We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Passendo ApS. (“Passendo”, “controller”, “we”, “us”, “our”). The use of www.passendo.com (“Internet pages of Passendo”, “website”) is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject. According to our Privacy Statement we believe that the only personal data that we process are your e-mail addresses and only before we use SHA256 to get the hash string. In any additional instance of data processing (what may happen during provision of our services, e.g. marketing profiling, newsletter subscription etc.) we shall use our best to process your data in accordance with the best practices and applicable law. The processing of personal data of a data subject shall always be in line with the laws of Denmark (primarily) – “applicable law” – including the General Data Protection Regulation (“GDPR”), and in accordance with the country-specific data protection regulations applicable to Passendo. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we may collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled. As the controller, Passendo has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
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a. Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”, “user”, “you”, “your”, “yours”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person such as your education, work experience, skills, photo, city or area and endorsements.
b. Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d. Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g. Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third-party or not.
Third-party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which you, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the Controller
The controller for the purposes of the GDPR, the applicable law and other applicable data protection laws and other provisions related to data protection is: Passendo ApS Toldbodgade 49b DK-1253 Copenhagen K Denmark Phone: +45 42 42 00 35 Email: email@example.com Website: www.passendo.com
3. Name and Address of the Data Protection Officer
The Data Protection Officer of the controller is: Mykola Vdovychenko, Passendo ApS Toldbodgade 49b, DK-1253 Copenhagen K, Denmark, Phone: +45 42 42 00 35 Email: firstname.lastname@example.org Website: www.passendo.com Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.
5. Collection of General Data and Information and Its Use by Passendo
The website of Passendo collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected information may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. When using these general data and information, Passendo does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Passendo analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
6. Additional Provisions on Use of Personal Data and Website Functional
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the written request or indication of the data subject, insofar as there are no statutory storage obligations. The Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of the controller’s employees are available to the data subject in this respect as contact persons. We may contact you by any electronic means such as email and other ways through Internet pages of Passendo, including text messages and push notifications. We may send you messages about the availability of Internet pages of Passendo, security, or other service-related issues as well as changes of this Privacy Statement. We may use user’s personal data (which can include your communications) needed to investigate, respond to and resolve complaints and issues with our services provided via Internet pages of Passendo (e.g., bugs, failures etc.). We use your data (which may include your communications) if we think it is necessary for security purposes or to investigate possible fraud or other violations of other legal documents published on Internet pages of Passendo. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our website (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of data controller, Passendo, personnel, or others. We attempt to notify Passendo about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Statement.
7. Security of Personal Data
Passendo does implement security safeguards designed to protect your personal data, such as HTTPS and other measures. We regularly monitor our systems for possible vulnerabilities and attacks. Although, we cannot warrant the security of any information that you provide us. There is no guarantee that such data will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We currently do not share personal data with third-parties for their direct marketing purposes. Learn more about this and about our response to “do not track” signals. If you have questions or complaints regarding this Privacy Statement, please first contact Passendo.
8. Subscription to Our Newsletters
On the website of Passendo, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller. Passendo informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the receipt of newsletter. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for the receipt of newsletter, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter. During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third-parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for receipt of the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in written.
The newsletter of Passendo contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Passendo may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects. Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third-parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. Passendo automatically regards a withdrawal from the receipt of the newsletter as a revocation.
10. Contact Possibility via the Website
The website of Passendo contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third-parties.
11. Routine Erasure and Blocking of Personal Data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the applicable laws or regulations to which the controller is subject. If the storage purpose is not applicable, or if a storage period prescribed by the applicable laws expires, the personal data are routinely blocked or erased in accordance with legal requirements.
12. Rights of the Data Subject
a. Right to confirmation
Each data subject shall have the right to obtain confirmation from the controller as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself or herself of this right of confirmation, the data subject may, at any time, contact our Data Protection Officer.
b. Right to access
Each data subject shall have the right to obtain from the controller free information about their personal data stored at any time and a copy of this information. Furthermore, the data subject will have access to the following information:
Furthermore, the data subject shall have the right to obtain information as to whether personal data are transnationally transferred or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, you may at any time contact our Data Protection Officer or another employee of the controller.
c. Right to rectification
Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, you may, at any time, contact our Data Protection Officer.
d. Right to erasure (right to be forgotten)
Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her as soon as possible, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
If any one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Passendo, the data subject may at any time contact our Data Protection Officer. The Data Protection Officer of Passendo shall promptly ensure that the erasure request is complied as soon as possible. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of Passendo will arrange the necessary measures in individual cases.
e. Right to restriction of processing
Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
If any one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Passendo, you may at any time contact our Data Protection Officer. The Data Protection Officer will arrange the restriction of the processing.
f. Right to data portability
Each data subject shall have the right to receive the personal data concerning him or her, which was provided to a controller in a structured, commonly used and machine-readable format. The data subject shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising the user’s right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer.
g. Right to object
Each data subject shall have the right to object, on grounds relating to their particular situation, at any time, to the processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. Passendo shall no longer process the personal data in the event of the objection, unless Passendo can demonstrate reasonable grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. If Passendo processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Passendo processing such personal data for direct marketing purposes, Passendo will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning him or her by Passendo for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may directly contact the Data Protection Officer. In addition, the data subject is free in the context of the use of information society services to use their right to object by automated means using technical specifications.
h. Automated individual decision-making, including profiling
Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by the applicable law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Passendo shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, the data subject may at any time directly contact our Data Protection Officer.
Right to withdraw data protection consent
Each data subject shall have the right to withdraw their consent to processing of their personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, the data subject may at any time directly contact our Data Protection Officer.
13. Data Protection for Applications and the Application Procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by completing a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure.
14. Legal Basis for the Processing Under the GDPR
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If Passendo is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in Passendo and his/her name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third-party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third-party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. It considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
15. The Legitimate Interests Pursued by the Controller or by a Third-Party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
16. Period for Which the Personal Data Will be Stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
17. Provision of Personal Data as Statutory or Contractual Requirement; Requirement Necessary to Enter Into a Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide Such Data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
18. Existence of Automated Decision-Making
As a responsible company, we do not use automatic decision-making but we may use profiling according to this Privacy Statement rules.
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