PERSONAL DATA POLICY AT LUKSUSBABY A / S
1.1 This policy on the processing of personal data ("Personal Data Policy") describes how Luksusbaby A / S ("we", "Luksusbaby", "us", "our", "we") collects and processes information about you.
1.2 The personal data policy applies to the personal information that you provide to us in connection with you being in contact with Luksusbaby as a customer or business partner. It can e.g. be, if you buy an item from Luksusbaby, contact Luksusbaby's Customer Service, or when you use Luksusbaby's website, www.luksusbaby.com ("Luksusbaby.com"), and when you visit one of our 2 physical stores in Aalborg and Aarhus .
1.3 Luksusbaby A / S is data responsible for your personal information. All inquiries too Luksusbaby can be made via the contact information listed under pkt. 7.
2. WHAT PERSONAL INFORMATION DO WE COLLECT, FOR WHAT PURPOSES AND LEGAL BASIS FOR THE PROCESSING
2.1.1 The purpose is to optimize the user experience and Luksusbaby.com's function, to generate useful and accurate statistics, to answer your questions on our chat function and on the basis of the information we receive from you through your use of Luksusbaby.com to conduct personalized marketing, including retargeting via e.g. Facebook and Google. This processing of information is necessary so that we can take care of our interests in improving Luksusbaby.com and show you relevant offers.
2.2 When you purchase a product or communicate with us regarding our products, we collect the information you provide. This can be name, address, email address, phone number, payment method,
information about which products you buy and possibly have returned, information about inquiries and complaints, delivery requests, as well as information about the IP address from which the order was made, if the order is made on Luksusbaby.com.
2.2.1 The purpose is that we can deliver the products you have ordered and otherwise fulfill our agreement with you, including to be able to manage your rights to return and advertise, as well as to be able to contact you if necessary regarding relevant information about the product you purchased. We may also process information about your purchases to comply with legal requirements, including product withdrawals, bookkeeping and accounting. When purchasing on Luksusbaby.com, the IP address is collected for the purpose of safeguarding our interest in being able to prevent fraud.
2.2.2 The legal basis for the processing is Article 6 (1) of the Data Protection Regulation. 1, letters b, c and f.
2.3 When you have subscribed to our newsletter, we collect information about your name, e-mail address and possibly mobile number.
2.3.1 The purpose is to take care of our interest in being able to deliver newsletters to you.
2.3.2 The legal basis for the processing is your consent to receive our newsletter and Article 6 (1) of the Data Protection Regulation. 1, letter a.
2.4.2 The legal basis for the processing is your consent to receive our newsletter and Article 6 (1) of the Data Protection Regulation. 1, letters b and f. Upon registration, you will be asked to give separate consent to electronic marketing.
2.5 When you visit one of our stores or our other locations (administration and warehouse), TV surveillance may be set up. If so, there will be a sign with a pictogram (with a picture of a camera) in a visible place in the store. The recordings are reviewed by random checks, specific suspicions or other irregularities and passed on to the police if there is a suspicion of a criminal offense.
2.5.1 The purpose of the TV surveillance is to give Luksusbaby the opportunity to prevent, detect and document offenses in relation to both customers and staff (robbery, theft, assault, fraud, etc.), irregularities in connection with cash transactions and the like, and that create security and safety for staff (robbery, assault and disagreements regarding payment).
2.5.2 The legal basis for the processing is Article 6 (1) of the Data Protection Regulation. 1, letter f, as Luksusbaby has a legitimate interest in preventing the types of crime mentioned in section 2.5.1 in the physical stores and at Luksusbaby's other locations.
2.6 When you visit Luksusbaby’s Social Media, e.g. Facebook, Instagram and LinkedIn, Luksusbaby processes the information you have made available via settings on our social media, your reactions to our posts, and your sharing thereof, as well as any comments to our post.
2.6.1 The purpose of Luksusbaby's processing of your personal information is to market Luksusbaby, to answer your inquiry, and / or to let you participate in our competitions and direct inquiries to you if you win. When Facebook Inc. uses personal information collected on Luksusbaby's Facebook pages or Instagram profiles, e.g. to improve their advertising system, Facebook Inc. may and Luksusbaby are considered to be joint data controllers. In this connection, we refer to Facebook's Data Policy.
2.6.2 The legal basis for this processing is Luksusbaby's legitimate interest in marketing Luksusbaby, answering your inquiry or letting you participate in a competition and contacting you if you win, cf. Article 6 (1) of the Data Protection Regulation. 1, letter f.
2.7 If you enter into a commercial relationship with us either as an individual or as an employee of a company we work with, we process information about your name, e-mail, telephone number, company or private address as well as any other information that you provide us in connection with our relationship and your inquiry.
2.7.1 The purpose of Luksusbaby's treatment is to take care of our cooperative relationship and to be able to fulfill Luksusbaby's obligations in this connection.
2.7.2 The legal basis for this processing will normally be the agreement entered into between you and / or the company you represent and Luksusbaby, cf. Article 6 (1) of the Data Protection Regulation. Depending on the nature of the cooperation, the legal basis may also be another, typically Luksusbaby’s legitimate interest in establishing and managing the relationship between you and / or the company you represent, cf. Article 6 (1) of the Data Protection Regulation. 1, letter f.
3. RECIPIENTS OF PERSONAL INFORMATION
3.1 Luksusbaby cannot access to your IP address, but it is left to our partner Google Analytics, which processes this to generate statistics on the use of our website. Google Analytics acts solely on behalf of Luksusbaby, which is why they are not allowed to use the information for their own purposes. Luksusbaby has also implemented Facebook Pixels on luksusbaby.com to collect data for use in optimizing our Facebook ads. In this connection, Facebook receives information about your IP address as well as information about your device, the websites you visit, the purchases you make, the ads you see and the way you use Luksusbaby.dk about your web browser and which pages you visit. When Facebook Inc. uses personal information collected via Facebook Pixels on Luksusbaby.com e.g. to improve their advertising system, Facebook Inc. may and Luksusbaby are considered to be joint data controllers. In this connection, we refer to Facebook's Data Policy.
3.2 In connection with the delivery of goods that you have purchased from Luksusbaby, information about your name, address, e-mail, telephone number and order number and specific delivery requests will be passed on to PostNord, DSV, DHL or another carrier responsible for the delivery of they bought goods for you. In addition, your information may be passed on to business partners who assist with our business activities, including lenders.
3.3 When you complete payment transactions on Luksusbaby.com, this is done via Luksusbaby's PCI-DSS (Payment Card Industry - Data Security Standard) certified partner, OnPay. The information is stored in a secure PCI-DSS certified environment that complies with international security standards. When you use a payment card on Luksusbaby.dk, only Luksusbaby's PCI-DSS certified partner OnPay - and not Luksusbaby - will have access to your information.
3.4 Recordings from TV surveillance in the physical stores can be passed on to the police as part of the investigation of specific cases of offenses.
3.5 Information that Luksusbaby processes about you as part of a cooperative relationship will not be passed on to third parties, unless it is necessary for the purpose of the relationship, or it is necessary for us to be able to pursue a legitimate interest, e.g. in connection with disputes where the information may be disclosed to authorities and judicial bodies.
3.6 Information may be left to external partners who process the information on our behalf. We use external partners for, among other things, technical operation of systems and improvements of Luksusbaby.com, sending out newsletters and targeted marketing, including retargeting, as well as for your assessment of our company and products. These companies are data processors and under our instruction and process data for which we are data responsible. The data processors may not use the information for any purpose other than fulfilling the agreement with us, and are subject to confidentiality about this. We have entered into written data processor agreements with all data processors who process personal data on our behalf.
3.7 Some of these data processors, e.g. Google Analytics v / Google LLC. and Facebook Inc. is established outside the EU. The necessary guarantees for the transfer of information to data processors outside the EU are ensured by observing valid transfer guarantees.
4. YOUR RIGHTS
4.1 In order to create transparency regarding the processing of your information, we, as the data controller, must inform you of your rights.
4.2 The right of access
4.2.1 You are at all times entitled to request information from us about, among other things, what information we have registered about you, what purpose the registration serves, what categories of personal information and recipients of information that may. may be, as well as information on where the information comes from.
4.2.2 You have the right to receive a copy of the personal data that we process about you. If you want a copy of your personal information, you must send a written request to email@example.com. You will be asked to document that you are who you pretend to be.
4.3 The right to rectification
4.3.1 You have the right to have incorrect personal information about yourself corrected by us. If you become aware that there is an error in the information that we have registered about you, you are encouraged to contact us in writing so that the information can be corrected. You will be asked to document that you are who you pretend to be.
4.4 The right to delete
4.4.1 In certain cases, you have the right to have all or some of your personal information deleted by us, e.g. if you revoke your consent and we have no other legal basis to continue the processing. To the extent that continued processing of your information is necessary, e.g. in order for us to comply with our legal obligations, or for legal claims to be established, asserted or defended, we are not obliged to delete your personal data. You will be asked to document that you are who you pretend to be.
4.5 The right to limit the treatment to storage
4.5.1 In certain cases, you have the right to have the processing of your personal data limited to only storage, e.g. if you believe that the information we process about you is incorrect.
4.6 The right to data portability
4.6.1 In certain cases, you have the right to have personal information that you have provided to us provided in a structured, commonly used and machine-readable format and have the right to transfer this information to another data controller.
4.7 Right of objection
4.7.1 You have the right at any time to object to our processing of your personal data, with a view to direct marketing, including the profiling carried out in order to target our direct marketing, as this processing is carried out on the basis of your consent and / or our legitimate interests, cf. sections 2.1, 2.3, 2.4, 2.6 and 2.7. If you do not want us to use your personal information for direct marketing and profiling, you must also delete your cookies, as mentioned in section 5.1 below.
4.8 The right to withdraw consent
4.8.1 You have the right at any time to revoke a consent you have given us for a given processing of personal data, including for sending newsletters. If you wish to revoke a consent, please contact firstname.lastname@example.org.
4.9 The right to complain
4.9.1 You have the right to submit a complaint to the Danish Data Protection Agency at any time regarding our processing of your personal data. Complaints can be submitted by email to email@example.com or by phone +45 33 19 32 00.
5. DELETION OF PERSONAL DATA
5.2 Information collected in connection with your purchases and inquiries to Luksusbaby in connection with this, cf. pkt. 2.2, will in principle be deleted a little over 2 years after your purchase, when the right to complain about the item has expired. However, information can be stored for a longer period of time if we have a legitimate need for longer storage, e.g. if it is necessary for legal claims to be established, asserted or defended, or if storage is necessary for us to meet legal requirements. Information on the return of goods is stored for up to 5 years in accordance with invoice requirements and accounting legislation.
5.3 Information collected in connection with your subscription to our newsletter, cf. point 2.3, will be deleted when your consent to the newsletter is withdrawn, unless we have another basis for processing the information.
5.5 Information originating from TV surveillance, cf. section 2.5, will automatically be deleted no later than 30 days after the recording took place, unless the information is included in the investigation of a specific case. If your information is part of the investigation of a specific case, it will be deleted when the case is closed and the purpose of the processing is no longer present.
5.6 Information you provide on Luksusbaby's profiles on Social Media, cf. section 2.6, will in principle remain on these profiles as part of the page's history. You can always delete your information on Luksusbaby's profiles on Social Media whenever you want. The information that Luksusbaby processes about you as a result of your participation in competitions, and which in this connection is copied over to Luksusbaby's own systems, is deleted after 3 months.
5.7 Information that originates from a co-operation relationship, cf. section 2.8, is stored as long as it is relevant in relation to the existing or potential co-operation relationship and in a subsequent period, as long as it is necessary for Luksusbaby to be able to document the relationship.
6.1 We have implemented appropriate technical and organizational security measures against the accidental or unlawful destruction, loss, alteration or deterioration of personal data and against the disclosure or misuse of unauthorized persons
6.2 Only employees who have a real need to access your personal information in order to carry out their work have access to the information. These employees are instructed in how personal data is handled properly.
7. CONTACT INFORMATION
7.1 Luksusbaby A / S, cvr. no. 37757519 is data responsible for the personal data collected by Luksusbaby.
7.2 If you have any questions or comments about this Personal Data Policy or wish to make use of one or more of your rights described in section 4, you can contact:
Tel. No .: 50 50 84 87
8. CHANGES IN PERSONAL DATA POLICY
8.1 This Personal Data Policy is continuously updated. The current version is the one that can be found here at Luksusbaby.com at any time.
8.2 If you have signed up for Luksusbaby Kundeklub, you will be informed of the changes in the policy by sending information to your registered e-mail address.
9.1 This is version 2 of Luksusbaby's Personal Data Policy updated at 24 November 2020.