Data collection and privacy policy

Question

Accepted Answer

PRIVACY POLICY 
Content
In General
What personal data do we collect, for what purposes and what are the legal basis for this processing
Recipient of personal information
Your rights
Deleting personal data
Security
Contact info
Changes in the privacy policy
Versions
1. In general
1.1 This Privacy Policy ("Privacy Policy") describes how Saxo.com A / S ("Saxo", "us", "our", "we") collects and processes information about you.
1.2 The Personal Data Policy applies to personal data that you submit to us or that we collect via Saxo's websites and apps (the "Website").
1.3 Saxo is the data controller for your personal data. All inquiries to Saxo can be made via the contact details listed under appendix 7.
1.4 As of the 1st of July, Saxo took over the service "Politiken Books" (Former CVR. 26933676) and all associated sub-activities, resultning in the data responsibility for personal data has been transfered to Saxo.
2. What personal data do we collect, for what purposes and what are the legal basis for the processing 
2.1 When you visit the Website, we automatically collect information about you and your use of the Website, eg about what type of browser you are using, what search terms you use on the Website, your IP address, including your network location, and information about your computer in order to optimize the user experience and Website function and carry out targeted marketing, including retargeting via Facebook and Google. This processing of information is necessary in order for us to improve the Website and show you relevant offers. The legal basis for the treatment is the EU Personal Data Regulation Art. 1, points b and f.
2.2 When you buy a product, we collect the information you provide yourself, eg name, address, e-mail address, telephone number, payment method, information about which products you buy and possibly returned, delivery requests, and information about that IP address from which the order is made. This processing of information is for the purpose of providing the products you have ordered and otherwise fulfilling our agreement with you, including in order to manage your rights to return and advertise and to be able to contact you in connection with your order. We can also process information about your purchases in order to comply with legal requirements, including for accounting and accounting, as well as conduct targeted marketing. Upon purchase, the IP address is collected for the purpose of preventing fraud. The legal basis for the treatment is the EU Personal Data Regulation Art. 1, points b, c and f.
2.3 When registering for our newsletter, we collect information about your name, e-mail address and telephone number. with the purpose of being able to take care of our interest in delivering newsletters to you. The legal basis for the treatment is the EU Personal Data Regulation Art. 1, points b and f.
2.4 When creating a user profile or signing up for subscription services, you are asked to provide eg name, address, e-mail address, telephone number. In addition, we collect information during your membership, about your use of the customer club benefits, competitions you participate in, etc. We compare this information with other information we have about you, including information about what you have purchased and possibly returned. We do this treatment with the purpose of managing your membership and providing you with the benefits and benefits of the membership of the customer club, as well as our interest in sending newsletters and targeted marketing. The legal basis for the treatment, the EU Personal Data Regulation's Article 6 (1) 1, b and f. You can be asked to give separate consent to electronic marketing at registration.
2.5 When you publish or provide services on our publishing platform, we collect the information you provide, such as name, address, email address, telephone number, payout information, and information on the IP addresses from which the platform is used. This processing of information is for the purpose of fulfilling our agreement with you. Payout information is processed to comply with legal requirements, including for accounting and accounting purposes. IP addresses are collected for the purpose of enforcing copyright and preventing fraud. The legal basis for the treatment is the EU Personal Data Regulation Art. 1, points b, c and f.
2.6 When communicating with us, we collect the information you specify, eg name, address, e-mail address, telephone number, and the contents of your inquiry. This processing of information is for the purpose of providing the best possible customer service. The legal basis for the treatment is the EU Personal Data Regulation Art. 1, points b and f.
 
3. Recipients of Personal Information
3.1 Information about your name, address, e-mail, telephone number and order number and specific delivery requests are passed on to the carrier who is responsible for the delivery of the purchased goods to you. When purchasing non-stocked goods, the information mentioned can be passed on to the manufacturer or seller of the product concerned, who will then be responsible for the delivery. 3.2 In connection with the purchase of services at Saxo Publish, contact and product information can be passed on to relevant suppliers (data controllers) of the relevant service for fulfilling the contract.
Recipients of Personal Information within the EU
3.3 Information may be left to external partners who process the information on our behalf. We use external partners for, among other things, technical operation and improvements of the Website, the sending of newsletters and targeted marketing, including retargeting (eg recommendations based on your preferences), as well as for your assessment of our company and products. These companies are data processors and under our instructions and process data for which we are the data controller. The data processors may not use the information for any purpose other than the fulfillment of the agreement with us and are subject to their confidentiality. We have entered into written data processing agreements with all data processors who process personal data on our behalf.
Recipients of Personal Information outside the EU
3.4 Information may be left to external partners who process the information on our behalf. We use external partners for, among other things, technical operation and improvements of the Website, the sending of newsletters and targeted marketing, including retargeting (eg recommendations based on your preferences), as well as for your assessment of our company and products. These companies are data processors and under our instructions and process data for which we are the data controller. The data processors may not use the information for any purpose other than the fulfillment of the agreement with us and are subject to their confidentiality. We have entered into written data processing agreements with all data processors who process personal data on our behalf.
 
Some data processors are established in the United States:
Google Analytics v. Google LLC., Microsoft Corporation, Atlassian PTY Ltd, The Rocket Science Group LLC, MailChimp, Cloudflare Inc., Richelevance Inc., SurveyMonkey Inc.,, Functional Software Inc. (Sentry), Zendesk, Inc. The necessary information for the transfer of information to the United States is ensured through the data processor's certification under the EU-US Privacy Shield, cf. EU Nature of the Personal Data Regulation. 45th
3.4.1 Google LLC
3.4.2 Microsoft Corporation
3.4.3 Atlassian PTY Ltd
3.4.4 The Rocket Science Group LLC d / b / MailChimp
3.4.5 Cloudflare Inc
3.4.6 RichRelevance Inc
3.4.7 SurveyMonkey Inc.
3.4.8 Zendesk, Inc
 
Data processors in other countries outside the EU / EEA:
3.4.9 TIAC Group (TIACd.oo), Serbia
 
Reference to standard contractual provisions for the transfer of personal data between the EU / EEA and countries outside the EU / EEA. An agreement has been entered into on the basis of SCC (Standard Contractual Clauses) agreement.
4. Your rights
4.1 In order to create transparency about the processing of your information, we, as the data controller, must inform you of your rights.
4.2 The court of appeal
4.2.1 You are at any time entitled to request information about, among other things, what information we have registered about you, what purpose the registration serves, which categories of personal data and recipients of information there may be. may be, as well as information about where the information originated.
4.2.2 You have the right to receive a copy of the personal information we process about you. If you would like a copy of your personal information, please send a written request to info@saxo.com. You may be asked to document that you are the one you are giving yourself to be.
4.3 The right to rectification
4.3.1 You have the right to obtain incorrect personal information about yourself corrected by us. If you become aware that there are errors in the information that we have registered about you, you are encouraged to contact us in writing so that the information can be corrected.
4.3.2 Information that we have collected in connection with your creation of a user profile or your registration with our customer club, you have the possibility to correct via log-in to your user profile.
4.4 The Right to Delete
4.4.1 In some cases, you have the right to have all or some of your personal information deleted by us, for example, if you revoke your consent and we do not have another legal basis to continue processing. To the extent that continued processing of your information is necessary, for example, in order for us to comply with our legal obligations, or for legal claims to be established, enforced or defended, we are not obliged to delete your personal information.
4.5 The right to restrict treatment for storage
4.5.1 In some cases, you have the right to limit the processing of your personal data to consist only of storage, eg if you believe that the information we process about you is incorrect.
4.6 The right to data portability
4.6.1 In some cases, you have the right to obtain personal information you provided to us in a structured, commonly used and machine-readable format and have the right to transmit this information to another data controller.
4.7 The right to object
4.7.1 You have the right at any time to object to our processing of your personal data for the purpose of direct marketing, including the promotion made to target our direct marketing.
4.7.2 You are also entitled at any time for any reason relating to your personal situation to object to the processing of your personal data which we undertake on the basis of our legitimate interests, cf. section. 2.1 and 2.3.
4.8 The right to revoke consent
4.8.1 You have the right at any time to revoke the consent you have given us to a given processing of personal data, including to the profiling made by you as a member of the customer club. Consent to newsletters and recommendations may be withdrawn either through your user profile, at the bottom of the marketing material you have received or by contacting us at info@saxo.com.
4.9 The right to appeal
4.9.1 You have the right at any time to file a complaint with the Data Inspectorate, Borgergade 28, 5, 1300 Copenhagen K about our processing of your personal data. Complaints can, among other things, be submitted by mail dt@datatilsynet.dk or by phone +45 33 19 32 00
5. Deleting personal data
5.1 Information collected about your use of the Website cf. section. 2.1. anonymized when you have not used the Website for 2 years.
5.2 Information collected in connection with purchases you have made on the Website cf. section. 2.2 will generally be anonymized 2 years after the order is completed or canceled, unless you have an active user cf. section. 5.1. However, information can be stored for a longer period if we have a legitimate need for longer storage, for example if it is necessary for legal claims to be established, enforced or defended, or if storage is necessary for us to meet legal requirements. Accounting materials are kept for 5 years until the end of a financial year to meet the requirements of the Accounting Act.
5.3 Information collected in connection with your registration for our newsletter will be deleted when your consent to a newsletter is withdrawn. However, information can be stored for a longer period if we have a legitimate need for longer storage, for example if it is necessary for legal claims to be established, enforced or defended, or if storage is necessary for us to meet legal requirements.
5.4 Information that we have collected in connection with your creation of a user profile or your registration for our customer club item. 2.4, we will automatically delete if you have not used the Website or had an active membership for 2 years.
5.5 Information collected when you have published or provided services on our publishing platform, cf. section. 2.5 will generally be anonymized 2 years after you have last had a publication or service for sale, unless you have an active user cf. section. 5.1. However, information can be stored for a longer period if we have a legitimate need for longer storage, for example if it is necessary for legal claims to be established, enforced or defended, or if storage is necessary for us to meet legal requirements. Accounting materials are kept for 5 years until the end of a financial year to meet the requirements of the Accounting Act.
5.6 Information collected in relation with that you have communicated with us cf. section. 2.6, will as a rule be anonymized 2 years after you have contacted us. However, information can be stored for a longer period if we have a legitimate need for longer storage, for example if it is necessary for legal claims to be established, enforced or defended, or if storage is necessary for us to meet legal requirements.
 
6. Security
6.1 We have implemented appropriate technical and organizational safeguards to protect against personal data being accidentally or illegally destroyed, forfeited, altered or impaired, and against unauthorized knowledge or misuse.
6.2 Only employees who have a relevant need to access your personal data to do their work are allowed to access it.
7. Contact info
7.1 Saxo com A / S is the data controller for the personal data collected through the Website. Saxo.com A / S shares data responsibility with Facebook for the personal data collected through our publicly available Facebook pages.
7.2 If you have any questions or comments regarding this Privacy Policy or would you like to exercise one or more of your rights described in section 4, please contact:
 
SAXO.COM A / S Rådhuspladsen 37. DK-1785 Copenhagen V
Tel. no .: (+45) 3815 0510 Email: info@saxo.com
 
8. Changes in the Privacy Policy
8.1 If we make significant changes to the Privacy Policy, you will be informed of this by sending information to your email address. This will happen in case you have an active user profile, cf. section. 5.4, or an order that has not yet been anonymized cf. section. 5.2.
9. Versions
9.1 This is version 2 of Saxo's personal data policy dated 23.10.2018. (Translated to english 28.03.19)
9.2 Previous versions: 9.2.1 Version 1 of Saxo's personal data policy dated 22.05.2018
9.3 Adding of point 1.4 as of the 27.10.2020
9.4 Optimizing setup, with no chances to content, beside 9.3. 27.10.2020
9.5 Removed external partners, with whom we've ended our partnership. Removed from point 3.4.9.6 Minor corrections. 31.05.2023