Finklusiv ApS also processes personal data about you because we need to fulfil a contract with you. When you are a customer of Finklusiv ApS, we have entered into a contract. In order to fulfil this contract, we need to process your personal data. This may also occur in connection with the issuance of invoices or similar transactions necessary for the customer relationship. The legal basis for this is Article 6(1)(b) of the Data Protection Regulation.
To fulfill a legal obligation
We may be obliged to disclose information to public authorities in certain cases, for example for the purposes of preventing money laundering, financial crime, or similar events. The legal basis is Article 6(c) and (e) of the Data Protection Act.
For marketing purposes
We process your personal data for marketing purposes, as well as for analyses that we use internally in Finklusiv ApS. The legal basis for our processing of personal data for marketing purposes is our legitimate interest in being able to communicate with you. The legal basis for this is Article 6(1)(f) of the Data Protection Regulation.
If you do not wish to receive marketing material from Finklusiv ApS, you can object at email@example.com
Web browser cookies
Finklusiv’s website uses “cookies” to improve the users experience. Users’ web browsers store cookies on their hard drives for record-keeping purposes and sometimes to track information about them. Users can choose to set their browser to reject cookies or alert you when cookies are being sent. However, the User should be aware that certain parts of the Website may then have reduced functionality.
How we use your personal data
The purpose of processing your personal data is customer management. We process information about you in order to be able to advise you in the best possible way on how to build a good application file in the best way to get a business account in a bank, and how to build a good relationship with your bank so that you can achieve a long-term cooperation with it.
In doing so, we will pass on your personal data to the bank.
We process your personal data for marketing purposes, as well as for analyses that we use internally in Finklusiv ApS.
If you do not wish to receive marketing material from Finklusiv ApS, you can object at firstname.lastname@example.org
Supplier / Collaborators
If you cooperate with or are a supplier to Finklusiv ApS, we may process personal data about you. The purpose of the processing is to obtain the service that we have agreed with you or your employer, including that we can communicate with you and/or the company you work for.
We use NewBanking Identity as a third-party service provider that stores your personal data. All data is stored encrypted and cannot be accessed or processed by anyone other than those you have specifically granted access. You can manage the content and information you share when using NewBanking by logging in via www.NewBanking.com
. You can also download information associated with your NewBanking account through www.NewBanking.com
You have visited our Facebook page
If you have visited Finklusiv ApS on Facebook, Facebook has placed cookies on your computer or other medium you have used to visit the page. We are joint data controllers with Facebook, for this processing of your personal data. The purpose of this processing is to get a better knowledge of you who visits Finklusiv ApS on Facebook.
You must contact Facebook if you wish to exercise your rights in relation to Facebook. If you wish to use your rights in relation to the information that we have obtained in this way, you must contact us as set out in this personal data policy
You have visited our LinkedIn page
If you have visited Finklusiv ApS on LinkedIn, LinkedIn has placed cookies on your computer or other medium you have used to visit the page. We are joint data controllers with LinkedIn, for this processing of your personal data. The purpose of this processing is to get to know you better as a visitor to Finklusiv ApS on LinkedIn.
You should contact LinkedIn if you wish to exercise your rights in relation to LinkedIn. If you wish to use your rights in relation to the information that we have obtained in this way, you must contact us as set out in this personal data policy
What personal data do we process?
Depending on the nature of your inquiry to Finklusiv ApS, we collect a number of personal data about you.
It is important to emphasise that we only collect information that is necessary for each purpose, and this list does not necessarily reflect all the information that we have collected about you in particular. You are always welcome to contact us if you want to know what personal data we process about you.
Identifying information including; name, gender, social security number, email and telephone number.
Other identifying information may include: place of birth, education and employment, marital status, residence status, ID cards such as passport, driving licence and health insurance card.
Your relationships, including; family relationships, guardian and power of attorney relationship.
Information on assets, including; property details, car and other means of transport, securities held in custody, and other assets.
Other information, including; advice notes, client reports and statements, client complaints, correspondence, meeting documents, payments, consent forms and valuation information.
Basis for advice, including; finances, credit situation, tax information, credit conditions, customer needs, dreams and aspirations, sales opportunities and sales strategies.
Transactions, including; trades and orders, banking transactions, credit card transactions and payments.
In Finklusiv ApS we do not collect and process sensitive personal data about you. However, if you yourself provide us with information that contains sensitive personal data, for example, information from a meeting or a budget, about your health or that you are a member of a particular trade union, Finklusiv ApS considers this to be your express consent to the processing of this information. Our legal processing basis for this is Article 9(2)(a) of the GDPR. We do not process this information in other contexts and it is deleted when it is no longer relevant.
When do we delete your personal data?
We continuously assess when it is no longer necessary to keep your data. In doing so, we consider, among other things, the need for the data to be available to you within the statute of limitations and the need to document our advice.
We do not delete your personal data as long as we provide a service or product to you. We keep specific information for a longer period of time. This will be information that needs to be retrievable under legislation e.g. the Money Laundering Act.
If you have been a customer with us we are under money laundering legislation personal data about you is kept for at least 5 years after the customer relationship ends.
Disclosure of your personal data
In order to fulfil the terms of our agreements with you, we need to transfer your personal data to other companies that provide contractual services to us. We may use data processors in third countries outside the EU and EEA. The use of other companies is based on data processor agreements or other contract and we have ensured that the rights and level of protection accompany your personal data.
We may also share your information with competent courts and authorities when we are legally obliged to do so (for example, to allow such bodies to investigate, prevent or act against unlawful activities) or we need to take action to protect our rights or the rights of third parties.
Profiling and automated decisions
Our processes may in some cases be partially automated, and therefore an automatic evaluation of your personal data takes place, for example to analyse your financial situation. Before a decision is taken, the processing will always be passed by a staff member who has the necessary competence and possibility to change the decision before the case is closed.
The Company enters into written agreements with all sub-processors involved in the provision of the Services, including the safeguards and guarantees required under the General Data Protection Regulation (EU Regulation No 679 \ 2016, “GDPR”), in particular with regard to the implementation of security measures required by the GDPR.
With respect to data breaches, we will notify you without undue delay when we confirm that a data breach affecting personal data has been detected. We will provide you with sufficient information to enable you to comply with any obligations to report or inform competent authorities or data subjects. We will cooperate with you and take reasonable commercial steps as directed by you to assist in the investigation, mitigation and remediation of each such data breach. For the avoidance of doubt, you are responsible for both filing reports required by applicable law and notifying data subjects, and you shall defend, indemnify and hold us harmless from any costs (including attorneys’ fees), fines or penalties, or any damages that failure to act on your part may cause.
Under the Data Protection Rules, you generally have the right to:
- access the information we process about you and a range of other information
- object to our processing of the data
- ask for inaccurate information about yourself to be corrected
- in specific cases, ask for your personal data to be deleted or for processing to be restricted.
- In certain cases, the right to transmit the data (data portability)
You should contact us if you wish to exercise your rights.
You can read more about your rights below and in the Data Protection Supervisor’s Guidance on the Rights of Data Subjects. You can find the guide on datatilsynet.dk
Right to see information (Right of access)
You may at any time access the personal data that we have recorded about you. This right may be limited for reasons of protection of other people’s data.
Right to object
In some instances, you have the right to object to our otherwise lawful processing of your personal data.
You may object to the processing of your data for marketing purposes.
Right of rectification (Correction)
You have the right to have inaccurate information about yourself corrected and we will, where possible, keep your information up to date ourselves.
Right to erasure
In exceptional cases, you may have information about you deleted before the time of our general deletion. This right may be limited for our or others’ legitimate interests including we may be required to retain information for longer periods.
Right to restriction of processing
In some instances, you have the right to have the processing of your personal data restricted. If you have the right to have processing restricted, we may only process the data in the future – other than storage – with your consent, or for the establishment, exercise or defence of legal claims, or to protect an individual or important public interests.
Right to transmit data (Data portability)
In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have those personal data transferred from one controller to another without hindrance.
You should contact us if you wish to exercise your rights. You can do this by contacting our data controller :
The data controller of Finklusiv ApS
Marie B. Olafsdottir
Complaint to the Danish Data Protection Authority
If, contrary to expectations, you believe that we are not processing your personal data in accordance with the law, please contact us. You can write to us by e-mail and we will deal with your enquiry as soon as possible so that any misunderstandings can be corrected.
You also have the right to lodge a complaint with the Data Protection Authority. You can find the contact details of the Data Protection Agency at www.datatilsynet.dk
Please note: In the event of a conflict between the Danish version and the English version of the document, the Danish version prevails.
Version 30 June 2022