1. The purpose of this policy

The Comarché ApS ("TCM") processes personal data about you in a range of different situations. We process such data when you sign up for news and updates from us, if we are in touch about potentially establishing a cooperation, when you visit our website, place and order with us apply for a job with us, or if you otherwise come into contact with us.

This privacy policy contains information on TCMs processing of personal data.

2. Data Controller

The legal entity which is the data controller for the processing of personal data undertaken by TCM is:

The Comarché ApS
Company Reg. No: 41 25 06 31
Dampfærgevej 8, 5.
2100 Copenhagen Ø
Denmark

You can contact us with any questions regarding our processing of personal data at:

E-mail: info@thecomarche.com

3. Personal data processing

You can read more about how we process personal data in the table below:

Customer relationship administration

Purpose

Data Subject

Category of Personal Data

Legal Basis

Source

Retention Period

The purpose is to manage customer relationships, including handling of orders, providing customer service, invoice, undertake quality assurance and control as well as administer, manage and develop our business and services, operate and maintain our systems.

Customers.

Non-sensitive personal data such as name, title, address, telephone number, e-mail address, information about complaints or contact to customer service as well as invoice and account information.

The processing is necessary for the performance of contracts with our customers or in order to take steps at the request of the customers prior to entering into contracts, cf. General Data Protection Regulation article 6, paragraph 1, point b.

Further, the processing is necessary for compliance with legal obligations to which TCM is subject, cf. General Data Protection Regulation article 6, paragraph 1, point c.

Moreover, such processing is also necessary in order for us to pursue our legitimate interests in managing customer relationships, fulfiling contracts with our customers, administering and developing our business and services, and handle the operation and maintenance of IT systems that are used as a part of our management of customer relationships, cf. General Data Protection Regulation article 6, paragraph 1, point f.

Customers.

The personal data is deleted after 5 years, unless specific circumstances require a shorter or longer storage period.

Courses, networks and similar events organized by TCM

Purpose

Data Subject

Category of Personal Data

Legal Basis

Source

Retention Period

The purpose is to arrange, hold and evaluate courses, networks and similar events organized by TCM.

Participants.

Non-sensitive personal data such as name, title, e-mail address, telephone number and organisation.

Processing of personal data in connection with enrollment of courses, networks and similar events at TCM is necessary for the performance of contracts with participants, or in order to take steps at the request of the participants prior to entering into a contract cf. General Data Protection Regulation article 6, paragraph 1, point b.

The processing is necessary in order for TCM to pursue its legitimate interests in being able to evaluate and administrate courses, networks and similar events and to keep in touch with the participants, cf. General Data Protection Regulation article 6, paragraph 1, point f.

Further, the processing is necessary for compliance with legal obligations to which TCM is subject, cf. General Data Protection Regulation article 6, paragraph 1, point c.

The participant in question or the participants employer.

The personal data is deleted after two years, calculated from the time of the completion and evaluation of the course, network or event, unless specific circumstances require a shorter or a longer storage period.

Marketing

Purpose

Data Subject

Category of Personal Data

Legal Basis

Source

Retention Period

The purpose is to carry out marketing activities, such as sending out newsletters, invitations to various events and other forms of direct communication.

Parties with which we have business relations or who have provided their consent hereto.

Non-sensitive personal data such as name, title, e-mail address, telephone number and organisation.

If we have been in contact with you in one form or another, then we consider that we have a legitimate interest in processing your personal data so that we can maintain our relationship and market our services, while also ensuring that the messages we send to you are as relevant as possible, cf. General Data Protection Regulation article 6, paragraph 1, point f.

Processing of personal data in connection with sending out our newsletter is undertaken on the basis of your consent, cf. General Data Protection Regulation article 6, paragraph 1, point a. 

Further, the processing is necessary for compliance with legal obligations to which TCM is subject, cf. General Data Protection Regulation article 6, paragraph 1, point c.

The relation in question or through publicly available sources such as LinkedIn or Facebook or through the website of the data subject’s organisation.

The personal data is deleted when the relation in question requests that we stop contacting the relation.

With regards to our newsletter, the personal data is deleted after two years calculated from the time where the relation in question withdraws its consent.

Visitors at www.thecomarche.com

Purpose

Data Subject

Category of Personal Data

Legal Basis

Source

Retention Period

The purpose is to administer visitors at thecomarche.com

Visitors atthecomarche.com

Non-sensitive personal data, such as IP-address.

We process personal data if we have the visitor’s consent, cf. General Data Protection Regulation article 6, paragraph 1, point a.

You can read more about how TCM uses cookies in our Cookie Policy.

The visitor.

You can read more the different cookies used in our Cookie Policy.

Recruitment

Purpose

Data Subject

Category of Personal Data

Legal Basis

Source

Retention Period

The purpose is to recruit, including process and assess applicants in relation to a current or future positions with TCM.

Applicants.

Non-sensitive personal data, including name, address, telephone number, e-mail address, educational background, professional experience and any other personal data that the applicant provides, as well as references. 

Personal data about criminal convictions and offences, including the applicant’s criminal record.

In some cases, we process sensitive personal data, including data concerning health, which will be of great importance to the applicant's ability to perform the position.

Processing of non-sensitive personal data is necessary in order for TCM to pursue its legitimate interests in being able to recruit applicants to positions at TCM, cf. General Data Protection Regulation article 6, paragraph 1, point f.

We process personal data that is collected from references provided that the applicant has consented to this, cf. General Data Protection Regulation article 6, paragraph 1, point a.

Further, we process personal data which are manifestly made public by the applicant, cf. General Data Protection Regulation article 9, paragraph 2, point e.

We process personal data on criminal records if it is necessary for the purpose of a legitimate interest in ensuring that the applicant is suited for the position at TCM that is being recruited for, cf. General Data Protection Regulation, article 10, cf. Data Protection act section 8, paragraph 3.

The processing is necessary for the purposes of meeting and respecting our or the applicant’s labour law obligations and specific rights, cf. General Data Protection Regulation article 9, paragraph 2, point b, cf. the Danish Data Protection Act article 7, paragraph 2.

The applicant and any references (if the applicant has given his/her consent) and data that is otherwise publicly available.

Personal data about applicants who are not offered a position is deleted after 3 months, calculated from the time on which the applicants has received notice that their applications has been rejected, unless the applicants has given consent for a longer storage period or specific circumstances require a shorter or a longer storage period.

Supplier and Partner Administration

Purpose

Data Subject

Category of Personal Data

Legal Basis

Source

Retention Period

The purpose is to manage supplier- and business partner relationships.

Suppliers and business partners, including any employees employed with them.

Non-sensitive personal data, including name, title, address, telephone number, e-mail address. As regard employees employed with suppliers and business partners we process name, title, e-mail address and telephone number.

The processing of personal data is necessary for the performance of contracts with suppliers and business partners, or in order to take steps with suppliers and business partners prior to entering into a contract cf. General Data Protection Regulation article 6, paragraph 1, point b.

The processing is also necessary for compliance with legal obligations to which TCM is subject, cf. General Data Protection Regulation article 6, paragraph 1, point c.

Further, the processing is necessary in order for TCM to pursue its legitimate interests in managing our supplier and business partner relationships and to perform the contracts with our suppliers and business partners, cf. General Data Protection Regulation article 6, paragraph 1, point f.

Suppliers and business partners, including any employees employed with them.

The personal data is deleted after 5 years, calculated from the time of the supplier and business partner relationship is terminated, unless specific circumstances require a shorter or a longer storage period.

 

4. Transfer and hand over of personal data

TCM keep your personal data confidential and will only transfer your personal data to third parties in very few instances, cf. the below.

We transfer personal data to our auditors and to other professional advisors in certain cases, e.g. so that auditors can perform audits or so that we can receive professional advice from other consultants and advisors. In addition, we may transfer personal data to courts and other public authorities in cases where it is necessary to do so in order for a legal claim to be established, exercised or defended.

We also use external suppliers, such as IT suppliers, accountants, etc. which may receive personal data in connection with the assistance they provide to us. TCM enters into data processing agreements with external suppliers which process personal data on behalf of TCM in order to ensure that all necessary security measures are adopted by our external suppliers.

We also transfer personal data of our customers to our business partners for the purpose of shipping orders to our clients.

Mostly, we do not transfer personal data to countries outside of the EU/EEA. However, in certain situations, e.g. where a customer, business partner, supplier or similar is based outside of the EU/EEA. In such situations, we always ensure that such transfers take place subject to appropriate safeguards such as binding corporate rules, standard data protection clauses adopted by the European Commission, EU/US Privacy Shield or similar. This is e.g. the case in connection with administration of our e-mail newsletters.

5. Security of processing

We protect the confidentiality, privacy and accessibility of customer’s and other relations’ data, including personal data. TCM places a high level of priority on customer confidentiality and information security and we are strongly committed to ensuring the continuous protection of information. We have implemented security measures that shall ensure the data protection of both customer information and personal data as well as other confidential information. We regularly conduct internal reviews in order to ensure that we have an adequate degree of security in place and that we are complying with our policies.

6. Your rights as a data subject

As a data subject, you have a range of basic rights. These rights can be restricted, however; for example, in cases where the access to personal data that you would otherwise be entitled to receive would entail violating the rights and freedoms  of another or violating our duty of confidentiality to someone else

Withdrawal of consent

In cases where our processing of your personal data is based on your consent (e.g. to receive e-mails from us), you are entitled to withdraw such content at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. In order to withdraw your consent to our processing of your personal data, we ask that you contact us.

If you no longer wish to receive e-mails containing information and marketing materials from TCM, you can easily unsubscribe from the mailing list by replying to an e-mail you have received from us with the message "unsubscribe from marketing content" and to unsubscribe from our newsletter, click the "unsubscribe from newsletter" link in the last issue of the newsletter you have received.

Right to access

You are entitled to be informed as to whether or not TCM is processing personal data about you and if so, you are entitled to find out what types of personal data we process and what purpose we process them for and you are entitled to receive a copy of such data.

Right to rectification

You are entitled to have any incorrect or incomplete personal data rectified. If the personal data is disclosed to others, we will ensure that the recipients are informed of any corrections, provided this is possible and legal.

Right to erasure

You are entitled to have personal data that TCM is processing on you deleted. If the data has been disclosed to others, we will ensure that the recipients are informed of any deletion, provided this is possible and legal.

Right to restriction of processing

You are entitled to have the processing of your personal data restricted so that the data can only be stored by TCM. If the data has been disclosed to others, we will ensure that the recipients are informed of any restrictions, provided this is possible and legal.

Right to data portability

In certain cases, you are entitled to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller.

Right to object to TCM’s processing

In certain cases, you are entitled to object to our processing of your personal data.

7. Changes to this privacy policy

Transparency is an ongoing commitment and we therefore update this privacy policy on a continuous basis. The privacy policy was last updated on 24 June 2020.

8. Contacts and complaints

If you would like to complain about TCM’s processing of your personal data, we ask that you send an e-mail with the details of your complaint to info@thecomarche.com. We will address your complaint and get back to you as soon as possible.

You are also entitled to complain to the Danish Data Protection Agency (Datatilsynet):

Danish Data Protection Agency
Carl Jacobsens Vej 35
2500 Valby

Telephone: +45 33 19 32 00
E-mail: dt@datatilsynet.dk

For more information about how to complain to the Danish Data Protection Agency, please refer to the agency’s website: www.datatilsynet.dk.

 

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