Privacy policy

Group 8

Data protection and confidentiality are important to KIRKBI Invest A/S (“we”, “us”, or “our”). This Privacy Policy sets out clear guidelines for KIRKBI Invest A/S’ processing of your personal data when you visit our website, https://www.travbyen.dk/, or in other ways interact with us via the website regarding Travbyen in Billund. 

  1. Data controller and contact information

KIRKBI Invest A/S is data controller for the processing of your personal data. You can find our contact information below:

KIRKBI Invest A/S
Koldingvej 2
DK-7190 Billund
CVR No. 31159830
Phone: 75 33 88 33
E-mail: travbyen@kirkbi.com

 

  1. Purpose, legal basis, and types of personal data

Below we have listed for which purposes we process your personal data when you interact with us regarding Travbyen in Billund.

 

a. To reply to your inquiries

If you contact us via the contact information on the website or in other ways, we will use your personal data to be able to respond to your inquiry. We typically process the following personal data about you: name, email, phone number and the topic of your inquiry.

We use art. 6(1)(f) in the GDPR (the rule on balancing of legitimate interests) as our legal basis. Our legitimate interest is to be able to respond to your inquiry and communicate with you.

We collect the personal data directly from you and we will keep your personal data only for the period necessary to fulfil the purposes listed above and e.g., for documentation, depending on specific request.

 

b. Pictures, video clips etc. from events

In connections with events regarding Travbyen we will sometimes take mood pictures, video clips or similar (hereinafter the “Recordings”) of the activities. In this connection, we may process your personal data (your picture). 

We use the Recordings internally to be able to communicate about the Trotting Track Project, and for internal evaluation. In addition, we use the Recordings for external communication about the Trotting Track Project, including in presentations, reports, and other external material and on the website for Travbyen where we may use some of the pictures to communicate about the development of Travbyen and the citizen involvement in the development of the area. We do not use the pictures for marketing. 

We use the rule on balancing of legitimate interest in Article 6(1)(f) of the General Data Protection Regulation as our legal basis for this processing. Our legitimate interest is to be able to document the Trotting Track Project, the ctizen involvement and to be able to communicate about the development of Travbyen, as described above. 

We store the pictures for as long as necessary for the above purposes. When we no longer need to process them for the fulfillment of one or more of the purposes listed above, the personal data will be deleted. 

 

c. To process proposals for activities or development of the area

If you submit proposals for activities or development of the area, either via the contact form, the contact information on the website or in other ways, we will use your personal data to be able to respond to your inquiry or assess your proposal. We may in this connection also contact you to find out more about your proposal or further dialogue in order to include any proposals in the development of the area.

We typically process the following personal data about you: name, email, phone number and the content of your proposal.

We use art. 6(1)(f) in the GDPR (the rule on balancing of legitimate interests) as our legal basis. Our legitimate interest is to be able to assess your proposal and communicate with you regarding your proposal to find out more about your proposal or further dialogue in order to include any proposals in the development of the area.

We collect the personal data directly from you and we will keep your personal data only for the period necessary to fulfil the purposes listed above and e.g., for documentation, depending on the specific proposal.

 

d. Use of our website

We use cookies on the website. You can read more in our cookie policy https://www.travbyen.dk/cookiepolicy/.

 

  1. Recipients

In order to fulfil above purposes, we may disclose your personal data to third parties, who on a contractual basis with KIRKBI Invest A/S, deliver relevant services, e.g., IT services. Such disclosure is subject to data processing agreements, and the data processor may not use the data for other purposes than to perform the processing on our behalf.

In general, your personal data is not disclosed to other data controllers without your consent, unless we are legally required to do so.

 

  1. Processing of personal data outside the EU/EEA

KIRKBI Invest A/S transfers, stores, and processes your data (including personal data and content) both inside and outside Denmark. Wherever in the world your personal data is transferred, stored, or processed by us or by companies carrying out such services on our behalf, we will take reasonable steps to ensure that your personal data is adequately protected in accordance with applicable data protection laws. 

If your personal data is transferred to countries outside the EU/EEA, such a transfer will be made on the following legal basis: 

  • Binding Corporate Rules  
  • The country has been approved by the European Commission as having an adequate level of security 
  • If the country is not approved by the European Commission as having an adequate level of security, we will transfer the data by use of "Model Contracts for the Transfer of Personal Data to Third Countries" (Standard Contractual Clauses), as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities 

We use Microsoft 365 for data storage within the EU/EEA. However, in some cases personal data may be accessed or transferred to countries outside the EU/EEA. If this is the case the transfer mechanism is Standard Contractual Clauses as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities

 

  1. Security

We have high standards for security, including when it comes to the protection of your personal data. We, therefore, have internal procedures and policies in place to ensure that we live up to our high standards and thereby comply with the requirements of implementing appropriate technical and organisational measures. Thus, we do our best to safeguard the quality and integrity of your personal data.

 

  1. Retention of personal data

We will retain your personal data for the period necessary to fulfil the purposes listed in Section 2. Data may be processed and stored for a longer period in anonymized form or if we are legally required to do so.

 

  1. Your rights

In accordance with the General Data Protection Regulation and the Danish Data Protection Act, you have certain rights.

  • You have the right to request access to and rectification or erasure of your personal data;
  • You have the right to object to the processing of your personal data and have the processing of your personal data restricted;
  • You have an unconditional right to object to the processing of your personal data for direct marketing purposes;
  • You have the right to receive the personal data that is being processed in a structured, commonly used, and machine-readable format (data portability).

Please note that there may be conditions to or limitations of these rights. It is, therefore, not certain that you e.g., always have the right of data portability - this depends on the specific circumstances of the processing activity.

You can exercise your rights by contacting us (see below). If you contact us by email, we will have to verify your identity for security purposes.

If you disagree with the way, we process your personal data or the purposes we process the data for, you are welcome to contact us. You can also file a complaint with:

The Danish Data Protection Agency
Carl Jacobsens Vej 35
DK-2500 Valby
T: +45 33 19 32 00
E: dt@datatilsynet.dk

  1. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy to accommodate material changes in legislation, new technologies, new and improved functions or to improve our website.

 

  1. Contact information

Send a mail to travbyen@kirkbi.com – with “Privacy Policy” in the subject line if you would like us to change or delete your personal data or if you have any questions related to this Privacy Policy.

 

 

This Privacy Policy was updated 15 March 2022