if this is necessary in order to pursue the objectives described above. Our authority for such disclosure will as a rule be the same as described above as it applies to our own processing.

5.1.3 Your personal data may in certain cases be disclosed to our external legal advisors for use in a specific project. This may be if the Company requires legal assistance in a case in which you are involved and where the applicable personal data are required by our legal advisors. 

5.2 Transfer to third countries 

5.2.1 Data associated with customer satisfaction surveys may be transferred to countries outside the EU/EEA. This is due to the fact that our data processor is located in the United States. 

5.2.2 Transfer of your personal data to the United States takes place on the basis of standard EU contracts on the transfer of personal data to third countries which thereby guarantees a sufficient level of protection. You are entitled to receive a copy of the basis for such transfer if you contact us (please see our contact details under point 8 below).

6 STORAGE RESTRICTION

6.1 Erasure policy

6.1.1 The Company has prepared a policy that describes how and when we delete personal data. If you wish to know more about our time limits for erasure, please contact us using the details under point 8.

6.2 Request for erase

6.2.1 When you contact us with a request to have your personal data rectified or erased, we check whether conditions have been met and, if so, implement rectification or erasure as soon as possible. 

7 YOUR RIGHTS

7.1 Pursuant to data protection legislation, you have rights as regards our processing of your personal data. 

7.2 You are entitled to:
• apply for access to information about the data we process about you (pursuant to Article 15 of the General Data Protection Regulation)
• apply for us to rectify the personal data we process about you (pursuant to Article 16 of the General Data Protection Regulation)
• apply for us to erase the personal data we process about you (pursuant to Article 17 of the General Data Protection Regulation)
• apply for us to restrict the personal data we process about you (pursuant to Article 18 of the General Data Protection Regulation) 
• apply for data portability to the extent that this may be applicable (pursuant to Article 20 of the General Data Protection Regulation)
• object to our processing of your personal data (pursuant to Article 21 of the General Data Protection Regulation)

8 CONTACT DETAILS 

8.1 To the extent that you may have questions about the above or your rights under data protection legislation, please contact the Company as follows: 
E-mail: ajos@ajos.dk

Find out more about Danish data protection legislation and your rights on the Danish Data Protection Agency website at www.datatilsynet.dk. The Danish Data Protection Agency is the government body that in the final instance is able to assess whether your personal data are being processed legally - e.g. as part of a complaint. 

The contact details for the Danish Data Protection Agency are: Datatilsynet, Borgergade 28, 5., 1300 Copenhagen K, telephone 3319 3200, dt@datatilsynet.dk. See also https://www.datatilsynet.dk/om-datatilsynet/kontakt/

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