LUBRAL Specialsmøremidler's Data Policy (GDPR)

1.         GENERAL

1.1     This personal data policy applies only to personal data that is collected from this Home Page, www.lubral.dk.

1.2     This Privacy Policy describes how LUBRAL Special Lubricants ("LUBRAL") collects and processes personal information about you.

1.3     Personal data is everything that can be attributed directly or indirectly to a person - even if it is only possible to specifically know who the information relates to.

1.4     LUBRAL is the data controller for your personal data. All inquiries to LUBRAL can be made using the contact details listed under section 7.

2.         COLLECTED PERSONAL INFORMATION, ITS OBJECTIVES AND LEGAL BASIS OF TREATMENT

2.1     LUBRAL collects personal information about you when you contact us. Personal information covers data like your:

This information is stored in our book keeping.

There are three ways to collect information. One is when you approach the company regarding a purchase or an information about a product. Such inquiries may be by telephone, using email, or when using the Home Page if you thereby need to provide personal information. Another way is through visits to the Home Page if you specifically create a personal profile, for example when purchasing a product or by signing up for a newsletter. The third way is that when visiting the Home Page we automatically collect information about you, see section 2.2.

  1. The purpose is that we can deliver the products you have ordered and otherwise fulfill our agreement with you, eg. so that we can manage your rights in order for you to file a complaint. Information about your purchases can also be processed to comply with legal requirements including for accounting and accounting purposes.
  2. The legal basis for the processing is the EU General Data Protection Regulation (GDPR) Article 6 (1), points b, c and f.

2.2      While visiting LUBRAL's Home Page we automatically collect information about you, ie. about your use of it. This includes data like your IP address and hence your network location, and what type of computer you use (iPad, mobile or desktop), and what type of browser you use and which pages you seem to prefer, also how long time you may spend on each page. LUBRAL uses Google Analytics and thus has access to the tools offered there.

  1. The purpose is to optimize the user’s experience while using the Home Page and to optimize the Home Page's functions as well as to make targeted marketing by applying the Google Analytics tool. This processing of information is necessary so that we can improve the Home Page and generally show to users relevant information and offers.
  2. The legal basis for the processing is the EU General Data Protection Regulation (GDPR) Article 6 (1), point f. Processing is necessary for the data controller or a third party to pursue a legitimate interest, unless the data subject's (customer's or employee's) interests or fundamental rights and freedoms requiring the protection of personal data precede it.

2.3      If you sign up for our newsletter, we keep your name and your email address.

  1. The purpose is to make sure to deliver the newsletters to you.
  2. The legal basis for the processing is the EU General Data Protection Regulation (GDPR) Article 6 (1), point f.

3.         RECEIVERS OF PERSONAL INFORMATION

3.1      All shipping information such as name, address, e-mail, telephone number and order number and specific delivery requests are passed on to a carrier or a freight carrier to handle and deliver goods to you. A freight carrier is a data controller. When purchasing non-stocked goods, the said personal data are not passed on to the manufacturer or producer, or any other company or person who could otherwise have been responsible for the delivery.

3.2     Information may be left to external partners who process the information on behalf of LUBRAL. We use external partners (data processors) for, among other things, technical operation and improvements to the Home Page. These companies, LUBRAL's external partners, are data processors and under our instructions and process data that LUBRAL is responsible for. Data processors may not use the information, such as name and e-mail etc. for purposes other than fulfillment of the agreement with us, and is subject to confidentiality. We have signed data processing agreements with all data processors who process personal data on our behalf. Broadcast of newsletters takes place as an integrated use of the Home Page. We do not currently use retargeting, nor do we use companies such as TrustPilot for assessments based on personal experiences, but we make statistics (cf. section 2.2) on the Home Page itself.

3.3     Our data processor, Google Analytics /by Google LLC is established in the United States. The necessary information for the transfer of information to the United States is ensured through the data processor's certification under the EU-U.S. PRIVACY SHIELD FRAMEWORK, cf. the nature of the EU GDPR Article 45.

4.         YOUR RIGHTS

In order to establish openness about the processing of your information we as the data controller must inform you of your rights.

4.1     The right of access

  1. You are at any time entitled to ask us for information on what information we have registered about you. This includes the purpose the registration serves, which categories of personal data and recipients of information there may be, as well as information about where the information originated.
  2. You have the right to receive a copy of the personal information we process about you. If you want a copy of your personal information, you must send a written request to helpcenter@lubral.dk. You may be asked to verify your identity.

4.2     The right to correct data

  1. You have the right to rectify incorrect personal information about yourself. If you become aware that there are errors in the information that we have registered about you, you are encouraged to contact us in writing so that the information can be corrected.
  2. Information we have in connection with your signing up for our newsletters can be corrected in your user profile.

4.3     The right of deletion

  1. In some cases, you have the right to have all or some of your personal information deleted by us. If you revoke your consent and we do not have another legal basis to continue processing, for example, then your personal information will be deleted. To the extent that continued processing of your information is necessary, for example, in order for us to comply with our legal obligations or for legal claims to be established, enforced or defended, we are not obliged to delete your personal information.

4.4     The right to object

  1. At any time you have the right to object to our processing of your personal data for direct marketing purposes, including the profile-raising made to target our direct marketing.
  2. You also have the right at any time, of personal reasons, to object against the processing of personal data which we make on the basis of our legitimate interests, cf. section 2.

4.5     The right to restrict treatment for storage

  1. In some cases you have the right to limit the processing of your personal data to consist only of storage, for example if you believe that the information we process about you is incorrect.

4.6     The right to data portability

  1. There are cases where you have the right to get your personal information from us in a structured, commonly used and machine-readable format and have the right to transfer that information to another data controller.

4.8     The right to revoke consent

  1. At any time you have the right to revoke a consent you have given to us for the use of processing of personal data, for example the data you entered during signing up for a newsletter. If you wish to revoke your consent, please contact us at helpcenter@lubral.dk.

4.9     The right to appeal

  1. You have the right at any time to file a complaint about our processing of your personal data with the Danish Data Protection Agency, Borgergade 28, 5, 1300 Copenhagen K. Complaints can, among other things, be submitted by mail to the Danish Data Protection Agency dt@datatilsynet.dk or by telephone +45 33 19 32 00.

5.         DELETING PERSONAL DATA

5.1     Information collected using the Home Page will be deleted according to the rules of our Cookie Policy. LUBRAL does not set cookies itself. Third-party cookies have varying deadlines. The individual deadlines are listed in our Cookie Policy where you can also read more about how to delete your cookies from different browsers.

5.2     Information collected during your use of the Home Page, cf. section 2, is handled according to the following rules:

  1. Inactive users are deleted after 1 year. An inactive user is a user who has not been logged in for a period of 1 year. Users who are registered for a newsletter or other things are considered to be an active user.
  2. If you unsubscribe a newsletter the personal data entered at the time of signing up will be deleted after 1 year.

6.         SECURITY

6.1     Implementation of safeguards

We have implemented appropriate technical and organizational safeguards against the personal or accidental destruction, loss, alteration or degradation of personal data as well as against the knowledge or misuse of any unauthorized person.

6.2     Access limitations

Only employees who have a real need to access your personal data to do their work have access to them.

7.         CONTACT INFORMATION

LUBRAL Specialsmøremidler is the data controller for the personal data collected from the Home Page.

If you have any questions or comments regarding this Data Policy or would like to exercise one or more of your rights described in section 4, please contact:

LUBRAL Special lubricants
c/o K. Torpenhow
Sundvej 6-8
2900 Hellerup

Tel. 39 62 19 40
Email: helpcenter@lubral.dk

8.         CHANGES IN PERSONAL DATA POLICY

If we make any changes to the Data Policy, you may get informed by looking at the version number and the date at the end of this Data Policy.

If you have signed up for our customer club or a newsletter, you will also be informed that way.

9.         VERSIONS

Version 1, LUBRAL Specialsmøremidler's Data Policy (GDPR): May 24, 2018.

Version 2, LUBRAL Specialsmøremidler's Data Policy (GDPR): April 2, 2019. Source: FDIH

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