This privacy policy applies on behalf of Carletti A/S (CVR no. 89563518). The data controller for your personal information is the company with which you interact. If you are unsure which company you are interacting with, you can contact us at carletti@carletti.dk.
In this privacy policy, you can learn how we process your information. This privacy policy applies to all individuals who purchase products or interact with us in any way, such as using our websites or communicating with us via social media or other platforms.
How we process your personal data
The processing of your data depends on the context in which you interact with us.
Below, you can read more about the activities where we process your information, including who the information concerns, the types of information we process, the legal basis, and how long we retain the information.
In this policy, you can also learn more about who we may share the information with.
Please note that we may process information for various purposes if you interact with us in multiple ways, such as being both a customer or visiting our websites.
If you contact us, including filing a complaint
The data controller for the processing of your personal data is Carletti A/S with which you correspond. You can contact us at carletti@carletti.dk.
The purpose of our processing of your information, if you contact us as a consumer or if you complain about one of our products or an experience with us, is that we can process your inquiry and ensure that you receive a response from us.
Our legal basis for processing your information in the above situations is our legitimate interest in processing your inquiry and ensuring that any complaints, including complaints about our products, are investigated, and handled, cf. Article 6(1)(f) of the General Data Protection Regulation.
We ask not to receive information that falls within the special category of data, cf. Article 9(1) of the General Data Protection Regulation, including health data, information about religious beliefs or trade union membership. If you nevertheless provide such information to us, we assume that you have given your explicit consent to the processing, and we therefore process this information based on your consent, cf. Article 6(1)(a) and 9(2)(a) of the General Data Protection Regulation.
The information we process
We may process the following information about you as a consumer or complainant:
· Contact information: e.g., name, address, e-mail, telephone number, postcode, customer number, initials
· Work-related information: e.g., title, position, place of work
· Other information that you yourself provide to us when you contact us
· Special categories of data, e.g., data about your health, religion or trade union membership, if you have provided them in connection with your enquiry with us.
Storage of your information
We do not store information longer than is necessary to fulfill the purpose. The period during which we store your information will be determined specifically depending on the case in which the information is included. We delete your information as soon as your case has been processed unless we need to be able to document the correspondence/complaint for a longer period.
If you are a customer or a potential customer
The purpose of processing your information when you are a customer or potential (consumer or business) customer, including when you make purchases in our online stores, is to fulfill agreements with you, including ensuring the completion, delivery, or cancellation of an order and related services.
If you are a direct party to the contract (e.g., if you are a one-man business), our legal basis for processing your information is to enter into or fulfill a contract with you as a customer or potential customer in connection with the conclusion of a contract, according to the General Data Protection Regulation, Article 6 (1)(b). In other cases, we process your personal information based on our legitimate interest in protecting our rights and obligations under the agreements, etc., that we have entered into with the company you are employed by, according to the General Data Protection Regulation, Article 6 (1)(f).
In addition, we process your information in connection with:
· Customer support and general communication
· Quality assurance of our products and services
· Development of our products and services
· Credit ratings
· Internal analysis and reporting, as well as training of our employees
Our legal basis for this processing is generally that we can pursue our legitimate interest in the above purposes, according to the General Data Protection Regulation, Article 6 (1) (f).
The processing may also be necessary to establish, pursue, or defend legal claims, according to the General Data Protection Regulation, Article 6 (1)(f), and Article 9 (2)(f).
The information we process:
We may process the following information about you as a customer or potential customer:
· Contact information; e.g., name, address, email, phone number, postal code, customer number, initials
· Work related information: e.g., title, position, place of work
· Financial information, such as payment terms, details of bank account and credit valuations
· IT related information, such as user-id, login details, and data and logs about your use of our websites
· Photos or videos of you
Storage of your information
We retain your information for as long as we have a business relationship and for a period after the end of collaboration's to comply with applicable laws, including accounting laws in the countries where we operate. However, the information may be processed and stored longer in anonymized form.
If you visit our website
Personal information about you will be collected through our websites and apps in one or more of the following cases:
· When you visit and browse our websites
· When you create a user profile
· When you download material from our website
· When you use our other features and services
We will also collect your personal information through our websites and apps when you communicate with us, such as submitting an inquiry through a contact form, subscribing to our newsletter, participating in our competitions, or using other services and services through our websites. These processes are described in separate sections of the privacy policy.
The purpose of processing your data when you visit our websites is:
· That we can manage user accounts and profiles
· That we can develop, improve and manage these platforms, including ensuring the content is relevant and presented in the most effective way on your device
· To ensure that you have the opportunity to participate in/register for interactive features and offers from us
· To analyze traffic on our websites
Our legal basis for processing your information is our legitimate interest in the above purposes, according to the General Data Protection Regulation, Article 6 (1)(f), or your consent, which we obtain if required by law, according to the General Data Protection Regulation, Article 6 (1)(a), e.g., in connection with the use of cookies. You can read more about the use of cookies in the section below.
We are also obligated to ensure compliance with laws regarding the marketing of our products. Therefore, we process information for this purpose, and our legal basis for processing this information is our legal obligations to comply with laws related to the purchase and marketing of our products, according to the General Data Protection Regulation, Article 6(1)(c).
Finally, we may also process information that you have apparently made public, according to the General Data Protection Regulation, Article 6(1)(f), and Article 9(2)€.
The information we process:
We may process the following information about you as a visitor to our websites:
· Contact information; e.g., name, address, email, phone number, postal code, customer number, initials
· Photos or videos
· Other information that you may have published
· Cookies
Storage of your information
Information processed in our apps is stored as long as your profile is active, but we may retain the information for a longer period if required by law in the countries where we operate. As for the storage period for cookies, please refer to the cookie section below.
If you visit our social media profile
We and the providers of the relevant social media are joint data controllers for the processing of personal data collected in connection with your visit to our profile or page on each social media platform.
We have profiles or pages on various social media platforms. You can customize your privacy settings individually on each platform. We refer to the provider's privacy policies and settings for the use of the platform.
The information we process:
When you visit or interact with our profiles on social media, we and the provider of that social media platform may collect, process, and store the following types of personal information about you:
· Information available on your profile, including name, gender, marital status, workplace, interests and city
· Whether you “Like” or have used other reactions on our profile
· Comments you leave on our posts, including in connection with competitions
· Your visit to our profile
Purposes of processing:
We process your personal information for the following purposes:
· Improvement of our products and services, including our profiles and pages on social media
· Statistics and analysis
· Communication with you if you comment on a post, write a review or send us a message
· Marketing in general
The social media providers process your personal information for purposes such as:
· Improving their services
· To provide us with statistics that the social media providers compile on the basis of, among other things, your visit to our profiles and pages
· Advertising and personalization of activities on the site
Our legal basis for processing your personal information is your consent, which you have given by using the social media platform and adjusting your settings there, according to the General Data Protection Regulation, Article 6(1)(a).
We do not process sensitive personal information about you unless you have made it publicly available, according to the General Data Protection Regulation, Article 9(2)(e).
The information we process
We may process the following information about you as a user of social media:
· Information available on your profile including name, gender, marital status, workplace, interests, city
· Whether you “like” or have used other reactions on our profile
· Comments you leave on our posts, including in connection with competitions
· Your visits to our profile
Storage of your information
We encourage you to delete comments, likes and other interactions you have left on our profile if you no longer want them to appear on our pages. We do not delete such publicly available interactions.
If you communicate with us via the social media messaging function, we will delete the messages when you request it.
Please refer to the privacy policy of the individual social media providers for information on how long they keep your personal data.
The social media platform providers’ sharing of information
The providers of social media platforms may, among other things, share your personal data with the following categories of recipients:
· Other entities within the group of companies of which the social media provider is part
· Externally with business partners who provide analysis and survey services
· Advertisers
· Other people who visit our profile or social media page (to the extent your information is publicly available)
· Researchers and other academics
You can find more information about with whom the social media providers share your personal data in the privacy policy of the individual providers, including in which cases the social media providers may transfer your personal data to recipients outside the EU/EEA.
If you receive marketing or participate in a marketing competition
The purpose of processing your data when you receive marketing or participate in a marketing competition is that we can carry out and administer marketing, including sending newsletters and conducting and administering competitions.
We also process your information to ensure that we comply with relevant legislation, e.g., applicable Marketing Practices Act(s) in the country where the marketing activities are carried out, when you receive marketing of our products or participate in our competitions.
We will only send you product information, newsletters, and other marketing material by e-mail if you have given your prior and explicit consent to this, unless applicable law allows us to contact you without such consent. In this connection, we make sure to fulfill our legal obligations to comply with legislation on the purchase and marketing of our products, cf. Article 6(1)(c) of the General Data Protection Regulation.
If you participate in one of our competitions and win a prize, we may make your and your potential guests’ information available on our website or on our social media pages. We may also share your information with third parties if necessary to provide you with your prize. The legal basis for processing in connection with competitions is generally the performance of an agreement with you, cf. Article 6(1)(b) of the General Data Protection Regulation.
For the above purposes, we may also process information that you have manifestly published, e.g., on one of our social media pages, cf. Article 6(1)(f) and Article 9(2)(e) of the General Data Protection Regulation.
The information we process
· Contact information, e.g., name, address, email, telephone number, zip code, customer number, initials
· Participant information: for example, information about you and your guests in connection with a competition that you enter or have won
· Photos or video of you and your potential guests
· Personal information: Age
· Other information that you yourself have provided in connection with participation in a competition or similar.
Storage of your information
We store your information for up to 2 years, unless we are obliged to store your information for a longer period in the country in which you have received marketing or participated in a competition or for as long as necessary for us to handle any matters regarding marketing or participation in a competition, including to document your participation. However, the data may be processed and stored longer in anonymized form.
We store documentation of your marketing law consent for 2 years from when you have revoked your consent to receive direct marketing material.
Sharing personal data
We may share your personal data with our suppliers and partners if necessary to fulfil our obligations to you. Suppliers and partners may be, for example, suppliers of goods or services (e.g., in connection with the delivery of an order to you), IT suppliers and providers of IT systems.
In connection with visits to our websites, use of other digital services offered by the Group or participation in events and when receiving other marketing material, we may also share your information with hosting companies, providers of booking systems, providers of marketing services and other providers of services necessary to fulfil these purposes. Such service providers will process the personal data in accordance with our instructions under signed data processing agreements.
Information may be required to fulfill our obligations under the law or to protect our or others’ rights, property, or safety. In these cases, we may disclose information to public authorities, auditors, lawyers, or other advisors.
In some cases, we disclose your data to other companies in the Group for the purpose of analyzing, developing, and managing our business, as well as in cases where our services are shared between our companies.
In connection with the development of the Group, the corporate structure may change, e.g., by transfer of all or part of the activities. In the event of transfer of parts of the business or other commercial changes, the processing basis for the connected disclosure of personal data is generally our legitimate interest herein.
If we transfer information to third parties outside the EU and/or EEA, we are obliged to take special precautions to ensure that your information is protected. We will always ensure an adequate level of data protection and a lawful basis for the transfer of your data, for example by using the EU Standard Contractual Clauses (SCC).
You can contact us at any time for more information about who your information is shared with.
Consent
In cases where we process your information based on your consent, you can always withdraw your consent. If you withdraw your consent, we will stop processing your information unless we are entitled or obliged to continue processing or storing your information on other grounds, including in accordance with the law.
Withdrawing your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
You can withdraw your consent at any time by:
· Contacting us (see contact details below)
· Deleting your profile in cases where you have created a profile
· Consent to cookies can be withdrawn as described in the cookie policy of the website you are visiting
If you withdraw your consent, you may not be able to fully use the features we offer on our websites.
Cookies
We use cookies on our websites. You can read more about our use of cookies in the cookie policy, which is available and updated at any time via a link on the website you are visiting.
Your rights
When we process your personal information, you have a number of rights under the General Data Protection Regulation:
· You have the right to gain insight into the information we process about you
· You can object to our collection and further processing of your information
· You have the right to have your information corrected or deleted, subject to certain statutory exceptions
· You have the right to ask us to restrict processing
· In certain cases you have the right to receive the information we have registered about you and request us to transfer such data to another data controller (data portability)
· If we process your data on the basis of “our legitimate interest”, then you can object to the processing on this basis
If you wish to exercise your rights, please contact us (see contact details below). In connection with inquiries regarding your rights, we ask you to provide us with sufficient information to enable us to process your inquiry, including that you enable us to identify you in relation to what your request is about.
Contact us
If you wish to exercise your rights or if you have questions about the processing of your data, you can contact us per e-mail at: carletti@carletti.dk.
Complaints
If you disagree with the way we process your information or the purposes for which we process the information, you are welcome to contact us at carletti@carletti.dk.
You can also lodge a complaint with your local data protection authority. You can find an overview of data protection authorities in the EU here: https://edpb.europa.eu/about-edpb/about-edpb/members_en
Changes to the privacy policy
We reserve the right to change this privacy policy in the event of significant changes in legislation or as a result of changes in our processing activities.