1. General terms and Data Controller
1.3 Data Controller for the Website is Contour Design (please find contact information in clause 7 below).
2. Categories of personal data that we collect, purpose and legal basis
2.1 When you visit the Website, we collection information about you and your use of the Website, for instance when you subscribe to our newsletter, participate in competitions, etc. We also collect cookies. You can read more about the changes below.
2.2 Goods on approval
2.2.1 When you make a request for goods on approval, we register your name, company, e-mail address, telephone number, information about the goods you have on approval and information about the IP address from which you placed your order.
The purpose is to deliver the products you have requested for approval and otherwise fulfil our obligations under our agreement with you, execute your request for goods on approval or pass it on to the relevant dealer in charge of the goods on approval. The legal basis for the processing is thus our agreement with you.
2.3.1 When you subscribe for our newsletters, we collect, based on your consent, information about your name and e-mail address.
The purpose is to provide you with offers, targeted marketing, information and service e-mails. We may profile you based on your information, and any cookies, for purposes of marketing products, etc. that may be of interest to you. The legal basis is your consent.
2.4 Contact via web, including contact form and support form on the Website
2.4.1 When you contact us, say, in connection with an order, a request or a complaint, we process your identification information, such as name, e-mail, and other personal data about you that you provide when contacting us.
The purpose is to provide customer service, respond to requests, handle complaints, etc. The legal basis may be the agreement with you as a customer, our legitimate interest in defending ourselves in case of legal claims and/or legal obligations. If, while contacting us via the Website, you have provided health information, the processing of such information is based on your explicit consent. You may withdraw your consent at any time.
2.5 Media portal for dealers and customer data
2.5.1 As a dealer, you can get access to our SharePoint media portal. We will process your e-mail address in that connection.
The purpose of such processing is to use your e-mail address to give you access to the media portal so that you can access marketing material. The legal basis is the agreement with you as dealer or, alternatively, if you are employed with the dealer, Contour Design’s legitimate interests in your having access, on behalf of the dealer, to the marketing material for purposes of your work.
2.5.2 In connection with the placing of orders, we process data about our customers’ contact persons. Such data are typically name, business address, telephone number and e-mail.
The purpose of the processing is to handle orders placed by our customers and deliver the products ordered to the customer’s store. The legal basis is Contour Design’s and the customer’s legitimate interests in the sale/purchase and compliance with legal requirements.
2.6 User reviews received via a form on the Website
2.6.1 If you are a user of one of our products, you may file a user review on the Website. In this connection, we will collect your name, position, company (optional information), e-mail address, information about product name as well as any other information you might provide about yourself along with a description of your experience with our product (including any health information provided by you in your user review).
The purpose of the processing is to publish your user review for marketing purposes on the Website. The legal basis is your explicit consent. You may withdraw your consent at any time.
3. Data protection of children
3.1 We are aware of the special need for data protection involving children.
3.2 We do not purposefully collect personal data about children below the age of 13, unless we have the consent of the custodial parent or guardian. If you believe that we have collected personal data about children below the age of 13, we kindly ask you to contact us so that we may delete such information.
5. With whom do we share your personal data?
5.1 Independent Data Controllers
We pass on your personal data when necessary to be able to deliver products to you, for instance when sending you goods on approval where the nearest dealer (or the dealer chosen by you) is to handle the goods on approval and will contact you to arrange for the free trial period. In such a case, your name, e-mail, telephone number and specific delivery preferences may be passed on to the dealer or one or more carriers handling the physical delivery of the goods. If the goods on approval are provided by Contour Design, and you decide to purchase the product, we will pass on your personal data to the nearest dealer (or the dealer chosen by you), who will then complete the purchase agreement with you and subsequently bill you.
In connection with the use of the contact form, the support form, requests to have goods on approval and the user review form, such forms will be passed on to other entities in the Contour Design Group as well as local business partners (distributors) with a view to responding to your request.
5.2 Data Processors
5.2.1 We pass on personal data to data processors who are solely processing personal data on our behalf and who are not allowed to use such data for their own purposes. We have entered into agreements with all data processors and ensured that they are subject to confidentiality.
5.2.2 Data processors may be based in the EU/EEA or in other countries provided that we can ensure adequate processing security of your personal data. We use data processors for, among other purposes, technical operation and improvement of the Website, distribution of newsletters and targeted marketing, including retargeting. Some of these data processors are located in the USA (Google, Facebook, LinkedIn and Mailchimp). The necessary guarantees for the passing on of personal data to the USA are ensured through their certification under the EU-U.S. Privacy Shield.
6. Your rights as a data subject
6.1 You are entitled to have access to your personal data.
6.1.1 You are entitled, at any time, to be informed about which personal data we process about you, from which source they originate and what we use them for, etc. You may ask for a copy of these personal data. Access may be limited in consideration of other data subjects’ rights, trade secrets and/or intellectual property rights.
6.1.2 In certain instances, you may also be entitled to have an electronic copy of your personal data or have the personal data passed on to another data controller provided that the processing is based on consent or agreement (so-called data portability).
6.2 You are entitled to have incorrect personal data corrected or deleted.
6.2.1 If you believe that the personal data we are processing about you are incorrect, you are entitled to have them corrected.
6.2.2 In some instances, we will be obliged to delete your personal data. For instance in the event that you withdraw your consent. If you believe that your personal data are no longer necessary to meet the purpose for which we collected them, you may request to have them deleted. You may also contact us if you believe that your personal data are processed contrary to Danish legislation or other legal obligations.
6.2.3 When you contact us to request to have your personal data corrected or deleted, we will investigate if your request is justified and, if so, we will correct or delete your personal data as quickly as possible.
6.3 You are entitled to object to our processing of your personal data.
6.3.1 You are entitled to object to our processing of your personal data. You may also object to the processing of your data for direct marketing purposes. If your objection is justified, we will make sure to cease processing your personal data.
6.4 Right to withdraw your consent
6.4.1 You are entitled, at any time, to withdraw a consent you have given us to process personal data. If you wish to withdraw your consent, please contact us via e-mail at firstname.lastname@example.org.
6.5 How to exercise your rights?
6.5.1 You may exercise your rights by contacting us.
6.6.1 If you wish to complain about our processing of your personal data, you may also contact the Danish Data Protection Agency (Datatilsynet), Borgergade 28, 5th floor, 1300 Copenhagen K, Denmark. You may lodge a complaint via e-mail email@example.com or tel. +45 33 19 32 00. Or you can contact The Information Commissioner’s Office, Water Lane, Wycliffe House, Wilmslow – Cheshire SK9 5AF – www.ico.org.uk.
7. Contact information
7.1 If you have any questions or wish to exercise your rights, please contact us.
Contour Design Nordic A/S
Borupvang 5B, st.tv.
Tel.: +45 7027 0227
8. Deletion of personal data
8.1 Information collected using cookies, etc. will be deleted as set out in clause 4 above.
8.2 In the event that you withdraw your consent to receive our newsletter, we will register your un-subscription, and you will not receive further communications. We will store information about your un-subscription for as long as such documentary evidence is required by law.
8.3 Information collected in connection with your purchases via the Website will be stored for five years to the end of a financial year to meet the requirements of the Danish Bookkeeping Act.
8.4 Information collected in connection with the ordering of goods on approval on the Website will be kept on file for 12 months.
8.5 Information collected in connection with approaches via the contact form on the Website and/or via e-mail to firstname.lastname@example.org will be stored for six months. Any health information provided by you via the contact form will be deleted at an earlier point in time in the event that you withdraw your consent.
8.6 Information collected in connection with support approaches via the support contact form on the Website and/or via e-mail to email@example.com will be stored for three years. Any health information provided by you via the contact form will be deleted at an earlier point in time in the event that you withdraw your consent.
8.7 Information collected in connection with use of our SharePoint media portal for dealers will be stored until you are no longer a dealer or, if you are employed with the dealer, when the dealer informs us that you can no longer have access to the media portal for purposes of your work.
8.8 Information collected in connection with your filing of a user review will be kept on file only until the product is discontinued, if not deleted earlier. The user review will be deleted before the product is discontinued in the event that you withdraw your consent to the processing.
9.1 We have of course taken technical and organisational measures to avoid that, by mistake or illegal conduct, your personal data are deleted, published, lost, impaired, come to the knowledge of third parties, are misused or otherwise processed in manner contrary to applicable law.
9.2 Only employees who have a real need to access your personal data in order to perform their job will be granted access to your personal data.
[Version 1 – 10 July 2018]
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