Information on the processing of personal data
Updated: 4 September 2020.
Dear User,
We care about your Personal Data and we are committed to protecting and processing them with the utmost attention and diligence.
We would like to provide you with clear information about the means of the processing regarding Personal Data collected through Holte Software Poland sp. z.o.o. (hereinafter Holte Software Poland sp. z.o.o., “we”, “us” or “our”) when we act as data controller. You can also read about your rights in connection with our processing of your data
1. Holte Software Poland sp. z.o.o. as data controller
Holte Software Poland sp. z.o.o. is part of the EG group, one of Scandinavia’s largest providers of technology solutions for the private and public sector. Our continuous focus on our customers, their industries and the delivery of industry-leading solutions enables EG to become a leader in its field.
In connection with our business activities, we process a certain amount of personal data. We do so to be able to serve you in the best possible way. We mainly collect and process general (non-sensitive) data.
Should you have any questions regarding our processing of your personal data, please contact EG’s data protection office:
EG A/S
Data Protection Office
Industrivej Syd 13 C
7400 Herning, Denmark
E-mail: dpo@eg.dk
Tel. No.: +45 7013 2211
2. What personal data we collect and for what purpose
We process your personal data in various situations. Below you can read more about how we process data in different situations.
2.1 Users of the Holte Poland website
When you visit EG’s websites (e.g. www.holte.pl), Holte Poland may process information about your IP address, as well as information about your computer, device and browser.
We also process information relating to your visit (e.g. information about how you access our websites, how you navigate through them, pages you visit, content you view, searches you perform, ads you view, etc.). ). This information is collected through cookies, log files and other technologies. For more information, please see our cookie banner.
We also process data that you provide to us in connection with your use of the website, e.g. when you fill in a form or register online, including your name, company name, company address, business phone number/mobile phone number, email address, position, interest in a product and any other information that you provide to us.
We use your data to enable us to provide you with relevant services and products and to improve your experience of our websites and online services and the services and products we offer. We also use your data to display content to you on our and other websites based on your actions and preferences and to limit the number of times you view the same content.
The basis for data processing is our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) or your consent (Article 6(1)(a) of the General Data Protection Regulation and the Act of 16 November 2012 amending the Telecommunications Act and certain other acts Article 173. (https://www.dziennikustaw.gov.pl/D2012000144501.pdf)
2.2 EG’s customers and potential customers
If you are a customer/potential customer of EG or a contact person of one of EG’s customers/potential customers, EG processes personal data concerning your name, company name, business address, business telephone number/mobile telephone number, email address, position, your purchases, payment information and information from publicly available sources, as well as other information you provide to us.
We process personal data in order to fulfil the contract concluded with our customers, to provide services, invoicing, statistics and quality management, as well as to keep records of our customers and to provide general service, marketing and sales to our customers and potential customers.
The basis for data processing is the contract concluded with you (Article 6(1)(b) of the General Data Protection Regulation) or our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
2.3 Participants in EG events
When you sign up for and attend events organised by EG, we process information about your name, company name, company address, business phone/mobile phone number, email address and the event you are attending.
We process this information to manage the event and for security reasons, as well as to send you relevant materials.
The basis for data processing is our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) or your consent (Article 6(1)(a) of the General Data Protection Regulation and Article 10 of the Danish Marketing Practices Act).
2.4 Recipients of marketing services and participants in competitions
When you receive marketing materials from EG or enter competitions, we process information about your name, company name, company address, business/mobile phone number, email address, position and interest in the product. We also process information about your marketing or communication preferences and how you use the marketing materials we send to you (including whether you have opened an email from us, whether the email has been read and what links have been opened) and the information you provide to us.
We process your data for marketing our company and its products, to set up and manage your account as a marketing subscriber and to run competitions, draw winners etc. We use your preferences and usage data to understand how our customers perceive our marketing activities and to prepare marketing activities for you and our other customers in the future.
We only send marketing material to you by e-mail or other electronic channels after we have obtained your consent in accordance with the provisions of the Danish Marketing Practices Act.
We have set special conditions for our newsletter: By signing up to receive EG’s newsletter, you consent to EG processing your personal data (Art. 6 (1) (a) of the General Data Protection Regulation and § 10 of the Danish Marketing Practices Act) for the sole purpose of receiving newsletters and marketing materials. You may withdraw your consent unconditionally and at any time (Article 7(3) of the General Data Protection Regulation). This can be done by clicking the unsubscribe link in the newsletter. Your personal data will be deleted unless we have another legal basis to continue processing your personal data.
We also use your data to display content to you on our and other websites based on your actions and preferences and to limit the number of times you see the same content, and to measure the effectiveness of our content and marketing efforts.
The basis for data processing is our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) and/or your consent (Article 6(1)(a) of the General Data Protection Regulation and Article 10 of the Danish Marketing Practices Act).
2.5 Partners and/or suppliers of Holte Poland sp. z.o.o.
If you are a partner or supplier of Holte Poland or a contact person at a partner/supplier, we process information about your name, company name, company address, business telephone number, e-mail address and position, as well as publicly available information and other information that you provide to us.
We process such data in order to manage contracts, as well as to receive goods and services from our suppliers and partners and, where applicable, to recognise contracts with our customers.
The basis for data processing is the contract concluded with you (Article 6(1)(b) of the General Data Protection Regulation) or our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
2.6 Other general purposes of data processing
We may supplement the information referred to above with information from other sources. This may be publicly available information, including information we obtain from publicly available sources.
The information we have obtained for the purposes described above may also be processed by Holte Poland in order to comply with laws and regulations to which Holte Poland is subject in connection with the operation of our business or to comply with various reporting or information obligations under applicable laws and regulations (Article 6(1)(c) of the General Data Protection Regulation).
Should Holte Poland sell all or part of our business, sell or transfer our assets or otherwise be involved in a merger or transfer of all or a substantial part of our business, EG may transfer user information to the party or parties involved in the transfer as part of this transaction, if permitted by Danish law (Article 6(1)(f) of the General Data Protection Regulation).
Finally, Holte Poland may process your personal data in order to enforce or defend our or a third party’s legal or legitimate interests if this is necessary, lawful and proportionate (Article 6(1)(c) of the General Data Protection Regulation).
3. Sharing data with other entities
Holte Poland may disclose your personal data within the EG Group and to other suppliers and/or service providers for the purpose of the general operation of our business.
Holte Poland may also disclose personal data to public authorities in situations where we are obliged to disclose personal data in accordance with the law and the notification obligations we are subject to.
We receive technical data from third party analytics providers about your visits to our website.
We endeavour to limit the disclosure of personal data in personally identifiable form and thus the disclosure of information that can be attributed to you personally.
Holte Poland also entrusts your personal data to data processors, e.g. in connection with the administration of our IT systems or in connection with our marketing. Our data processors process your personal data exclusively for our purposes and on our instructions. We enter into data processing agreements with our data processors to ensure the required security and data protection and compliance with our data protection obligations.
In general, the principle of balancing of interests set out in Article 6(1)(f) of the General Data Protection Regulation is applied as a basis for processing.
4. Transfer of personal data to countries outside the EU/EEA
As we process your personal data, we may transfer this information to countries outside the EU/EEA. Data protection laws in these countries may be less stringent than in Denmark and other EU/EEA countries. However, in some countries, the European Commission has determined that the level of data protection is in line with the level of protection in the EU/EEA. If we transfer personal data to countries where this is not the case, the transfer of personal data to these countries outside the EU/EEA will be based on standard data transfer agreements developed by the European Commission or another similar basis for transferring data specifically designed to ensure an adequate level of protection.
You can read more about the transfer of personal data to non-EU/EEA countries on the European Commission website.
5. Storage period, data integrity and security
We will keep your personal data for no longer than is necessary for the purpose for which it was collected. When your data is no longer needed, we will ensure that it is deleted in a secure manner.
It is our policy to protect your personal data by taking appropriate technical and organisational security measures.
Information security is EG’s highest business risk priority. We take information security seriously and professionally based on internationally recognised security standards, including ISO 27001/2, and have implemented security measures to ensure that all personal data we process is protected. We regularly conduct internal audits on the adequacy and compliance with policies and measures.
6. Your rights
As a data subject, you have a number of rights under the General Data Protection Regulation. Please contact us if you wish to exercise these rights.
You can withdraw your consent unconditionally and at any time. This can be done by sending us an email (see the email address above). Withdrawing your consent will not have any negative consequences. However, it may mean that we cannot accept certain requests from you in the future. The withdrawal of consent will not affect the lawfulness of processing based on your consent before its withdrawal. Furthermore, it will not affect processing carried out on another legal basis. You may also object to our processing of your data, without reservation and at any time, where it is based on our legitimate interests.
Your rights also include the following:
- Right of access: You have the right to access your personal data that we process.
- Right to rectification: You have the right to rectify inaccurate personal data about you and to complete incomplete personal data.
- Right to erasure (right to be forgotten): In certain circumstances, you have the right to have your personal data erased before the time we delete them.
- Right to restriction of processing: In certain circumstances you have the right to restrict the processing of your personal data. If you have the right to restrict processing, from then on we will only process your data – with the exception of storage – with your consent or for the establishment, exercise or defence of legal claims, to protect the rights of another natural or legal person or for reasons of substantial public interest.
- Right to object: You have the right to object to our processing of your personal data in certain circumstances, and always where the processing is for direct marketing purposes.
- Right to data portability: In certain circumstances, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have that personal data transferred from one controller to another.
- Right to lodge a complaint: You may lodge a complaint with the Polish Data Protection Agency (PDPA) at any time in relation to our processing of your personal data. For more information, please visit https://uodo.gov.pl/p, where you can also find further information on data subjects’ rights
7. Updates
Please note that we are constantly reviewing and updating this data information. It is therefore a good idea to update your data regularly. The notification above indicates when it was last updated. The latest version will always be available on our website.
8. Information on the use of cookies
Below you can read how EG companies use their own cookies and third-party cookies to analyse the use of our online activities.
Please note that on some Holte Poland websites there is content that can only be displayed if cookies are saved. Cookie data is also used to collect personally identifiable information for marketing purposes.
A cookie is a small text file that is stored in the web browser on your computer, smartphone, iPad or other device you use to browse the Internet. Cookies make it possible to recognise your computer etc., to collect information about your online behaviour, including the websites and functions visited by your browser. Using cookies ensures that it works correctly from a purely technical point of view.
In some cases, cookies are the only way to make a website work as intended. A cookie is a passive file and therefore cannot collect information on your computer or spread computer viruses or other malware. It is anonymous and does not contain any personal information. Cookies are used by basically all websites. For more information, see our cookie banner.
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