Emdrupvej 26, 2.
2100 København Ø
Company registration number: 50810216
1.2 The Policy is prepared and made available to comply with the general data protection regulation (2016/679 of 27 April 2016) (the ”GDPR”) and the rules included herein on information to be provided to you.
2. Collecting personal data with cookies
2.1 By visiting and using our website(s), cookies are collected and used on the basis of consent. Information in these cookies includes browser type, search terms on our website(s), search terms on other website(s), IP address. We also collect the type of computer and technical information about means of connection to our website or my7N, such as the operating system and the Internet service providers’ utilized and other similar information (hereinafter "Cookiedata").
2.2 Cookiedata is used for improvement of the website(s) and the user experience, to deliver our products, services or goods, administration of customer relationships in general (orders, purchase history, invoicing etc.), customer support and targeted marketing.
2.4 If you wish to limit or decline the cookies placed on your computer when visiting our website, you can do so at any time by changing your consent in the cookie box. You will find a shortcut to the cookie box in the left corner of the website. However, you should be aware that if you decline or reject cookies it will impact the functionality of the website which means that there are features on the website that you will not be able to see. Any browser also allows that you delete cookies collectively or individually. How this is done depends on the used browser. Remember to delete the cookies in all browsers if you use several different browsers.
2.5 How long the cookies are stored on your computer varies. For more information about the expiration of the cookies, please refer to the “cookie declaration” which you will find in the cookie box.
2.7We use Google Analytics as a web analytics service. This service provides statistical information about users of our website. Google Analytics processes among others IP addresses and information from cookies used on our website to clarify the number of page views, the number of users, which browsers the users use. This information does not contain personally identifiable data.We use Facebook Pixel to track visitor activity on our website. This means that Facebook collects the following information:
- Http Headers: Anything present in HTTP headers. HTTP Headers are a standard web protocol sent between any browser request and any server on the internet. HTTP Headers include IP addresses, information about the web browser, page location, document, referrer, and person using the website.
- Pixel specific Data: Includes Pixel ID and the Facebook Cookie.
- Button Click Data: Includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.
Among others, we track the following events: view content, search tracking, lead tracking on form submission, complete registration.
We use Facebook Pixel for the following purposes: Targeted marketing campaigns, including track conversions, remarket/build custom audience based on page visitors and to enhance the targeting of ads. The cookies that are placed on your computer expires after 90 days.
You can read more about the Facebook Pixel via the following links: https://www.facebook.com/business/learn/facebook-adspixel and https://www.facebook.com/privacy/explanation.
You can choose not to receive targeted marketing by changing your ad preferences and settings on your Facebook account or by following the link below: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
For more information about the cookies that we place on your computer, including third-party cookies, please refer to the “cookie declaration” which you will find in the cookie box.
3. Types of personal data processed
3.1 We process personal data about you when this is necessary and in accordance with the applicable legislation. Depending on the specific circumstances, the processed personal data include the following types of personal data: name, address, telephone number, email, invoicing and bookkeeping data and documentation, payment card details In addition, we also process the following types of personal data: IP Address, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform or other identifiable personal data only when it is voluntarily submitted.
Furthermore, we collect technical information about your visit including Uniform Resource Locators (URL) clickstream, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouseovers).
When using my7N, you may provide additional information to create a profile to be used to sell your services as a consultant to potential customers. Information provided may include CV, passport number and social security number. We will only collect and process your social security number with your explicit consent.
3.2 We do not collect sensitive personal data (so-called "special categories of personal data"), and we therefore only process such data if you send them to us on your own initiative.
3.3 As a general rule, we only collect personal data about you from you. If specific circumstances allow or require us to collect personal data about you from someone else than you, we will inform you hereof, which may be done by updating this Policy.
3.4 If we need to collect more personal data than what is specified above, we will inform about this. Such information may be provided by our updating of this Policy.
4. Purposes for processing the personal data
4.1 We only process personal data for legitimate purposes in accordance with the GDPR. Depending on the circumstances, the personal data is processed for the following purposes:
- (a) To deliver products or services to a user, customer or member.
- (b) To answer enquiries or complaints from users, customers or members.
- (c) To give support and service messages, including answering questions and complaints and send updates about our products and services.
- (d) To improve our products, services, or website.
4.2 We also process the personal data for the following purposes: for operation and maintenance purposes, including collecting files that record interaction with this Website and my7N (System Logs or IP Address), for legal purposes, including in Court or in the stages leading to possible legal action arising from improper use of this Website, my7N or related services and with respect to my7N, in order to create a profile of the user and to share this with potential customers for the purpose of selling the users services as a consultant.
5. Legal basis for processing personal data
5.1 We only process your personal data when we have a legal basis to do so in accordance with the GDPR. Depending on the specific circumstances, the processing of personal data is done on the following legal basis:
- a) If we have asked for a consent for the processing of specific personal data, the legal basis for such personal data is a consent, cf. article 6(1)(a) of the GDPR, as the consent can always be withdrawn by contacting us via the contact details provided at the end of this Policy, and, if the consent is withdrawn, the personal data processed on the basis of consent is deleted, unless it can or must be processed, for example, in order to comply with legal obligations.
- b) The processing is necessary for the purposes of the legitimate interests where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, cf. the GDPR, article 6(1)(f).
6. Disclosure and transfer of personal data
6.1 We only pass on personal data to others when the law allows it or requires it. Our company is part of a concern/company group where personal data is shared between the group companies depending on the circumstances.
6.2 We transfer personal data to the following recipients from the EU/EEA:
- (a) Banks (for example in connection with payments etc.).
- (b) Data processors.
- (c) Suppliers.
- (d) Collaborators.
6.3 We may transfer personal data to affiliate or subsidiary companies, as well as employees and service providers in charge of or involved in the operation of the Website or my7N (administration, sales, marketing, legal, system administration), as well as agents, and professional advisors. Furthermore, we may transfer personal data to external business partners, vendors, suppliers in order to deliver a service to us or on the behalf of us, such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies in order to assist in processing the personal data. The updated list of these parties may be requested at any time.
6.5 We transfer personal data to countries or international organizations outside the EU/ EEA.
6.6 If personal data is transferred outside of the EEA we ensure an adequate level of security by transferring to countries approved by the European Commission as having an adequate level of protection, or by entering into appropriately-drafted contract between us and the non-EEA entity receiving the data.
6.7 Our use of Facebook Pixel means that personal data may be transferred to Facebook Inc in USA. This transfer is based on Facebook Inc.'s self-certification under "EU-U.S. Privacy Shield" which you can read more about here: https://www.facebook.com/about/privacyshield.
For more information about Privacy Shield see www.privacyshield.gov.
7. Erasure and retention of personal data
7.1 We ensure that the personal data is deleted when it is no longer relevant for the processing purposes as described above. We also retain personal data to the extent that it is an obligation from applicable law, as is the case with for example accounting and bookkeeping materials and records. If you have any questions about our retention of personal data, please contact the email mentioned at the bottom of this Policy.
8. Data subject rights
8.1 Data subjects have a number of rights that we can assist with. If a data subject wants to make use of his or her rights, he or she can contact us. The rights include the following:
8.1.1 The right of access: Data subjects have a right to ask for copies of the information that we process about them, including relevant additional information.
8.1.2 The right to rectification: Data subjects have a right to ask for rectification of inaccurate personal data concerning him or her.
8.1.3 The right to erasure: In certain circumstances data subjects have a right to obtain the erasure of personal data concerning him or her before the time when erasure would normally occur.
8.1.4 The right to restrict processing: Data subjects have, in certain situations, a right to have the processing of his or her personal data restricted. If a data subject has the right to have the processing of his or her personal data restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest in the European Union or of a European member state.
8.1.5 The right to object: Data subjects have, in certain situations, a right to object to the legal processing of his or her personal data. Objection can also be to the processing of personal data for the purpose of direct marketing.
8.1.6 The right to data portability: Data subjects have, in certain situations, a right to receive his or her personal data in a structured, commonly used and machine readable format and have the right to transmit those data to another data controller without hindrance from the data controller to which the personal data has been provided.
8.2 More information about data subject rights can be found in the guidelines of the national data protection authorities.
If a data subject wishes to make use of his or her rights as described above, the data subject is asked to use the contact details provided at the end of this Policy.
We strive to do everything to meet wishes regarding our processing of personal data and the rights of data subjects. If you or others despite our endeavors wish to file a complaint, this can be done by contacting the national data protection authorities.
9. Changes to this Policy
9.1 We reserve the right to update and amend this Policy. If we do, we correct the date and the version at the bottom of this Policy. In case of significant changes, we will provide notification in the form of a visible notice, for example on our website or by direct message.
10.1 If you have questions or comments to this Policy or if you would like to invoke one or more data subject rights, please contact us at info.DK@7N.com.
This is version 5, last updated 12.08.2020.