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Privacy policy – SaltPower |
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At SaltPower (”SaltPower”, ”we”, ”us” or ”our”) confidentiality and data protection is a high priority. This privacy policy sets out the guidelines for SaltPower’s processing of your personal data and provides you with the information you have the right to receive according to applicable data protection law. You must read the privacy policy before submitting your personal data to SaltPower.
Data controller and contact information
The data controller for your personal data is:
SaltPower ApS
Østager 2
6400 Sønderborg
Denmark
Company registration no.: 25 07 42 97
1. If you visit our website
This section sets out the policy of SaltPower’s processing of personal data regarding users of SaltPower’s website http://saltpower.net/.
- Cookies
Types of personal data
SaltPower uses cookies on our website and applications. SaltPower may collect, process and store the following personal data about you via cookies when you visit our website or applications:
- IP address
- Hardware, software and internet browser used to access our website
- Date and time of your access to our website or applications
- Time zone
- Preferences and click behaviour
- Browsing history
We use cookies to collect the personal data stated above. You can find more information regarding our use of cookies in our cookie information banner on our website.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Promotional marketing in general
- Product and service development
- Statistics and analysis
Legal basis
SaltPower will mainly process your personal data based on the following legal basis:
- Legitimate interests: The processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis, marketing activities (where consent is not required), as well as improving and developing our products and services (Article 6 (1) (f) of the GDPR).
- Consent: In some cases, we need your consent, e.g. in order for us to place cookies on your devices (Article 6 (1)(a) of the GDPR).
Retention period
Your personal data will be deleted when it is no longer needed for one or more of the purposes mentioned above. Please refer to our cookie information banner on our website for information about the expiry of cookies placed on your device.
The personal data may, however, be processed and stored for a longer period of time if anonymised.
2. Contact persons at customers, suppliers and other business partners
This section sets out the policy for SaltPower’s processing of personal data collected from contact persons at customers, suppliers and other business partners who collaborate with SaltPower.
Collection of personal data
SaltPower may collect, process and store personal data about you in the following instances:
- When your company or the company you are employed with enters into an agreement with SaltPower
- When you have shown an interest in SaltPower, e.g., by providing your business card to SaltPower
- When you collaborate and communicate with SaltPower
Types of personal data
SaltPower may collect, process and store the following personal data:
- Name, email address, telephone number and similar identification data
- Organizational data, such as company name, company address, job position, business area, primary work location and country
- Contractual data, such as purchase orders, invoices, contracts and other agreements between your company (or your employer) and SaltPower, that may include e.g., your contact information
- Financial data, such as payment terms and bank account details
Such information may be provided directly by you (primarily via emails and other correspondence) or by a third party such as your employer.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Generally, to plan, perform and manage the business relationship, including any contracts
- Administration, such as processing payments, evaluation of credit ratings, performing accounting, auditing, and billing
- Completion of requests received from you
- General communication
- Statistics and analytics
- Marketing
- Dispute handling
Legal basis
SaltPower will mainly process your personal data based on the following legal bases:
- Contractual obligation: The processing of your personal data will in some cases be necessary for the performance of a contract (Article 6 (1) (b) of the GDPR).
- Legitimate interests: We may process your personal data pursuant to our legitimate interest in, for instance, to manage daily operations according to lawful and fair business practices, including planning, performing and managing the business relationship or our legitimate interest in e.g. statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services. The processing may also be necessary for our legitimate interests in preventing fraud or establish, exercise, or defend legal claims (Article 6 (1) (f) of the GDPR).
- Legal obligation: The processing of your personal data will in some cases be necessary to comply with legal obligations, such as our obligations to prevent illegal activity (Article 6 (1) (c) of the GDPR).
Retention period
Your personal data will be retained for 3 years from the end of the business relationship.
Any personal data included in bookkeeping records will be stored for 5 years as from expiry of the financial year at which time the data will be deleted. The storage period has been determined on the basis of the storage requirements laid down in s. 10 of the Consolidated Bookkeeping Act and, consequently, with a view to complying with applicable law.
Anonymized personal data may be kept for a longer period of time.
3. If you apply for a job
This section sets out the policy for SaltPower’s processing of personal data in relation to recruitment.
Types of personal data
SaltPower may collect, process, and store the following personal data:
- Personal data which you have disclosed in your job application and CV as well as any attachments
- Personal data you disclose during any job interviews
- Information about you, including information regarding your previous jobs, activities, competencies, performance, as well as your general appearance, which is publicly available on the internet, including on social media
- Results of personality tests etc.
- Criminal records
- References from your previous and/or current employers
- Health information if the position you have applied for demands special requirements for your health
Purposes of the processing
- Your personal data will be processed for the purpose of assessing whether we can offer you a position.
Legal basis
SaltPower will mainly process your personal data based on the following legal bases:
- Request to enter into an employment contract with us: We may process your personal data on the basis of your request to enter into an employment contract with SaltPower (Article 6 (1) (b) of the GDPR).
- Legitimate interests: We may process your personal data on the basis of our legitimate interests in carrying out further assessments of whether we want to hire you, including on the basis of personality tests, publicly available information on the internet and – if the position entails a financial responsibility - credit information and rating (Article 6 (1) (f) of the GDPR).
- Consent: In exceptional cases and only when no other legal basis can be applied, SaltPower may ask separately for your consent to process your personal data (Article 6 (1) (a) and 9 (2) (a) of the GDPR and s. 8 (3) of the Danish Data Protection Act). SaltPower will, for instance, only take references from your previous and/or current employers or collect your health information or criminal records if you have consented to this.
Retention period
If you are offered a position with SaltPower, your application and additional relevant personal data obtained during the recruitment procedure will be stored in your employee file.
If you are not offered a position, we will store your application and any additional personal data obtained during the recruitment procedure for a period of 6 months following our rejection, unless you have provided your consent to the storage hereof for a longer period.
If we have collected your criminal records, we will delete them immediately after we have received and reviewed them.
4. If you visit our profiles or fan pages on social media
This section sets out the policy for SaltPower’s processing of personal data collected via SaltPower’s profiles or fan pages on social media.
SaltPower and the providers of social media are joint data controllers for the processing of your personal data collected when you visit SaltPower’s profile or fan pages on social media. SaltPower complies with the guidelines of the Danish Data Protection Agency concerning joint data controllership and, using the applicable tools the best way possible, SaltPower attempts to ensure that you receive information on the processing of your personal data when you visit SaltPower’s profiles or fan pages on social media.
SaltPower has profiles or fan pages on the following social media:
- YouTube (Google LLC)
- LinkedIn (LinkedIn Ireland Unlimited Company)
- Twitter (Twitter International Company)
Collection of personal data
Depending on your conduct on the social media, SaltPower and the provider of the social media in question may retrieve the following personal data about you:
- Your "likes" or other reactions expressed on SaltPower’s profile or fan page
- Comments left by you on SaltPower’s profile or fan page
- Your visits to SaltPower’s profile or fan page
- Age, gender, relationship status, place of work, lifestyle, geographical information and fields of interest
Purpose of the processing
SaltPower may process your personal data for the following purposes:
- To communicate with you if you comment on our posts or send us a direct message
- Improve our products and services, including our profiles and fan pages on social media
- Statistics and analytics
Legal basis
SaltPower will mainly process your personal data based on the following legal bases:
- Legitimate interests: We may process your personal data on the basis of our legitimate interests in being able to improve SaltPower’s products and services (Article 6 (1) (f) of the GDPR).
The providers of the social media process, among other things, your personal data to enable them to improve their advertisement system and to provide SaltPower with statistics, which the provider, for example, works out on the basis of your visit to SaltPower’s profile or fan page on the social media in question, with a view to advertising and customising the activities on the profile or fan page. The providers of the social media process your personal data as a consequence of their legitimate interests, including their interest in providing innovative, customised, secure and profitable services (Article 6 (1) (f) of the GDPR).
- Consent: The providers of social media may also processes your personal data in accordance with your consent, which you are entitled to withdraw at any point in time via the settings on the website of the social media in question (Article 6 (1) (a) of the GDPR).
Retention period
Your personal data will be retained by SaltPower for one year from your interaction with SaltPower on social media. SaltPower does not delete reviews, comments, likes or other interactions you leave publicly on our profiles and fan pages. You may delete such expressions or interactions by removing your review, comment, like or other interaction from our profile or fan page.
Please refer to the privacy policy of the provider of the relevant social media for information on their retention of your personal data.
Anonymized personal data may be kept for a longer period of time.
Who do providers of social media share your personal data with?
The providers of social media may, among other things, share your personal data with the following categories of recipients:
- Other undertakings in the group which the provider of the social media in question is a part of
- Externally with partners providing analytical services
- Advertisers
- Other individuals using our profile or fan page on the social media in question
- Surveying partners
- Researchers and academics
For more information on the parties with whom the providers of social media share your personal data, we refer to the providers’ general privacy policies.
Your personal data may be transferred by the providers of social media to recipients outside the EU/EEA in accordance with the European data protection standards applicable from time to time. You may read more in the providers of social media’s general privacy policies.
For information of who SaltPower shares your personal with, please refer to section 6 below.
5. If you visit our physical locations
This section sets out the policy for SaltPower’s processing of personal data collected from video surveillance when visiting our physical locations.
Collection of personal data
SaltPower has installed video surveillance in certain areas of our locations, such as the entrances to our premises. These areas are clearly marked with signs.
The video surveillance is kept on secure servers which only a limited number of employees have access to. The recordings will only be accessed in case of suspicion of criminal offences or in relation to internal/external audits.
The recordings may be disclosed to the Police for criminal investigations if the personal data are processed for the purpose of safeguarding public or private interests which clearly override the interests of secrecy, cf. Article 6(1)(f) of the GDPR or if the disclosure is otherwise required by law, cf. Article 6(1)(c) of the GDPR. If disclosure is necessary for other purposes than the above mentioned, we will ask you to consent to such disclosure if you are part of the recordings, cf. Article 6(1)(a) of the GDPR.
Types of personal data
- Image material from the video surveillance.
- Date and time of the recording
Purposes and legal basis of the processing
The purpose of the video surveillance is security, including prevention of crime, cf. Article 6 (1) (f) of the GDPR.
Retention period
Recordings from video surveillance which has been conducted for the purposes of preventing crime are deleted or anonymized no later than 30 days after the recording has taken place, unless is it necessary for SaltPower to keep the recordings for the purpose of dealing with a specific dispute, e.g. in relation to solving a crime.
6. Disclosure to other data controllers and sharing with data processors
To fulfil the purposes described above we may provide access to your personal data for third parties who, on the basis of a contractual relationship with SaltPower, provide relevant services, e.g. IT-providers, email providers and marketing providers. Such service providers will only process personal data in accordance with our instructions pursuant to the data processor agreements entered into.
In connection with SaltPower’s development, the company structure may change, e.g. through a full or partial sale of SaltPower. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, as a general rule, Article 6 (1) (f) of the GDPR, as SaltPower has a legitimate interest in handing over part of its assets as well as making commercial changes.
Aside from above, it is a general rule that your personal data is not disclosed to a third party without your permission. However, under certain circumstances and in accordance with applicable law, we may need to disclose your personal data to
- Police
- Lawyers
- Auditors
- Courts
- Public authorities
- Prospective buyers
- Affiliated companies
If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA which does not have an adequate level of protection, such transfer will be based on the EU Commission’s standard contracts or binding corporate rules.
7. Your rights
- You have the right to access the personal data we process about you
- You have the right to object to our collection and further processing of your personal data
- You have the right to have your personal data rectified and deleted, with certain statutory exceptions, including the Bookkeeping Act
- You have the right to request us to restrict the processing of your personal data
- Under certain circumstances you may also request to receive a copy of your personal data as well as the transmission of your personal data which you have provided us with to another data controller (data portability)
- You may, at all times, withdraw any consent you may have given. We will then delete your personal data, unless we can continue the processing on another basis. Our newsletter can be unsubscribed by clicking the link at the bottom of the newsletter
8. Questions or complaints
If you have any questions in relation to this privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us:
SaltPower ApS
Østerager 2
6400 Sønderborg
Denmark
Email: info@saltpower.net
If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to the Danish Data Protection Agency:
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Denmark
Email: dt@datatilsynet.dk
9. Changes to the privacy policy
We reserve the right to make changes to this privacy policy from time to time. When updated, the date at the bottom of the privacy policy will be updated accordingly. The, at all times, applicable privacy policy will be available at our website.
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[ 12-01-2024]