Personal Data Protection Policy

1. Data controller

Carsten Holm A/S is the Data Controller responsible for processing personal data necessary in connection with the processing of the following:

Customers’ and suppliers’ collaboration with Carsten Holm A/S
Private individuals’ applications for jobs or periods of practical work experience submitted to Carsten Holm A/S

Carsten Holm A/S seeks to ensure that your personal data is processed in accordance with applicable legislation, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter named GDPR) and associated Danish legislation. We have therefore adopted this Personal Data Protection Policy to protect your personal data.

Contact details:

Carsten Holm A/S
Kielbergvej 16
5750 Ringe, Denmark
Business registry/VAT no.: DK 89490812
Tel: +45 62 62 52 55
Email: holm@carstenholm.dk

2. Fundamental principles for processing personal data

Carsten Holm A/S maintains fair and transparent processing of all the personal data we collect and store. We process all personal data in accordance with the fundamental principles of data processing and best practices to ensure that personal data is:

Processed legally, fairly and transparently
Collected solely for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
Sufficient, relevant and limited to that which is necessary to meet the purposes stated
Accurate and, if necessary, updated
Stored for no longer than is necessary to meet the purposes stated
Stored in a manner that ensures appropriate security and confidentiality.

3. Processing personal data

3.1 Carsten Holm A/S’ processing of personal data regarding customers and suppliers

To ensure correct processing of the personal data of customer and supplier contacts, Carsten Holm A/S processes a series of personal data submitted in connection with registering the person in Carsten Holm A/S’ systems. Carsten Holm A/S processes solely the personal data of customer and supplier contacts that is necessary, relevant and sufficient to meet the following purposes.

Carsten Holm A/S collects and stores the personal data of customer and supplier contacts in connection with:

Recording details of the person in relevant systems at Carsten Holm A/S.
Historical email data regarding case processing related to day-to-day operations and business procedures
Valid trading/partnership agreements
Marketing activities (once consent is given)
Invoicing and accounting
Performance of ordinary administrative tasks for external contacts, such as recording and maintaining personal contact details.
Recording the login code to relevant systems
Preparing statistical data based on external contacts’ personal data for operational and audit-related purposes

We collect, record and store only the personal data we need to achieve specified purposes.

3.2 Carsten Holm A/S’ processing of personal data in connection with applications for jobs and periods of practical work experience

In connection with applications for jobs and periods of practical work experience submitted digitally, Carsten Holm A/S stores applications and associated personal data solely in our email archives. The data is recorded and processed nowhere else and will at no time be transferred to a third party. Our email archives are erased at regular intervals, at which time all the data is erased.

3.3 The legal basis for Carsten Holm A/S’ processing of your personal data

We base our processing of personal data on the following legal basis:

Your consent cf. Art. 6(1)(a) and Art. 9(2)(a) of GDPR
Carsten Holm A/S’ legal and contractual obligations cf. Art. 6(1)(b) of GDPR
Carsten Holm A/S’ legitimate interests that override your interests and fundamental rights, cf. Art. 6(1)(f) of GDPR The legal basis includes how we process your personal data for purposes related to the preparation of statistical data or in connection with assessing, at any given time, whether Carsten Holm A/S’ purposes and charter are met.
If Carsten Holm A/S has a legal basis for collecting and processing your personal data other than the above, Carsten Holm A/S will inform you of that legal basis and of our legitimate interest in processing your personal data.

Carsten Holm A/S will transfer your personal data only when necessary.

Carsten Holm does not transfer the personal data of customer and supplier contacts to third parties, unless transfer of their data is necessary in connection with their capacity as cooperative partners of Carsten Holm A/S. Situations in which we may transfer the personal data of customer and supplier contacts include:

Transfer of personal data to system developer
Transfer of personal data to server host
Transfer of personal data to co-organisers of training courses and events

Carsten Holm A/S does not transfer the personal data of customer and supplier contacts to countries outside EU/EEA. If a sub-data processor transfers personal data to countries outside EU/EEA, the conditions for such transfer will be described in the associated data processor agreement

Carsten Holm A/S stores your personal data for no longer than is necessary.
Carsten Holm A/S stores the personal data of customer and supplier contacts only for as long as is necessary to achieve their specific purpose.

Carsten Holm A/S erases the personal data of customer and supplier contacts when it is no longer necessary that we store them for specific purpose(s) or when we are no longer legally required to process them.

Carsten Holm A/S updates your personal data
Carsten Holm A/S regularly checks that the personal data of customer and supplier contacts that we process is accurate, and we make sure that the data is regularly updated. As our case management processing depends on accurate personal data regarding our customer and supplier contacts, we ask them to notify us of relevant changes to their personal data.

Security of processing
Carsten Holm A/S has an internal IT security policy that includes instructions and measures designed to protect your personal data against destruction, loss, modification, unauthorised publication and unauthorised access or disclosure.

4.0 Use of cookies

Carsten Holm A/S’ website uses cookies in accordance with the following guidelines.

Our website “carstenholm.dk” uses cookies. When you use our website, you tacitly accept that the website uses cookies as described below. A cookie is a small text file that is saved on your web browser or on the device you use to access our website A cookie may contain text and figures, e.g. dates. Cookies are not computer programs, and they contain no harmful computer viruses or codes. Cookies can only be read by their website of origin. Ordinary cookies saved from our website are typically saved from the URL you can see in the browser address bar. However, the website may also contain fragments and data collected from other URLs than the one you can see in the browser address bar. Examples of other URLs include other analysis tools and general web content. This means that cookies from other URLs may be saved via Carsten Holm A/S’ website. These are called third-party cookies. Temporary cookies, called session cookies, are saved only for a single browser session. They are deleted once the user closes the browser. Other cookies, called persistent cookies, are saved for a specific period of time. They are erased after expiry of this period.

Purpose
We used cookies primarily to enhance the performance and functionality of our website for our users. Cookies are used to save specific information about the user’s web browser so that the website later recognises the user and loads faster using the saved information.

Third-party cookies
Our website uses third-party cookies. Google Analytics tracks and analyses how users use the website. To do this, Google Analytics sets one or more cookies that log the user’s information and activity on the website. Google Analytics is permitted to transfer this information to third parties if legally required to do so or if such third parties process the information logged on Google Analytics’ behalf. If you do not wish to be subject to Google Analytics’ tracking, you can opt out permanently. To opt out, download and install the Google Analytics Opt-out Browser Add-on in your browser: http://tools.google.com/dlpage/gaoptout?hl=en

Disable cookies
You can erase (delete) cookies from your browser’s historical data at any time. Note, however, that when you delete cookies, you do not avoid new cookies being saved on your device. To avoid new cookies altogether, you must set your browser to disable cookies. In some browsers, it is possible to disable cookies for a certain number/type of websites.

5. Rights

The right to withdraw consent
You have a right at any time to withdraw consent to processing your personal data. If you withdraw consent, kindly note that, in some cases, e.g. if Carsten Holm A/S has other legal grounds for processing your personal data, Carsten Holm A/S will be entitled to continue processing the data. In such cases, you will be notified.

The right to insight
You have a right at any time to receive information from Carsten Holm A/S as to which data we process about you and the source from which the data originates, the purpose(s) of the processing, whether we transfer personal data to third parties and for how long we will store your personal data or the criteria used to establish the storage period.

If you withdraw consent, Carsten Holm A/S has a duty to erase your personal data, unless we are required and authorised by dint of other legal grounds to process it. If you ask us to amend or erase your personal data, we will investigate if the conditions for such action are met and, if so, we will amend or erase the data as soon as possible.

The right to object to the processing of personal data
You have a right to object to our processing of your personal data. You can send your complaint to Carsten Holm A/S at holm@carstenholm.dk. If you lodge a complaint, Carsten Holm A/S shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. If Carsten Holm A/S does not believe that your complaint is reasonable, we will notify you of our objections.

Complaining to the Danish Data Protection Agency
You have a right at any time to lodge a complaint against Carsten Holm A/S regarding the processing of your personal data to the Danish Data Protection Agency. Read more at www.datatilsynet.dk