1.1 This notice on processing of Personal Data (“Privacy Notice”) describes how CONXION A/S, CVR number 27 60 39 71, Enggårdsvej 11, 4700 Næstved (“CONXION”, “us”, “ours”, “we”) collect and process information about you when you communicate with us or use the website www.conxion.dk, the web shop conxion.linkwebshop.com or customer specific web shops that are named after the model [customer name].linkwebshop.com (the “Services”).
1.2 We only sell our products to businesses and the information we process will primarily concern the company you represent.
1.3 The Privacy Notice applies to the processing of personal data that you give to us or that we collect through the Services or other sources.
1.4 CONXION is the data controller for your personal data. All inquiries to CONXION may take place by using the contact information stated in Section 6.
2. PERSONAL DATA WE COLLECT, THE PURPOSES OF THE PROCESSING AND THE LEGAL BASIS
2.1 When you visit the Services: We automatically collect information about you and your use of the Services, when you visit the Services. This includes information about your IP address, which type of browser you use, the webpages you visit on the site, the links you activate and generally how you use the Services.
2.1.1 The purpose is to pursue our legitimate interest in optimizing user experience and to improve the function of the Services as well as to register for how long visitors use the Services and to show you relevant offers.
2.1.2 The legal basis for the processing is the General Data Protection
Regulation (“GDPR”) art. 6(1)(f), as we have found after completing a
balancing of interest test that the described activity does not infringe your interests and fundamental rights and freedoms.
2.2 When you represent a company that is our customer and open a user account: We collect information about your name, email address, phone number, which company you represent and other information you choose to provide us with, including if you save product ideas and ‘like’ products etc.
2.2.1 The purpose with the processing is to communicate with you, including by email and phone, to respond to inquiries and notifications of defects and to provide you and the company you represent the best possible service, including to take into account special wishes and needs as well as to give us the preconditions to offer the company you represent relevant products and marketing.
2.2.2 The legal basis for the processing is to pursue our legitimate interest in communicating with you and to provide you with the best possible service as well as to market our products to the company you represent, c.f. GDPR art. 6(1)(f), as we have found after completing a balancing of interest test that the described activity does not infringe your interests and fundamental rights and freedoms.
2.3 When you purchase our products: We collect information about your name, which company you represent, your email address and phone number, possibly your picture (optional), method of payment, information on which products you buy on behalf of the company that you represent, delivery wishes etc.
2.3.1 The purpose with the processing is to deliver the products you have ordered and to perform the contract we have entered into with you/the company you represent.
2.3.2 The legal basis for the processing is to perform the contract and to deliver the products that have been purchased, c.f. GDPR art. 6(1)(b).
2.4 When you subscribe to our newsletters and request to receive other marketing material, including electronically: We collect information about your name, email address, which company you represent and your consent to receive direct marketing.
2.4.1 The purpose of the processing is to send you newsletters and to pursue our legitimate interest in sending you marketing material.
2.4.2 The legal basis for the processing is GDPR art. 6(1)(f). We will only send you e-marketing if you specifically have given your consent to receive such e-marketing.
3. RECEPIENTS OF PERSONAL DATA, INCLUDING THIRD COUNTRY TRANSFERS
3.1 Vi only share your Personal Data with third parties when we are obligated to so according to law or to deliver the services and products we offer through the Services.
3.2 Disclosure to data controllers: Information that you have provided to us in connection with a purchase is disclosed to the supplier whose products you have purchased. The disclosure is necessary to complete the purchase including to deliver the products.
3.3 Disclosure to data processors: Your information may be handed over to external business partners that process Personal Data on our behalf. We use external business partners for inter alia technical operations and improvement of the Services, analysis, distribution of newsletters as well as targeted advertising. One of these suppliers is
Link Network ApS, CVR number 35 65 95 60, which is the supplier of the technical purchase platform that facilitates several product suppliers’ offers and compiles orders from several buyers to the suppliers. Link Network ApS also facilitates the payment function and hosts our web shops. These companies are data processors and are under our instruction and process data that we are data controllers for. Data processors may not use Personal Data for other
purposes than to fulfil the agreement with is and are under a duty of confidentiality with regard to such data. We have entered into written data processor agreements with all data processors that process Personal Data on our behalf.
3.4 One of these data processors, Google Analytics v/Google LLC, is established in the United States. The appropriate safeguards for the transfer of Personal Data to the United Stated are secured through the data processors certification under the EU-U.S Privacy Shield, c.f. GDPR art. 45. A copy of Google LLC’s certification can be found here: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI.
4. WHEN WE DELETE YOUR PERSONAL DATA
4.1 Information collected about your use of the Services is deleted if you have not used the Services for 18 months.
4.2 If you have not signed into your account for a period of more than 18 months, we will delete your account and the information we have registered about you. You can also delete your account via the profile settings on the Services. We will however keep information about your purchases to fulfil our legal obligations in accordance with
Bookkeeping, Accounting and Tax legislation.
4.3 The information may be kept for a longer period, i) if we have a legitimate interest in storing the information for a longer period, ii) if it is necessary to establish, exercise or defend a legal claim, or iii) if the storing is necessary to comply with legal obligations. Accounting material is kept for 5 years until the end of the accounting year to comply with the requirements in the Danish Bookkeeping Act.
4.4 Information collected about your feedback on our newsletters is deleted when you withdraw consent to receiving our newsletters. Documentation on your consent to receive direct marketing will be stored for 2 years in order to document that we have not violated the law by sending you marketing material.
5. YOUR RIGHTS
5.1 With a view to create transparency on the processing of your Personal Data, we provide you with information on your rights in this section.
5.2 Right of access: You are entitled at any time to request information on inter alia the information we have registered about you, which purposes the registration serves, the categories of Personal Data and recipients of Personal Data there might be as well as
information on where the data stems from. You also have the right to receive a copy of the Personal Data that we process about you.
5.3 Right to rectification: You have the right to have inaccurate Personal Data about you rectified by us.
5.4 Right to erasure: Under certain circumstances you have the right to have all or some of your Personal Data erased, for example if you withdraw your consent and we do not have another legal basis enabling us to carry on with the processing. To the extent a continued processing of your Personal Data is necessary, e.g. to comply with
legal obligations or to establish, exercise or defend a legal claim, we are not obligated to erase your Personal Data.
5.5 Right to restrict the processing to storage: Under certain circumstances you have the right to restrict the processing of your Personal Data to only consist of storage, for example if you are of the opinion that the information we process about you is inaccurate.
5.6 Right to object: You have the right to object to our processing of your Personal Data when used for direct marketing purposes. You can unsubscribe from our newsletter and direct marketing via your user account. You also have the right to object, on grounds relating to your particular situation, to the processing of your Personal Data that is based on our legitimate interests.
5.7 Right to withdraw consent: You have the right to withdraw a consent you have given to us for a specific processing activity at any time, including in connection with your feedback to our newsletter.
5.8 Right to complain: You have the right to submit a complaint to Datatilsynet, Borgergade 28, 5, 1300 Copenhagen K, on our processing of your Personal Data. The complaint can inter alia be sent via email to email@example.com or via phone +45 33 19 32 00.
6. CONTACT INFORMATION
6.1 If you have any questions or comments to this Privacy Notice or if you wish to exercise one or several of your rights, you may contact:
Phone number: +45 55 77 75 91 / +45 22 10 75 91
7. CHANGES TO THIS PRIVACY NOTICE
7.1 In case we make any changes to this Privacy Notice, the newest version of the Privacy Notice will always be available on the Services, including your user account if you have opened such an account.