Privacy policy for BikeRep A/S

Version 1, 24 October 2018

Content
1. We take good care of your data
2. Data controller and contact information
3. Data processing is executed on an informed basis
4. The data about you that we process
5. Purpose of processing your personal data
6. Only processing of relevant data
7. Only processing of necessary data
8. Collection of consent before data processing or processing on another legal basis
9. Other forms of information we process that are obtained without consent
10. Your personal data is continually checked and updated
11. Erasure of unnecessary personal data
12. Protection of personal data
13. Cookies
14. Disclosure of personal data
15. Transfer to recipients in third countries, including international organisations
16. Newsletters and other marketing materials
17. Your rights

1. We take good care of your data

We have adopted this personal data policy, which forms the basis for our processing of your personal data, and which tells you how we process your personal data.

We decide the best way to process your data on an ongoing basis, and we are especially focused on ensuring that your basic rights are not negatively affected. Therefore, we pay particular attention to the risk of discrimination, ID theft, financial loss, loss of reputation and data confidentiality in general.

2. Data controller and contact information

BikeRep A/S is the data controller for bikerep.dk

Contact information:

BikeRep A/S
Central business registration no. (CVR)DK26267382
Brunbjergvej 2
8240 Risskov
Denmark

3. Data processing is executed on an informed basis

At the latest at the point in time when your personal data is about to be given, we will inform you about which data about you we are processing and for what purpose we are carrying out the processing. The information will either be given by way of a reference to this personal data policy, where a series of data collections and their purposes are described, or in the form of separate information given to you, if required with a request for your consent for the processing to take place.

4. The data about you that we process

We process your personal data in order to provide you with a better service and to ensure the quality of the products and services that we provide you with. Data can be collected and processed by us in connection with the following contact with us:

* Use of our websites, including online stores without the visitor making a purchase, including cookies. Read more in paragraph 13 on cookies.
* Inquiries to us made by e-mail, telephone or by ordinary letter
* A purchase via one of our online stores
* Inquiries made to customer service
* Particiation in competitions, events and similar
* Data, which can be collected and processed, covers:
* Contact information, e.g. name, address, telephone number, e-mail address
* Order data, purchase history, payment information
* Consent for marketing, newsletters or competitions
* User behaviour in connection with use of websites, which is collect via cookies. See more on the categories of data collection in paragraph 13.

5. Purpose of processing your personal data

Your personal data will be collected and processed for a specifically informed purpose or other legitimate commercial purpose. Such a purpose may include:

* Processing of your purchase and provision of our services
* Fulfilment of a contract based on your request
* Administration of your relationship with us
* Operation and optimisation of our websites
* Fulfilment of requirements in accordance with legislation
* Customer service and general communication with us
* Issuing of newsletters and marketing material from us or from one of our partners, see paragraph 16

6. Processing of relevant data

Your personal data will solely be processed on the basis of the data collected for the informed purpose, including via any inquiry to this personal data policy and for the purposes stated above. Only data that is necessary for the fulfilment of these purposes will be relevant and our processing will therefore be limited to such personal data.

Before we carry out any processing of your personal data, we carry out a specific assessment of whether it is possible to limit the amount of personal data we shall collected and process. We also carry out a specific assessment of whether it is possible to process your personal data in an anonymised form or pseudo-anonymised form.

7. Processing of necessary data

Our processing of your personal data will only cover the data that is necessary to process in accordance with the informed purpose(s), and the data that is necessary to fulfil legal or contractual obligations.

8. Collection of consent before data processing or processing on another legal basis

Before we carry out the processing, we will obtain your consent, or base the processing on another legal basis. Here you can find the basis and purpose of the collection and processing of your personal data, including, where appropriate, with reference to the privacy policy you can find in paragraph 11, which forms the basis for a number of different processes.

Your consent is voluntary and you may withdraw it at any time by contacting us. Please contact us if you have questions, or if you wish to withdraw your consent. Please be aware that if you choose to withdraw your consent in relation to information submitted to us, we will no longer be able to process your information further, unless we are legally or contractually obliged to do so.

If you choose to withdraw your consent, this does not affect the legality of our processing of your personal data based on your previously given consent and up to the time of the withdrawal. If you withdraw your consent, it therefore only takes effect from that point.

Here are some examples of instances where we collect your consent:

* The processing of personal data based on cookies when you visit our websites. See also paragraph 13 on cookies.

* Upon the creation of user profiles on one of our websites or web shops
* Participation in competitions, events and so on.
* The sending of newsletters

9. Other forms of information we process that are obtained without consent

9.1. The use of one of our websites, including web shops without
purchases during the visit

When you visit our websites, you will be asked to accept this privacy policy and cookie policy. In addition, our websites apply necessary cookies that are placed without your consent in accordance with legislation on cookies and upon the legal basis of the general data protection regulation article 6 (f). See also paragraph 13 on cookies.

9.2. Enquiries to us by email, telephone or post

Here the processing of your personal data is based on the fact that your enquiry to us has been made on your own initiative; cf. the general data protection regulation article 6 (b) (c) (d) (f). If your information is collected in connection with your enquiry, you will receive an email with reference to this privacy policy.

9.3. Purchases via web shops

When purchasing through one of our web shops where you provide contact information and payment information without at the same time creating a user profile, you can find the privacy policy in the terms and conditions for the web shop’s use of the information you submit to enable the completed purchase; cf. the general data protection regulation, article 6 (b) (c).

9.4. Enquiries to customer service

Via telephone: Here the processing of your personal data is based on the fact that your enquiry to us has been made on your own initiative, and thus refer to the privacy policy on our customer service webpage; cf. the general data protection regulation article 6 (b) (c) (d) (f). Via one of our websites: You will be asked to accept the privacy policy on our customer service webpage, cf. the general data protection regulation article 6 (a) (c) (f).

9.5. Purchases in one of our physical stores

Any collection of information in connection with a purchase via payment card or other electronic payment method is done so with simultaneous anonymisation.

10. Your personal data is continually checked and updated

Personal data that we process about you is checked and updated on an ongoing basis to ensure that the collected data is not false or misleading. If relevant changes occur related to the personal data we have collected about you, please contact us here gdpr@bikerep.dk if you are a customer to get the information changed.

In order to ensure the quality of your data, we have adopted internal rules and established procedures for the verification and updating of your personal data.

11. Erasure of unnecessary personal data

When the purpose of collecting and processing your personal data is fulfilled, the information will be deleted. We have assessed the need for the following storage periods as indicated in paragraphs 9.1-9.8:

11.1. Use of our websites, including online stores without the visitor making a purchase

See below about cookies, which states the specific storage periods.

11.2. Inquiries to us made by e-mail, telephone or by ordinary letter

Inquiries made by e-mail directly to our employees, or which are forwarded by one of our partners to one of our employees and which concerns us, will be deleted when the purpose of the storage no longer exists, which is assessed specifically on the basis of the individual e-mail in relation to the purpose of the inquiry and the content of the e-mail, including whether the e-mail falls under one of the other categories listed in this paragraph.

E-mail inquires made to our employees that do not concern us are deleted after the sender has been informed, if the inquiry does not give the employee reason to carry out further actions. We have a general deletion policy, whereby the employees must delete or anonymised personal data when its storage no longer fulfils a purpose.

11.3. Purchase made via an online store

Refer to the terms and conditions of trade for the specific online store.

11.4. Creation of user profiles on our websites or online stores

Refer to the personal data policy in the terms and conditions for the specific user profile.

11.5. Inquiries made to customer service

We have a general deletion policy, whereby the employees must delete or anonymised personal data when its storage no longer fulfils a purpose. The storage period may depend on the nature of the inquiry, including whether the information is stored as part of a complaint case, use of a product warranty or for any other legal or contractual basis.

11.6. Competitions, events and similar

We store your personal data that has been collected in connection with competitions, events and similar, as long as there is a purpose to the storage. For example, the storage period for a competition will typically end when the winner has been announced and for events, it will end when the event is finished.

11.7 The issuing of newsletters and marketing material

If you have given your consent to receive newsletters or other marketing material, we will store your information until you cancel your subscription to the newsletter or withdraw your consent for the receipt of marketing material. In the case of the submission of one-off material, we will store your information until there is no longer a purpose for storing it or in accordance with your specific consent. Also see paragraph 16.

11.8. Cookies

Regarding the erasure of personal data collected via cookies, please see paragraph 13.

12. Protection of personal data

Our processing of personal data takes place in accordance with the rules we have adopted internally. These rules contain instructions and measures with the aim of protecting your personal data. This means that we will treat your personal data in such a way as to avoid your personal data being destroyed, lost, changed or published in an unauthorised way, and to stop unauthorised access to or knowledge of your personal data.

We have established procedures for the granting of access rights to those of our employees who deal with sensitive personal data, and data that reveals information about personal interests and habits. We check their access attempts through logging and monitoring. In order to avoid data loss, we make continuous backups of our data sets. We also protect the confidentiality and authenticity of your data through encryption.

In the event of a security breach that results in a high risk of discrimination, identity theft, financial loss, loss of reputation or other significant damages to you, we will notify you of the breach as soon as possible.

13. Cookies

13.1. What are cookies?

As with almost all other websites, we use cookies to make our website function and to make it easier for you to use. Cookies help us, among other things, to recognise your computer or other web-enabled equipment and get an overview of your visits so we can continually optimise and focus the websites and our services. In this way we can provide you with a better user experience with more relevant content.

A cookie is a small text file that is stored on your computer, phone or other equipment that you use to visit the website. A cookie contains only text; it is not a program and does not contain viruses. Cookies are either placed by us (first party cookies) or one of our partners (third party cookies).

We divide cookies into the following categories:

* Necessary
* Functional
* Statistical
* Marketing

You can read more about our websites’ use of cookies, as well as how to block or delete cookies, in our cookie policy on the individual websites.

13.2. Data we process about you based on cookies

Some cookies collect the following types of information about you, which in different circumstances may constitute personal data:

* a unique ID
* technical information about your computer
* tablet or mobile phone
* your equipment’s IP address
* your geographical location
* which pages you click (interests and search history)
* information about transactions

13.3. The purpose and legal basis of our processing of your personal data

We process your personal data on the basis of cookies for the following purposes.

Necessary cookies:

* Basic functions for the websites
* Functional, Statistical and Marketing cookies:
* Website analysis cookies are used to track which pages are visited
* Customer service/Interaction cookies are used to support enquiries to customer service
* Social media cookies are used to share/’like’ products
* Marketing cookies are used to promote relevant products
* Video cookies are used to support content in the form of visual product guides and user guides

You can read more about the processing of information, including personal data, and the purpose of each cookie in the cookie policy on the individual websites.

The legal basis of our processing of your personal data consists of:

* The collection and processing of personal data on the basis of necessary cookies is carried out in accordance with the general data protection regulation article 6 (f) as the collection is necessary in order to make the website usable by activating its basic features, and because the website cannot function properly without these cookies. Therefore, you cannot consent to the placement of these cookies, but you can read more about how to delete these cookies in the cookie policy on the individual websites.
* The collection and processing of personal data via Functional, Statistical and Marketing cookies are carried out in accordance with the general data protection regulation article 6 (a) and (f) since the collection is achieved partly on the basis of your consent to the applicable cookie policy concerning our placement of cookies and thus the processing of personal data, and partly to optimise the websites for your benefit

13.4. Erasure of personal data collected via cookies

Please refer to the cookie policy for the individual website.

13.5. Disclosure of personal data and transfer to third countries

Regarding the disclosure of personal data and transfer to recipients in
third countries based on cookies, please refer to paragraphs 14 and 15.

14. Disclosure of personal data

We can, as appropriate, entrust your personal data to the following categories of beneficiaries:

* External IT suppliers, e.g. as part of operations and support in relation to our websites
* Our cooperation partners in the form of suppliers and subcontractors of goods and services to you on our behalf, e.g. the transportation and delivery of goods from web shops
* Suppliers of cookie services for websites (3rd-party cookies). You can read more about our disclosure of personal data from cookies to third parties on our websites in the cookie policies on the individual websites
* Accountants, lawyers and other advisors
* Public authorities, where legislation prescribes it

15. Transfer to recipients in third countries, including international organisations

15.1. Transfer to third countries via cookies

We transfer personal data based on cookies to a number of recipients outside the EU and EEA.

15.2. Non-cookie transfer to third countries

In some cases, we transfer information that is not gathered via cookies to suppliers, subcontractors or IT services outside the EU and EEA, e.g., when you shop via one of our online stores or participate in a contest or an event. You can find a list of the recipients outside the EU and the EEA of personal data that is not gathered via cookies, as well as the basis for the transfer, in the purchasing terms and conditions for the individual web shop, in the conditions of the competitions and in the conditions for the relevant event.

16. Newsletters and other marketing materials

In the following we refer to all types of newsletters and other marketing materials collectively as ‘newsletters’.

The personal data collected and processed on websites where you can sign up for our newsletters can be divided into two types: “web shops” and “physical formats”.

16.1. Newsletters from web shops

In this paragraph, you can read about how we process your personal data in connection with our newsletters, which you can consent to receive in several of our web shops. A link is directly embedded in the consent for the relevant newsletter so you can read about our processing and your rights before you give your consent.

16.1.1. The purpose and legal basis of our processing of your personal data

We process your personal data for the following purposes:

* Sending of emails (newsletters) with news, marketing, promotions, offers and information about competitions and events
* Administration of your relationship with us as the recipient of the newsletter
* Personalisation of newsletters and our web pages for you, including profiling based on cookies. See also paragraph 16.1.7.

The legal basis of our processing of your personal data:

* Your consent to the receipt of the newsletter, cf. the general data protection regulation article 6 (a)
* Fulfilment of marketing law regulation, cf. the general data protection regulation article 6 (c)
* Our legitimate interest in being able to collect and administer your information, including via cookies on our websites and the optimisation of our newsletters to you, cf. the general data protection regulation article 6 (f). See also paragraph 13 on cookies.
* Sending of certain types of newsletters without consent based on your previous purchases with us where we choose to utilise this opportunity in marketing law, cf. the general data protection regulation article 6 (f). Here the request instead will simply include a link to this privacy policy.

16.1.2. Categories of personal data

Data that can be collected and processed include:

* Name
* Telephone number
* Email
* Purchase history from web shops

16.1.3. Recipients or categories of recipients

We disclose your personal data for processing with our supplier of the IT system that handles our newsletters.

16.1.4. Transfer to recipients in third countries, including international organisations

We pass on or entrust your personal data collected in connection with newsletters, including through cookies on our websites for the use of the newsletter, to recipients in third countries.

16.1.5. Where your personal data is derived from

The information you have submitted in connection with registering for the newsletter and the information we have collected via cookies based on your visits to one or more of our websites.

16.1.6. Storage of your personal data

We store your personal data, including information obtained through cookies, for as long as you are signed up for a newsletter from us, and will erase the information via anonymisation once 1 year has passed since you last read a newsletter from us. We also store your consent for documentation purposes in relation to marketing law for 2 years from the last time we used your consent to send you marketing.

16.1.7. Profiling

We do not use profiling.

16.1.8. The right to withdraw consent

Your consent is voluntary and you may withdraw it at any time by contacting us. Please contact us if you have questions, or if you wish to withdraw your consent. Please be aware that if you choose to withdraw your consent in relation to information submitted to us, we will not be able to further process your information, unless we are legally or contractual obliged to do so.

16.1.9. Your rights

Please refer to paragraph 17.

16.2. Newsletters from physical formats

In this paragraph, you can read about how we process your personal data in connection with our newsletters, which you can consent to receive in several of our physical formats’ websites. A link is directly embedded in the consent for the relevant newsletter so you can read about our processing and your rights before you give your consent.

16.2.1. The purpose and legal basis of our processing of your personal data

We process your personal data for the following purposes:

The legal basis of our processing of your personal data consists of:

16.2.2. Categories of personal data

Data that can be collected and processed include:

* Name
* Telephone number
* Email

16.2.3. Recipients or categories of recipients

We disclose your personal data for processing with our supplier of the IT system that handles our newsletters.

16.2.4. Transfer to recipients in third countries, including international organisations

We pass on or entrust your personal data collected in connection with newsletters, including through cookies on our websites for the use of the newsletter, to recipients in third countries.

16.2.5. Where your personal data is derived from

The information you have submitted in connection with registering for the newsletter and the information we have collected via cookies based on your visits to one or more of our websites.

16.2.6. Storage of your personal data

16.2.7. Profiling

We do not use profiling.

You may at any time object against profiling, whereafter we will cease to profile you as indicated and erase the data collected about you.

16.2.8. The right to withdraw consent

Your consent is voluntary and you may withdraw it at any time by contacting us. Please contact us if you have questions, or if you wish to withdraw your consent. Please be aware that if you choose to withdraw your consent in relation to information submitted to us, we will not be able to process your information further, unless we are legally or contractual obliged to do so.

If you choose to withdraw your consent, this does not affect the legalityof our processing of your personal data based on your previously given consent and up to the time of the withdrawal. If you withdraw your consent, it therefore only takes effect from that point.

16.2.9. Your rights

Please refer to paragraph 17.

17. Your rights

In accordance with the general data protection regulation, you have a series of rights in relation to our processing of information about you. If you want to exercise your rights as a customer, please contact us here gdpr@bikerep.dk.

If you want to exercise our rights as an employee, a former employee, a job applicant or candidate, please contact us here gdpr@bikerep.dk.

17.1 Right to see information (right of access)

You have the right to access the information that we process about you and to a series of other information.

17.2 Right to make correction

You have the right to have any incorrect information about you corrected.

17.3 Right to erasure

In certain situations, you have the right to have information about you erased before the point in time when our standard general erasure takes effect.

17.4 Right to restrict processing

In certain situations, you have the right to restrict the processing of your personal data. If you have the right to restrict the processing of your personal data, we may only in the future process the information – apart from storage – with your consent or where a legal requirement can be established, exercised or defended, or to protect a person or important public interests.

17.5 Right to object

In certain situations, you have the right to object to our or to the illegal processing of your personal data. You can also lodge an objection against the processing of your personal information for direct marketing.

17.6 Right to pass on information (data portability)

In certain situations, you have the right to have your personal information returned to you in a structured, commonly used and machine-readable format and have the right to transfer this data to another data controller without hindrance. You can learn more about your
rights in the Danish Data Protection Agency’s guidelines, available at www.datatilsynet.dk.

17.7 Making complaints to the Danish Data Protection Agency

You have the right to make complaints to the Danish Data Protection Agency if you are dissatisfied with the way we process your personal data. To obtain the contact information of the Danish Data Protection Agency, go to www.datatilsynet.dk.