Privacy policy

1. INTRODUCTION

Carswip ApS, Langdyssen 5, 8200 Aarhus N, CVR. no.: 38653490 (“Carswip”) is the data controller for the processing of your personal data when you are a website user, customer and/or contact person. Below, Carswip has provided an overview of the processing activities in which personal data are processed, including among others the purpose thereof and the legal basis.

If you have any questions to this privacy policy (“Privacy Policy”) or you wish to exercise your data subject rights pursuant to Chapter III of the General Data Protection Regulation (“GDPR”) and according to section 6 of this Privacy Policy, please contact Carswip at support@carswip.com.

2. CATEGORIES OF PERSONAL DATA, PURPOSE AND LEGAL BASIS

2.1 Website visitors
When you visit Carswip’s website: https://carswip.com/ (“Website”), Carswip will process personal data about you, for instance, cookies, plugins and your IP-address. Depending on your activity on the Website and the information you to provide Carswip, we may also process information about your name, job title, phone number, email, company you work at and your chat history, if you use the Chatbot.

Carswip’s Cookie Policy includes further information on Carswip’s use of cookies and explains how you can delete or turn them off. The purpose of using cookies is to improve your user experience on Carswip’s website, to provide functionality, to generate statistics, to remember your preferences (e.g. choice of language), and to customise Carswip’s marketing.

The legal basis for the processing of your personal data is Carswip’s legitimate interests and that it is Carswip’s assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. GDPR art. 6 (1) (f). The legitimate interests pursued are to provide you with a website that works optimally, a good website experience and marketing activities.

2.2 Customer support inquiries
If you submit an inquiry relating to Carswip’s services to Carswip’s customer support e.g. by email or via our Chatbot in the website, Carswip will process personal data included in your inquiry and any other personal data of relevance to the inquiry. The personal data processed will be your name, your e-mail address, and possibly the personal data included in your inquiry.

The legal basis for the processing of personal data is Carswip’s legitimate interests and that it is Carswip’s assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. GDPR art. 6 (1) (f). The legitimate interests pursued are to provide customer support by answering the inquiries and business development.

2.3 Contact person at a vendor or another business partner
As a contact person at a vendor or another business partner, Carswip processes your personal data when you communicate with Carswip, e.g., via e-mails in connection with Carswip’s existing contractual relation with the company you are employed with or in connection with the conclusion or termination of a contract. Carswip processes ordinary personal data about you, including your name, e-mail address, telephone number, address, your position with the company, etc.

The processing of your personal data is necessary for Carswip to fulfil Carswip’s contractual obligations towards your employer. The legal basis for such processing of your personal data is that the processing is necessary for the purposes of legitimate interests pursued by Carswip and that it is Carswip’s assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. GDPR art. 6 (1) (f) in the GDPR. Carswip’s legitimate interests are fulfilment of our contractual obligations, maintaining and enhancing customer relationships, invoicing for the services your company provides to Carswip and/or vice versa, communicating with you if you have any questions related to our services or vice versa, and for documentation purposes in the event Carswip agree on matters relating to our services in writing via e- mail.

In some cases, processing of personal data is necessary in order to comply with a legal obligation to which Carswip is subject, for instance in relation to the obligation on the preservation of accounting records pursuant to the Danish Bookkeeping Act. In such case, the legal basis for the processing is GDPR art. 6 (1) (c).

3. RECIPIENTS OF YOUR PERSONAL DATA

Personal data can be disclosed to and shared with the following recipients:
– Auditors and legal advisers
– Other advisers, e.g. consultants and legal advisors
– Business partners, if relevant
– Data processors (for instance hosting)
– In the event of suspicion of criminal offences, data may be disclosed to the police or other third parties relevant to the matter in question

Legal basis for disclosure
The legal basis for disclosure of personal data to auditors is the Danish Act on Approved Auditors and Auditing Firms (revisorloven) and disclosure for the purpose of legal assistance is in order for us to safeguard our legal interests. Disclosure of personal data for the purpose of external legal advice is necessary for us to safeguard our legitimate interests, see article 6(1)(f) of the GDPR. The same applies to other advisers.

Any disclosure of personal data to our business partners will only happen if necessary to fulfil our legitimate interests in accordance with article 6(1)(f) of the GDPR.

In the event of suspicion of criminal offences where data may be disclosed to the police or other third parties, the legal basis is that disclosure is necessary for safeguarding our legitimate interests, see article 6(1)(f) of the GDPR.

4. TRANSFER OF YOUR PERSONAL DATA TO A THIRD COUNTRY (OUTSIDE OF EU/EEA)

In certain cases, Carswip will transfer your personal data to third countries outside of EU/EEA. If your personal data are transferred to such third countries, Carswip will ensure that such transfer will be carried out in accordance with applicable data protection legislation so that an adequate level of protection is ensured. If the personal data are transferred to recipients established in insecure third countries that are not approved by the EU-Commission, Carswip ensures an adequate level of protection for instance by entering into the EU-Commission’s standard contractual clauses and by implementing additional safeguards.

If in exceptional cases, none of the above legal bases apply, Carswip will obtain your explicit and prior consent to the transfer of your personal data to the specific third country.

You are welcome to request more information on our legal basis and safeguards for any transfers to countries located outside the EU/EEA and you may obtain a copy by contacting support@carswip.com.

5. STORAGE OF YOUR PERSONAL DATA

Carswip will only store your personal data as long as it is deemed necessary to fulfil the purposes for the processing of your personal data.

Contact person
If you are a contact person of our vendors or business partners, etc., Carswip will store personal data about you until termination of the contractual relationship (if any), as long as Carswip communicates with you because you are Carswip’s point of contact, or until it is no longer necessary for the establishment, exercise or defence of a legal claim.

Customer support inquiries
The inquiries and information you have provided Carswip with in relation to your inquiry will be deleted ongoing when they are handled, unless it is deemed necessary to store them for documentation purposes e.g., due to a dispute, including for the establishment, exercise or defence of legal claims.

Chat history – Chat bot
Your chat history will be deleted on an ongoing basis when it is no longer necessary for the purpose of communication via the website.

Bookkeeping material
Carswip will store your personal data to the extent it is necessary for bookkeeping purposes such as personal data related to invoicing. Such personal data will be stored for a period of 5 years from the end of the financial year to which the accounting records relate. The purpose is to comply with the legal obligation pursuant to the Danish Bookkeeping Act.

6. YOUR RIGHTS

Carswip has taken all necessary and adequate steps in order to protect your personal data and ensure your rights as a data subject.

You have a number of rights as a data subject. Please note that certain limitations may apply to your ability to exercise these rights, for example, when your right to obtain the information is found to be overwritten by essential considerations of private interests. If you have any questions or wish to exercise any of your rights as a data subject, please contact support@carswip.com.

According to the GDPR, you have the following rights:

6.1 Right of access
You have the right to request access to, including the disclosure of a copy of the personal data that Carswip process about you as well as the right to receive information on:
– the purposes of the processing;
– the categories of personal data concerned;
– the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries and in that connections the necessary measures carried out prior to the transfer;
– the envisaged storage period or the criteria used to determine that period;
– the existence of the right to request rectification, erasure, restriction or objection against processing of your personal data, including especially processing of personal data in connection with direct marketing purposes;
– the right to lodge a complaint with the Danish Data Protection Agency;
– where your personal data are obtained from if the personal data are not collected from you; and
– the existence of automated decision-making, including profiling, and as a minimum meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

6.2 Right to rectification
You have the right to have inaccurate personal data about yourself rectified as well as the right to request completion of incomplete personal data concerning you.

6.3 Right to erasure (“right to be forgotten”)
Under certain circumstances you have the right to obtain from Carswip the erasure of personal data concerning your, for instance if the processing is based on your explicit consent and you withdraw this consent.

6.4 Right to restriction of processing
You have the right to restrict Carswip’s processing of your personal data, for instance, in the event you dispute the accuracy of the personal data.

6.5 Right to data portability
When our processing of your personal data is carried out automatically and is based on your consent or a contract with you, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and the right to transmit those personal data to another data controller, if this is technically feasible.

6.6 Right to object
You have the right to object, on grounds relating to your particular situation, at any time to our processing of your personal data which is based on point (e) or (f) of GDPR art. 6(1). This applies at any time where personal data are processed for direct marketing purposes.

6.7 Right to not be subject to automated individual decision-making
You have the right not to be subject to a decision based solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

6.8 Right to withdraw a consent
If you have given us your consent to the processing of your personal data, you have the right to withdraw such consent at any time. However, the withdrawal of your consent will not affect the lawfulness of processing of your personal data based on consent before its withdrawal.

7. QUESTIONS OR COMPLAINTS

If you have any questions relating to this Privacy Policy, you wish to exercise your rights as mentioned above, or you disagree with the way Carswip process your personal data, you can contact Carswip by using the contact information provided in section 1 of this Privacy Policy.

You can also file a complaint to the Danish Data Protection Agency, which is an independent public authority that is, inter alia, responsible for monitoring and enforcing the application of the GDPR. The Danish Data Protection Agency’s contact information is available on its website: www.datatilsynet.dk.

8. AMENDMENTS TO THIS PRIVACY POLICY

This Privacy Policy will be updated and modified periodically, as well as when necessary due to changes in applicable data protection legislation and practice and, thus, Carswip recommend that you keep yourself updated of such changes.

Date of last change to this Privacy Policy: 6 January 2023.