Our Personal Data Policy
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1. Data Controller
1.1 SmartResponse A/S is the data controller – how to contact us.
SmartResponse A/S is the data controller for processing the personal data that we have received about you.
You will find our contact details below:
Vesterbrogade 149, building 9. 5.
DK-1620 Copenhagen V
Company No. (CVR): 25057325
Tel.: +45 3823 7000
1.2 Our partners are also data controllers
To the extent that we have disclosed your personal data to our partners, these are also data controllers for the further processing of your data (see section 3).
2. The objectives of and the legal basis for the processing of your personal data
We process your personal data for the following purposes:
2.1 Marketing from SmartResponse A/S
SmartResponse A/S (data controller) collects data on their own behalf. Data is collected for marketing purposes. Marketing covers promotions and newsletters by e-mail and promotional offers by text.
The legal basis for our processing of your personal data is consent.
2.2 Sharing your data with our partners
SmartResponse A/S shares your personal data with our partners to the extent that your personal data meets the partner’s wishes. Each partner is then the data controller for your personal data under their own auspices. Our partners are listed in the competition conditions with a contact form (e-mail, phone, text), the subject or subjects for contacting the user, as well as the partner’s contact e-mail.
Generally, it applies to both purposes that the data is not further processed for purposes other than that for which it is collected and which are specified in the competition’s conditions.
The legal basis for our processing of your personal data is consent.
3. Categories of personal data
We process the following categories of personal data about you:
SmartResponse only collects and shares data where the user has given their consent.
We do not collect data that is not described in our Personal Data Policy, and we never collect personal data without you having given us this data, for example, by registering, buying a product or participating in a survey.
SmartResponse A/S collects and stores no special categories of personal data (sensitive information). We collect general personal data such as name, address, phone number, e-mail address, IP address, age, gender and interests.
4. Recipients or categories of recipients
We will share your personal data with the following recipients:
Our partners are on a complete list of all data collection pages with the following information:
- Company name
- An indication of what the partner will contact you about
- Contact method (e-mail, phone and/or text)
- An indication of contact qualifying questions, if such are present for an individual promotion.
We also hand over your personal data to our data processors: text provider service, e-mail service providers and our software development partner and hosting partner.
In most browsers, you can change the settings for which cookies are to be set on your computer.
* A cookie is a small piece of data that is stored in your browser and can be read by either the systems behind SmartResponse or its partners. A cookie is not a program running on your computer, and a cookie is not a virus or spyware.
5. Transfer to recipients in third countries, including international organisations
We transfer your personal data to recipients outside the EU and EEA.
It is about a software development partner, Crossworkers, in Egypt.
We can state that this transfer is based on the Commission’s standard data protection clauses that meet the required guarantees of article 46 of the General Personal Data Protection Regulation (GDPR).
6. Where your personal data originates from
Your data is collected on collection pages, typically online competition pages or pages where you can subscribe to a service or purchase a product.
Your data is only collected after you have submitted a separate and unequivocal acceptance of our and our partners’ conditions, including this personal data policy.
7. Storage of your personal data
We cannot at present say how long we will store your personal data.
We only store your data for as long as it serves a businesslike and legitimate purpose. If you want to have your personal data deleted from our databases, it will happen 2 years after your request for documentation purposes, cf. the requirement from the Consumer Ombudsman.
Your data will not be used by us or shared with our partners during these 2 years.
8. The right to withdraw consent
You have the right to withdraw your consent at any time. You can do this by contacting us at the contact information listed above in point 1. If you choose to withdraw your consent, it does not affect the legality of our processing of your personal data based on your previous informed consent and up to the date of withdrawal. If you withdraw your consent, it only takes effect from this point.
If you want help to withdraw your consent with the partners who have received your data, you can also contact SmartResponse A/S, and we will contact the partners on your behalf and ask them to delete your data from their databases. The responsibility to delete your data from their own database is, however, the responsibility of each partner.
9. Your rights
You have a number of rights under the Data Protection Regulation in relation to our processing of data about you.
If you wish to exercise your rights, please contact us.
Right to see data (right of access)
You have the right to inspect the data we process about you, as well as some additional data.
Right of rectification (correction)
You have the right to have inaccurate data about you corrected.
Right of deletion
In special cases, you have the right to have data about you deleted before the time that we usually delete data.
Right to limit processing
In some cases, you have the right to have the processing of your personal data limited.
If you have the right to have limited processing, in the future we must only process data, except for storage, with your consent or for the purpose of determining, enforcing or defending legal claims or to protect a person or important public interests.
Right to object
In some cases, you have the right to object to our or lawful processing of your personal data.
You can also object to the processing of your data for direct marketing, including profiling.
Right to transmit information (data portability)
In some cases, you have the right to receive your personal data in a structured, widely used and
machine-readable format and to transfer such personal data from one data controller to another without hindrance.
You can read more about your rights in the Danish Data Protection Agency’s guidance on the rights of data subjects, which you can
find on www.datatilsynet.dk.
10. Complain to the Danish Data Protection Agency
You have the right to lodge a complaint with the Danish Data Protection Agency if you are unhappy with the way we process your
You can find the Data Protection Agency’s contact details on www.datatilsynet.dk.
SmartResponse A/S has implemented both technical and organisational security measures to ensure that your data does not end up in the hands of unauthorised persons, is misused or is otherwise processed in violation of the law concerning the processing of personal data.
All personal data is protected behind a firewall.