1.1We are committed to safeguarding the privacy of our website visitors.
1.2This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.4Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via URL.
1.5In this policy, “we”, “us” and “our” refer to Decision Focus ApS and Group of Companies. For more information about us, see Section 14.
2.How we use your personal data
2.1In this Section 2 we have set out:
(a)the general categories of personal data that we may process;
(b)the purposes for which we may process personal data; and
(c)the legal bases of the processing.
2.2We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.4We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users.
2.5We may process information contained in or relating to any communication that you send to us (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The communication data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users and the proper administration of our website and business.
2.6We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.9Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.Providing your personal data to others
3.1We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at URL.
3.2Identify personal data category or categories will be stored on the servers of our hosting services providers.
3.3We may disclose specify personal data category or categories to our suppliers or subcontractors insofar as reasonably necessary for specify purposes.
3.5In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.Retaining and deleting personal data
4.1This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3We will retain your personal data as follows:
(a)usage data will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 3 years following that date;
(b)profile data will be retained for a minimum period of 1 year following the date of closure of the relevant account, and for a maximum period of 3 years following that date;
(c)enquiry data will be retained for a minimum period of 1 year following the date of the enquiry, and for a maximum period of 3 years following that date;
(d)notification data will be retained for a minimum period of the period following the date that we are instructed to cease sending the notifications, and for a maximum period of the period following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications); and
(e)communication data will be retained for a minimum period of 1 year following the date of the communication in question, and for a maximum period of 3 years following that date.
4.4Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.Security of personal data
5.1We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
5.2We will store all your personal data on secure servers.
5.3The following personal data will be stored by us in encrypted form: your name, contact information.
5.4Data relating to your enquiries that are sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
5.5You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.1In Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2Your principal rights under data protection law are:
(a)the right to access – you can ask for copies of your personal data;
(b)the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c)the right to erasure – you can ask us to erase your personal data;
(d)the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e)the right to object to processing – you can object to the processing of your personal data;
(f)the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g)the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h)the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
6.3You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.4You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8To the extent that the legal basis for our processing of your personal data is:
(b)that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.9If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.10To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.11You may exercise any of your rights in relation to your personal data by emailing firstname.lastname@example.org.
7.Third party websites
7.1Our website includes hyperlinks to, and details of, third party websites.
7.2We have no control over, and are not responsible for, the privacy policies and practices of third parties.
8.1Please let us know if the personal information that we hold about you needs to be corrected or updated.
9.Acting as a data processor
9.1In respect of the Intercom chat function, we do not act as a data controller; instead, we act as a data processor.
9.2Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
10.1A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.<
10.2Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
11.Cookies that we use
12.1Most browsers allow you to refuse to accept cookies and to delete cookies.The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2Blocking all cookies will have a negative impact upon the usability of many websites.
12.3If you block cookies, you will not be able to use all the features on our website.
13.1We may update this policy from time to time by publishing a new version on our website.
13.2You should check this page occasionally to ensure you are happy with any changes to this policy.
13.3We may notify you of significant changes to this policy by email.
14.1This website is owned and operated by Decision Focus ApS.
14.2We are registered in Denmark under registration number DK 27 98 45 84, and our registered office is at Bregnerødvej 144, 3460 Birkerød .
14.3You can contact us:
(a)using our website contact form; or
(b)by email, using info_at_ decisionfocus.com.
15.Data protection registration
15.1We are registered as a data controller with the UK Information Commissioner’s Office.
15.2Our data protection registration number is ZA457933.