PRIVACY POLICY (FOR CUSTOMERS)
Flexofold ApS (the “Company”), in connection with the provision of the marketing, procurement, sales and after sales, warranty, technical support activities service (the “Service”) to customers (the “Customers”), for the purpose of complying with the EU General Data Protection Regulation (the “GDPR”) and to appropriately process the personal data of the Customers, hereby establishes this “Privacy Policy” (this “Privacy Policy”).
1. PROCESSING PERSONAL DATA
(1) DEFINITIONS
“Personal data” means any data relating to an identified or identifiable natural person, including, without limitation, name, address, date of birth, telephone number, e-mail address and user IDs of the Customers.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Controller” means a legal person, etc. which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a legal person, etc. which processes personal data on behalf of the Controller.
(2) TYPES OF PERSONAL DATA TO BE COLLECTED
The Company will collect the following types of personal data concerning the Customers in connection with the Service:
- Name, home and/or company address
- Phone number, fax number
- E-mail address
- Bank account number
- Relationships with the network of the Company
- Interests in the products of the Company
- Products related information (such as boat, engine, propellor)
- Cookies, when interacting on our website.
(3) PURPOSES OF USE OF PERSONAL DATA
The Company will process the Customers’ personal data for the following purposes:
- To calculate/recommend right type and size of propellors
- To promote Company’s products and services
- To respond to inquiries, requests and questions from customers
- To retain warranty claim information
- To make payments in relation to purchase and warranty
- To provide after warranty service and
- To manage and monitor the contacts among the Company ,Customers and sales, service network to improve the customer experience.
If the Company is to process the Customers’ personal data for purposes other than the above, the Company will notify the Customers in advance such new purposes of use and other matters as required by applicable laws.
By manifesting their intention to consent to this Privacy Policy, the Customers will be deemed to have consented to the processing of their personal data by the Company within the scope of the above purposes of use, and the Company will process the Customers’ personal data based on such Customers’ consent; provided, however, that Customers may withdraw such consent at any time, which such withdrawal shall not affect any legitimate processing performed pursuant to the consent prior to the withdrawal. The Company may also process Customer’s personal data within the scope of the above purposes of use under a legal basis permitted by GDPR.
The Company may require the Customers to provide their personal data in connection with the provision of the Services. In such case, if certain Customers do not provide its personal data, the Company may be unable to provide the Services.
(4) RETENTION PERIOD
The Company will retain the Customers’ personal data to the extent the Company requires such data for achieving the purposes of use specified in 1.(3) above, and will promptly delete the same when such data is no longer necessary.
(5) COOKIES
A cookie is a piece of text that is stored on the Customers’ computer by the Customers’ web browser. The Company use cookies to monitor how people use the Company's site so the Company can develop and improve the design, layout and function of the site.
Cookies enable the Company to identify the Customers’ device. The Company use cookies that are strictly necessary to enable the Customers to move around the site or to provide certain basic features. The Company use cookies to enhance the functionality of the website by storing the Customers’ preferences, for example. The Company also use cookies to help the Company to improve the performance of the Company's website to provide the Customers with a better user experience. The Company also allow cookies that may be served where the Company embed social media links such as Twitter, YouTube and LinkedIn.
If the Customers do not want the Company to use cookies in their browser, the Customers can remove cookies from the Customers’ computer's hard drive, or set their browser to block cookies or to send a warning notice before a cookie is stored on the Customers’ computer. However, please note that the Customers may not be able to use many of the services on the Company's website or other websites without cookies.
Notwithstanding the above, the Customers may not remove cookies from the Customers’ computer's hard drive or set the Customers’ browser to block cookies in certain services of the Company, in which case the Customers will be informed of the applicable cookie policy in such specific service.
(6) THIRD PARTY TRANSFER
The Company may provide the Customers’ personal data to third parties such as the subsidiaries and affiliates of the Company, dealers, retailers, cloud vendors and contractors of the Company, etc., to implement the purposes of use specified above. Such third parties which the Company may provide the Customer’s personal data include those located in countries outside the European Economic Area (the “EEA”, (including, without limitation, Japan; the same shall apply hereinafter), and the Customers are deemed to have consented to the following matters by consenting to this Privacy Policy:
- Certain countries outside the EEA may not be furnished with the same level of data protection laws as the EEA, thus part of the rights granted to the Customers within the EEA may not be available;
- The Customers’ personal data may be provided and processed for the purposes specified in 1.(3) above; and
- The Customers’ personal data may be provided to third parties located in a country outside the EEA.
(7) DISCLOSURE, CORRECTION, AND OTHER PROCEDURES CONCERNING THE PERSONAL DATA
The Customers are entitled with the rights to access to, request for correction, request for deletion, request to limit the processing, object to the processing, and request for data portability, with regards to the personal data retained by the Company pursuant to the provisions of relevant laws and regulations. Such requests shall be attended to the contact point set forth in “5. Contact” as per below.
The Company may refuse the Customers’ request if the Company deems that there is no basis for such request or if the request is deemed excessive.
The Customers may file objections to the data protection authorities having jurisdiction over the location of the Customers’ domicile with regards to the processing of their personal data by the Company.
(8) UNSUBSCRIBING FROM DIRECT MARKETING
If the Customers wish to unsubscribe from the Company’s direct marketing, such Customers should contact the contact point set forth in “5. Contact” below.
(9) SOCIAL MEDIA FEATURES
The Company's site may also include social media or lead generation features, such as Facebook or Twitter buttons and widgets, such as the share this button. These features may collect your IP address, which page Customers are visiting on the Company's site and may set a cookie to enable the feature to function properly. Social media and lead generation features and widgets may be hosted by a third party. Customers interactions with these features and widgets are governed by the privacy policy of the company providing it.
2. SAFETY MANAGEMENT MEASURES
In order to protect the personal data from unauthorized access and loss etc., taking into account the type of personal data, the degree of sensitivity and the degree of affect to the Customers including economic influence and mental harm in case the personal data is unlawfully infringed, the Company has comprehensively evaluated and judged the risks of personal data infringement, and has implemented necessary and appropriate personal, organizational and technical safety management measures in accordance with such the risk of personal data infringement, and further, will review such safety management measures as necessary, set up the process for taking corrective actions, and constantly make effort to improve its security.
The Company will make effort to appropriately manage personal data by restricting the entry of outsiders into the offices where the processing of personal data takes place, conducting educational awareness raising activities targeting all officers and employees involved in the protection of personal data, and appointing managers in charge for each division which processes personal data.
If the Company, in its role as a Controller, contracts a Processor, the Company shall select a Processor which is capable of implementing appropriate technical and organizational measures and shall manage such Processor in an appropriate manner.
Pursuant to the GDPR, the Company shall prepare records of the processing of personal data.
3. CONTINUOUS IMPROVEMENT
The Company shall continuously review and revise its efforts regarding the processing of personal data in order to correspond with changes in the GDPR, processing methods and the environment.
4. AMENDMENT TO THIS PRIVACY POLICY
The Company may amend this Privacy Policy at any time. The Company shall determine the effective date of the amendment and inform the Customers by 30 days prior to such effective date by means of publication on our website. The Customers who continue to use the Service on the effective date or thereafter shall be deemed to have consented to the amended Privacy Policy.
5. CONTACT
The Company’s contact point regarding this Privacy Policy is as shown below. Any questions or concerns regarding this Privacy Policy or the processing of personal data by the Company, or any requests concerning access, correction, deletion, limitation of processing or data portability of the personal data shall be attended to this contact point:
Flexofold ApS
Address: Dianavej 4, 7100 Vejle, Denmark
Phone: +45 7555 4346
Email: info@flexofold.com
Contact person: Marketing Manager, Annette Svendsen