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1.1 This personal data policy describes our collection and processing of the personal data we collect about our customers (hereinafter referred to as the personal data policy).
1.2 The personal data policy applies to current, former and potential purchasing and non-purchasing business customers of DCS ApS (hereinafter referred to as "the customers").
1.3 The personal data policy applies to business customers in connection with our processing of personal data.
1.4 The personal data policy covers all personal data that current, former and potential purchasing and non-purchasing business customers provide to us, or that we collect via www.dcs.dk and www.dev.dcs.dk (hereinafter referred to as "the website").
1.5 DCS ApS is the data controller for the personal data we collect about the customers, and acts as data processor for data on the customers' own customers – this includes data in connection with delivery to end customers.
1.6 By accepting the personal data policy, the customers undertake not to disclose personal data collected via dialogue between DCS ApS and the customers - whether directly or indirectly in relation to the purchase contract.
2.1 What personal data do we collect?
2.1.1 When you visit the website, we automatically collect data about you. This includes data such as which browser you use, which pages you visit, which search terms you use, and information about your computer and your IP address.
2.1.2 When you place an order on the website, we register your name, address, e-mail address, telephone number, as well as information about which products you purchase and, where applicable, return.
2.2 What purposes does the personal data serve?
2.2.1 We collect the personal data referred to in section 2.1.1 for the purpose of improving the shopping experience at DCS ApS via the website, optimising conversion, and for targeted marketing.
2.2.2 We use the personal data referred to in section 2.1.2 in order to deliver purchased products to the customers or directly to the customers' own customers, to comply with our obligations regarding complaints, and to comply with our bookkeeping obligations.
2.3 What is the legal basis for the processing?
2.3.1 The collection of personal data referred to in section 2.1.1 is necessary in order for us to pursue our legitimate interests in improving the website and the shopping experience, and to enable us to present the customers with relevant products and offers.
2.3.2 The collection of personal data referred to in section 2.1.2 is necessary in order for us to perform the purchase contract with the customers.
2.4 Where is your personal data stored?
2.4.1 Personal data is stored on our secure servers. Some personal data is disclosed to third parties. Certain of these third parties are data processors who store and process personal data on behalf of DCS ApS in accordance with this data policy and in accordance with the data processing agreements entered into with the respective data processors. All personal data is stored and processed in accordance with applicable data protection legislation.
2.5 How is your personal data collected?
2.5.1 Personal data is collected primarily upon creation of customer accounts and completion of purchases.
2.5.2 In addition, personal data is collected on the website, among other things by means of cookies.
3.1 DCS ApS makes use of external companies to, among other things, assist with the technical operation and ongoing development of the website, as well as to carry out targeted marketing. Certain of these external companies are independent data controllers for the data disclosed to them. The basis for this disclosure is a balancing of interests between, respectively, the interests of DCS ApS and the interests of the customers, which ensures that personal data is not used for improper or inappropriate purposes. In addition, DCS ApS has entered into agreements regarding the disclosure of data to external companies for the purpose of performing the purchase contract with the customers. This could, for example, be PostNord or GLS.
3.2 Other of these external companies are data processors subject to our instructions. They process data on our behalf, and DCS ApS is therefore responsible for ensuring that the data processors do not use data received from us for any purpose other than the performance of the agreement entered into with us. All our data processors have entered into written data processing agreements with us, setting out guidelines for what they may and may not use the transferred data for.
3.3 One of these data processors, Google Analytics operated by Google Inc, is established in the USA, and the necessary safeguards for the transfer of information to the USA are ensured through the data processor's certification under the EU-U.S. Privacy Shield. A copy of the certification can be found here:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI
Furthermore, Facebook Inc. is located in the USA, and you can find a copy of their certification here: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
3.4 Pursuant to section 1.5, DCS ApS acts as data processor in connection with delivery to end customers, which is why it is the customers' responsibility to enter into a data processing agreement. A standard template for this can be found at the bottom of this document.
3.5 For the purpose of performing the purchase contract, the customers' stated e-mail address is used to send order confirmations, invoices and delivery information.
4.1 In order to create transparency regarding the processing of your data, we, as data controller, must inform you of your rights.
4.2 Documentation
4.2.1 As part of our efforts to raise the overall level of data security, we require documentation before processing requests concerning the exercise of the rights set out in sections 4.3-4.9 below.
4.2.2 When contacting DCS ApS regarding deletion of personal data, you will be required to go through an identification process before the personal data is deleted. This means that a PDF will be sent to you, which you are asked to sign personally and then return either in physical form or as a scanned document.
The scanned document should be sent to [email protected]
Alternatively, a physically signed document can be sent to the address below:
DCS ApS
Høgemosevænget 1
8380 Trige
Denmark
4.3 The right of access
4.3.1 You are entitled, at any time, to request information from us regarding, among other things, what data we have registered about you, the purpose of the processing, and which sub-processors we use.
4.3.2 This right can be exercised by sending a request to [email protected].
4.4 The right to rectification
4.4.1 You have the right to have inaccurate personal data about yourself rectified by us. If you become aware that there are errors in the data we have registered about you, you are encouraged to contact us in writing so that the data can be corrected.
4.4.2 Data we have collected in connection with your creation of a customer account can be corrected by you via login to your customer account under the "Master data" and "E-mails" sections.
4.4.3 Regarding documentation, please refer to section 4.2.
4.5 The right to erasure
4.5.1 In certain cases, you have the right to have your personal data erased. To the extent that continued processing of your data is necessary, including in order for us to comply with our legal and bookkeeping obligations, or in order for legal claims to be established, exercised or defended, we are not obliged to erase your personal data.
4.5.2 Regarding documentation, please refer to section 4.2.
4.6 The right to restriction of processing
4.6.1 In certain cases, you have the right to have the processing of your personal data restricted to storage only, for example if you believe that the data we process about you is inaccurate.
4.7 The right to data portability
4.7.1 You have the right to receive your personal data in a structured, commonly used and machine-readable format, and you have the right to transfer this data to another data controller.
4.7.2 Regarding documentation, please refer to section 4.2.
4.8 The right to object
4.8.1 You may, at any time, object to our processing of your personal data that we collect in order to improve functions on the website and its structure, if you have particular reasons for doing so.
4.8.2 If we are unable to demonstrate legitimate grounds for continuing the processing, we will no longer be entitled to process your personal data.
4.8.3 Regarding documentation, please refer to section 4.2.
4.9 The right to withdraw consent
4.9.1 You have the right, at any time, to withdraw your consent in connection with your subscription to our newsletter.
4.9.2 Regarding documentation, please refer to section 4.2.
4.10 The right to lodge a complaint
4.10.1 You have the right, at any time, to lodge a complaint with the Danish Data Protection Agency (Datatilsynet), Borgergade 28, 5, 1300 Copenhagen K, regarding our processing of your personal data.
5.1 Personal data that we register about you through our website is, as a general rule, stored for 5 years, provided there is no activity on the account. Activity means that a purchase is made, information is changed, or a login occurs. A customer account is therefore only deleted if the account has been inactive for 5 years.
5.2 All invoices are stored for 5 years from the end of the financial year in accordance with the Danish Bookkeeping Act. After 5 years, all invoices are anonymised.
5.3 All purchase information is automatically deleted after 5 years.
5.4 Data we have collected in connection with your consent to receive newsletters from us will be deleted if you withdraw your consent, cf. section 4.8.
6.1 We have implemented appropriate technical and organisational security measures to prevent personal data from being accidentally or unlawfully destroyed, lost, altered or impaired, and to prevent it from coming to the knowledge of unauthorised persons or being misused.
6.2 Through the implementation of adequate organisational security measures, we have established guidelines regarding which employees have access to your data, such that only those employees who have a genuine need to access your personal data in order to perform their duties have access to it.
7.1 DCS ApS uses cookies on the website to improve the user experience and to personalise content. This information is shared with third parties, such as Google. By using our site, you consent to the use of cookies.
7.2 A cookie is a small data file that enables information to be stored, or already stored information to be accessed, on your computer from the website you visit. Cookies are used by the vast majority of websites today. Cookies help ensure that the website's functions work as intended, and they are used to recognise your computer on repeat visits. No personal information is stored in our cookies, and they cannot spread viruses or other harmful programs.
7.3 DCS ApS uses cookies in connection with analysis of website usage and automation of the purchasing process, such as automatic completion of delivery and payment method.
Below is a list of the cookies used by DCS ApS to improve the user experience:
| Cookie | Type | Description |
|---|---|---|
| REMEMBERME | 1st party | Cookie used to store preferences on the website. |
| flasfka | 1st party | |
| DSID | 3rd party | Advertising cookie via Google used to identify behaviour across devices. |
| IDE | 3rd party | Advertising cookie via Google. |
| _ga | 3rd party | Statistics on website usage via Google Analytics. |
| _okgid, _ok, _okbk, _okdetect, _oklv, _okla, hbild, olfsk, wcsid | 3rd party | Live chat functionality. |
| fr | 1st party | Advertising cookie via Facebook. |
7.4 If you do not wish to allow cookies, a guide is available on the website of the Danish Business Authority (Erhvervsstyrelsen) explaining how this can be done.
8.1 DCS ApS is the data controller for the personal data collected via the website.
8.2 If you have questions or comments regarding this Personal Data Policy, you can contact:
DCS ApS
Høgemosevænget 1
8380 Trige
Denmark
Phone: (+45) 70222505
E-mail: [email protected]
9.1 DCS ApS is entitled, at any time, to make amendments to this personal data policy. The date on which the personal data policy was last updated will always appear at the bottom of the document.
9.2 If you do not accept the amended policy, you will not be able to continue using the website.
10.1 Pursuant to sections 1.5 and 3.4, DCS ApS acts as data processor in connection with delivery to end customers and drop shipping to the customers' own customers, which is why entering into a data processing agreement is the customers' responsibility.
A standard template for this can be found here.
11.1 This is version 1 of DCS ApS' personal data policy, dated 24 May 2018.