1. GENERAL
1.1 EA Fellows ApS is a Danish management consulting firm located at Banegraven 20, 3550 Slangerup in Denmark. Our CVR/VAT-number is DK- 31622727 and our website is at http://eafellows.com.
1.2 In this policy on the processing of personal data (“Personal Data Protection Policy”) we explain how we, EA Fellows ApS (“EA Fellows”, “us”, “our”, “we”), collect and use your personal data when you communicate with us, order our services or visit our website (the “Website”).
1.3 Our services are mainly for business operators, and the data we process are therefore primarily in respect of the enterprise you represent.
1.4 If you approach us as a private individual, your data will be processed in compliance with this policy.
1.5 Our Personal Data Protection Policy applies to personal data you provide us with or that we collect from the Website or from other sources.
1.6 EA Fellows is the data controller of your personal data. For all communication with EA Fellows, please use the contact details provided in item 6.
1.7 One of the reasons why we use cookies on the Website is to optimise your use of the Website, which is described in our cookie policy.
2. WHAT PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSE
2.1 When you visit the Website: When you visit the Website we automatically collect data about you and your use of the Website. The data includes your IP-address, what type of browser you use, what pages you visit, what links you activate and general information about your navigation and use of the Website.
2.1.1 The purpose is to pursue our legitimate interests of improving user experience and the functionalities of the Website and to be able to register the amount of time visitors spend on the Website and to show you relevant information.
2.1.2 The legal basis for processing the data is set out in the General Data Protection Regulation (“GDPR”), point f) of article 6, paragraph 1, (the “balancing of interests” rule).
2.2 When you sign up for our newsletters and request other promotional materials: The data we collect will include your name, e-mail address and your telephone number, what enterprise you represent, what industry you are from, your consent and your interests and preferences if you choose to provide such information.
2.2.1 The purpose is to enable us to send you newsletters and pursue our legitimate interest in sending you promotional material.
2.2.2 The legal basis for processing the data is set out in the GDPR, point f) of article 6, paragraph 1, (the “balancing of interests” rule).
2.3 When you order a service, or receive a quote from us: The data we collect will include your name, what enterprise you represent, your telephone number, method of payment, information about the services ordered by you and the time and method of delivery.
2.3.1 The purpose of such data processing is to enable us to deliver the services offered or agreed upon, and to otherwise enable us to perform the contract concluded with you or the enterprise you represent, and to handle your right to lodge a complaint.
2.3.2 The legal basis for processing the data is to enable us to perform the contract and provide the services ordered, see point b) or f) of article 6, paragraph 1, in the GDPR (the “balancing of interests” rule).
2.4 When you register for one of our courses: The data we collect will include your name, e-mail address and telephone number and what enterprise you represent.
2.4.1 The purpose of such data processing is to enable you confirm your understanding of the course you have signed up for. We need your personal data in order to register you for the course and for the subsequent administration of your participation in the course.
2.4.2 When you register for the course, the contract concluded for participation in the course is the legal basis for processing your personal data.
2.4.3 The legal basis for processing the data is set out in the GDPR, point f) of article 6, paragraph 1, (the “balancing of interests” rule).
2.5 When you take part in a research and development proposal or project together with us: The data we collect will include your name, e-mail address, telephone number, which organization you represent, biographical information which is required in relation to the specific proposal or project.
2.5.1 The purpose of such data processing is to, either alone or in partnership, seek funding for research and development projects, fulfil any agreement we have with you or your organization in respect of proposal preparation, and to fulfil the agreement with the funding authority, in the event that the project is funded.
2.5.2 The legal basis for processing the data is to enable us to perform the contract and provide the services ordered, see point b) or f) of article 6, paragraph 1, in the GDPR (the “balancing of interests” rule).
2.6 When you have enquiries or otherwise interact with us: The data we collect will include your name, e-mail address and telephone number and what enterprise you represent together with your enquiry.
2.6.1 The purpose of processing the data is to reply to the enquiry and to be able to communicate with you in order to provide the service you request.
2.6.2 The legal basis for processing is set out in the GDPR, point f) of article 6, paragraph 1, (the “balancing of interests” rule).
2.7 If you are the contact person of an enterprise which is one of our clients: The data we collect will include your name, e-mail and/or telephone number, what enterprise you represent, as well as any other data that you choose to provide, not including any sensitive data.
2.7.1 The purpose of the data processing is to enable us to communicate with you, for instance by mail and telephone, and to provide you and the enterprise you represent with the best possible service, for instance by taking into account special wishes or needs and to enable us to provide the enterprise you represent with relevant information
2.7.2 In addition, we use the information to contact you, or the enterprise you represent, in order to establish how satisfied you are with the services we provide and/or to send you information about other services that we think may be of interest to you or the enterprise you represent.
2.7.3 The legal basis for processing is set out in the General Data Protection Regulation (“GDPR”), point f) of article 6, paragraph 1, (the “balancing of interests” rule).
2.8 If you represent a supplier: The data we collect will include your name, e-mail and telephone number, what enterprise you represent, as well as any other data that you choose to provide, not including any sensitive data.
2.8.1 The purpose of the data processing is to enable us to communicate with you and the enterprise you represent, for instance by e-mail or telephone, in connection with the tasks that you or the enterprise you represent perform for us as suppliers.
2.8.2 The legal basis for processing is set out in the General Data Protection Regulation (“GDPR”), point f) of article 6, paragraph 1, (the “balancing of interests” rule).
3. RECIPIENTS OF PERSONAL DATA, INCLUDING THIRD-COUNTRY TRANSFERS
3.1 We only share your personal data with third parties if we are required to do so by law or in order to be able to provide the services we offer via the Website.
3.2 Transfers to data processors. Your personal data will only be transferred to business partners who process the data on our behalf. Such enterprises are data processors and instructed by us to process data in respect of which EA Fellows is the data controller. Data processors must not use the data for any purpose other than performing their contract with us, and their processing of such data is subject to non-disclosure agreements. We have concluded written data processor agreements with all data processors processing personal data on our behalf.
3.3 To the extent that we process personal data outside the EU/EEA, such processing will be in compliance with the standard contractual clauses adopted by the EU Commission.
4. WHEN WE ERASE YOUR PERSONAL DATA
4.1 Data collected about your use of the Website, see item 2.1, will be erased at the latest 36 months after you last visited the Website.
4.2 Data collected in the course of your interaction with us, or in connection with your enquiries and requests for information will be erased when they are no longer needed for the purpose for which they were collected.
4.3 As a rule, see item 2.3., data will be erased five years after the end of the calendar year in which the agreement to collect them was concluded. However, the data may be stored for longer periods of time if: i) we have a legitimate interest in storing the data for a longer period of time, ii) it is necessary to establish, submit or defend a legal claim, or iii) such storage is necessary in order to meet legal requirements. Accounting materials will be retained for five years after the end of a financial year in order to comply with the requirements of the Danish Bookkeeping Act.
4.4 Data collected when you sign up for our newsletter will be erased when you withdraw your consent to receive the newsletter. However, data may be stored for a longer period of time if we have a legitimate interest in the prolonged storage of such data.
4.5 Data collected in respect of your participation in research and development proposals or projects, will normally be deleted six years after the formal closure of the project. If a project is not funded, the data will be deleted three years after the proposal is formally declared unfunded.
5. YOUR RIGHTS
5.1 In order to ensure that the manner in which we process your data is transparent, we state your rights in the next section.
5.2 Right to access
5.2.1 At any time you have the right to ask us what personal data we have recorded about you, what purpose recording the data serves, what categories of personal data we store and the potential recipients of such data, as well as information about the source of the data.
5.2.2 You have the right to have the personal data we process about you given to you in the form of a copy. If you wish to receive a copy of your personal data, you must send a written request to gdpr@eafellows.com. You may be asked to provide documentation that confirms your identity.
5.3 Right to rectification
5.3.1 You have the right to have your data rectified in case of inaccuracy or incompleteness. If you become aware of errors in the data we have registered about you, please write to us to have the data rectified.
5.4 Right to erasure
5.4.1 In certain circumstances you are entitled to have all or some of your personal data erased by us, for instance if you withdraw your consent and the continued processing cannot be based on another legal basis. To the extent that the continued processing of your data is necessary, for instance in order to enable us to fulfil our legal obligations or in order to establish, submit or defend a legal claim, we are not obliged to erase your personal data.
5.5 Right to restriction of processing
5.5.1 In certain circumstances, for example if you believe the information we store about you is incorrect, you have the right to limit the processing of the data.
5.6 Right to object
5.6.1 At any time, you have the right to object to our processing your personal data for direct marketing purposes, which includes profiling purposes to the extent that it is related to such direct marketing.
5.6.2 At any time, you also have the right to object to our processing of data on the grounds of our legitimate interests for reasons with respect to your particular situation.
5.7 Right to withdraw your consent
5.7.1 At any time, you have the right to withdraw your consent to a particular type of processing of your personal data, for instance in connection with signing up for our newsletter.
5.8 Right to lodge a complaint
5.8.1 You can complain to the Danish Data Protection Agency about the manner in which we process your personal data. You may lodge your complaint by sending an e-mail to dt@datatilsynet.dk or by calling +45-3319 3200.
6. CONTACT DETAILS
6.1 If you have any questions about or comments on this Personal Data Protection Policy or wish to exercise one or several of your rights, you can contact us at +45 5124 5878 or gdpr@eafellows.com.
7. CHANGES TO OUR PERSONAL DATA POLICY
7.1 If we make changes to our Personal Data Protection Policy, we will notify you of such changes by posting the revised policy on the Website.