This policy (together with our terms of use (as set out on our website [www.ospra.com] and any engagement letter or terms of service entered into with you as a client) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Provisions of this privacy policy may not apply to you depending on your location or citizenship.
For the purpose of the EU General Data Protection Regulation 2016/679 (GDPR), the controller of your data is Ospra Aps, incorporated and registered in Denmark with CVR 45025403 whose office is at Reventlowsvej 26, 8260 Viby J, Denmark.
All personal data will be held and processed in accordance with applicable data protection and privacy law, including the GDPR and the Danish Data Protection Act.
We may collect and process the following data about you:
Information you give us.: You may give us information about you by filling in forms on our website or by corresponding with us by phone, social media or email. This includes information you provide when you register to use our site, onboard as a client to our services, provide any information to our site, make an enquiry, provide feedback, correspondence with us, and when you report a problem with our site.
The information you give us may include your name; address; e-mail address; social media, phone number; billing information; personal identification; country of residence; photographs; organisation details (if relevant); or other personally identifiable information or commercial information in documents that you send us.
Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:information about your visit, including the full URL clickstream to, through and from our site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; internet protocol (IP) address, your location data, login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Information we receive from other sources. We also work with third parties (including, for example, clients, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers,) and may receive information about you from them.
The website uses cookies. A cookie is a small file of letters and numbers that we put on your computer. These cookies allow us to distinguish you from other users of the website which helps us to provide a good user experience and improve our website and services.
The cookies we use provide us with the following information:
The Internet domain and Internet Protocol (IP) address from which you access our website;
The type of Internet browser and the operating system of the computer you use to access our website;
The date and time you visit our website;
The pages you visit on our website;
The pages you shared on social media and to which social media network;
If you linked to our website from another website, the address of that website; and
If you were referred to our website from a search engine, the address of that website and the search term you used to find us. Any data processing that occur while using cookies used for the sole purpose of carrying out the transmission of a communication and/or strictly necessary to perform the services you required is based on Article 6 (1) lit. b GDPR.
In case personal data is processed in the course of using cookies and/or similar technologies that are used for other purposes, e.g. improving our website or marketing purposes, the processing is based on Article 6 (1) lit. f GDPR and represents our legitimate interest in maintaining our user base, bringing new users to the Website and informing (potential) users about services organized and provided by us.
Google Analytics
This Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
The Website uses Google Analytic’s IP anonymisation function. Google will truncate/anonymise the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On our behalf, Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to us. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this Website.
Furthermore, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en. An opt-out cookie will be set to prevent the future collection of your information when you visit this Website.
Further information can be found under https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google Adwords
We uses Google Adwords, a service to display ads for us. Google search and Google AdWords use cookies, which allow Google to display relevant ads on Google properties (such as Google Search). This works as follows: If you access our website through a Google ad on Google Search, Google Adwords will store a cookie on your device. If you visit certain pages on our website and the cookie has not expired, we, and Google, may recognize that the ad has been clicked and that a visitor has been redirected to our website. Each Google AdWords customer receives a different cookie. These cookies usually lose their validity after 30 days and are not intended to identify you personally.
The information generated by cookies on the use of this website (including your IP address) are transmitted to Google. You may refuse the use of cookies by selecting the appropriate settings on your browser.
You can also opt-out of personalized advertising in Google AdWords Settings.
Facebook Pixel
We may from time to time use Facebook pixel. This tool helps us to understand and deliver ads through Facebook. The collected data like your IP address and browser information is processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes.
LinkedIn Insights and Ads script
We may from time to time use LinkedIn Insights or Ads Script. Provider of this tool is the LinkedIn Corporation, 2029 Stierling Court, Mountain View, CA 94043, USA. This tool helps us to track conversions, retarget website visitors and improve our website.
We use information held about you in the following ways:
Information you give to us. We will use this information:
· to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
· to perform anonymised analytics to ensure we are providing the best possible service;
· to aggregate (in an anonymised form) for drawing conclusions about our services and relevant industry trends including those relating to ESG reporting and other impact measurements;
· to provide you with information about other services we offer that are similar to those that you have already purchased;
· to collect feedback from people and businesses and for staff training purposes;
· to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means information about services similar to those which were the subject of a previous sale to you, and you will be given an option to unsubscribe with each communication. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
· to notify you about changes to our service;
· to ensure that content from our site is presented in the most effective manner for you and for your computer; and
· for any purposes required by law such as for tax, legal, reporting and auditing obligations.
Information we collect about you. We will use this information:
· to administer our site, services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to improve our site and services to ensure that content is presented in the most effective manner for you and for your computer;
· to allow you to participate in interactive features of our service, when you choose to do so;
· as part of our efforts to keep our site safe and secure;
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
· to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
In accordance with GDPR, the main grounds that we rely upon in order to process your information are as follows:
· Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information.
· Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
· Necessary for the purposes of legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that we have established that those interests are not overridden by your rights and freedoms (including your right to have your information protected). Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and user experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
· Consent. In some circumstances, we may ask for your consent to process your information in a particular way.
You have certain rights in relation to the personal data that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request.
· Right of Access. You have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
· Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
· Right of Erasure. In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
· Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
· Right of Data Portability. In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
· In such circumstances, you can ask us to transmit that information to you or directly to a third party organisation.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of these rights at any time by contacting us using the details in the ‘Contact’ section below.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate such as our Facebook, Twitter, Instagram, LinkedIn or other social media pages. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can do this by contacting us using the details in the ‘Contact’ section below.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Disclosure of your Information
We may share your personal information with any member of our group from time to time, which means our subsidiaries, our ultimate holding company and its subsidiaries as defined in the Danish Companies Act.
We may share your information with selected third parties including:
· Business partners, suppliers, regulatory bodies, membership organisations and sub-contractors for the performance of any contract we enter into with them or you.
· Billing and payment service providers
· Customer support services providers
· Analytics and search engine providers that assist us in the improvement and optimisation of our site or services.
· Should it be reasonably necessary, professional advisors including debt recovery organisations.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use (as set out on our site) or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The data that we collect about you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your services, the processing of your payment details and the provision of support services. By submitting or otherwise providing your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
To the extent that any of your data is provided to third parties outside the EEA, or accessed by third parties from outside the EEA, we will ensure that appropriate safeguards are in place in accordance with the GDPR (such as the European Commission’s standard contractual clauses).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any commercial, legal, accounting or reporting requirements. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data and the potential risk of harm from unauthorised use or disclosure.
If you are unhappy about our use of your information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the Danish Data Protection Agency (www.datatilsynet.dk).
If you live or work outside of Denmark or you have a complaint concerning our activities outside of Denmark, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA can be accessed here (http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).
May change or update the privacy statement without notice. All such changes will take effect once they have been posted on the Website. It is your responsibility to monitor such updates. The privacy statement was last updated on the date stated at the beginning of this privacy statement.
If you have any questions about how we collect, store or use your information, please contact us at Lasse@ospra.com
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All rights reserved.