Last updated: August-2022
When you, eg: contact us, make a purchase on behalf of or otherwise represent one of our customers, partners and/or vendors, etc., we may collect and process your personal data. The data controller is the company within the Naver Energy which you are associated or have been in contact with, as further described below:
Data controller: Naver Energy ApS
Address: Havneholmen 29, 1561 Copenhagen V, Denmark
Naver Energy ApS is committed to ensuring that your personal data is stored and processed in accordance with the relevant rules on data protection, including the General Data Protection Regulation ("GDPR") and the Danish Data Protection Act.
1. CATEGORIES OF PERSONAL DATA
The personal data that we collect about you will typically include your name, job title, telephone number and e-mail address, which we may receive as part of the regular course of business relations or correspondence through phone or e-mail.
We do not process special categories of personal data (sensitive personal data) regarding representatives of our business partners.
2. PROCESSING PURPOSE
We will mainly collect and process your personal data for purposes of improving or facilitating an existing or future cooperation, or fulfilling an existing B2B contract between one of the companies within Naver Energy and the company you represent. In this connection, processing of personal data will typically be required when you contact us for a specific purpose or with a specific request or in an existing business relationship.
We will also collect and process your personal data for bookkeeping purposes and to invoice services provided to the company you represent and vice versa.
Further, we will collect and process your personal data for the defence of legal claims, e.g., claims related to existing warranties and product liability.
3. LEGAL BASIS FOR PROCESSING
The processing of your personal data is necessary for the purposes of our legitimate interests which are regarded not to be overridden by your interests or fundamental rights, cf. Article 6(1)(f) of the GDPR. Such legitimate interests include:
fulfilment of contractual obligations with the company you are representing;
Maintaining and enhancing customer relationships;
Invoicing for products and services provided to/by companies within Naver Energy and vice versa;
Communicating with you as a representative of one of our business partners;
maintaining documentation of events, correspondence, etc. in case of a specific dispute, claims and/or damages, or otherwise for the establishment, exercise, or defence of/against legal claims.
Furthermore, certain processing is necessary in order to comply with our legal obligations, cf. Article 6(1)(c) of the GDPR, namely retaining bookkeeping material pursuant to applicable bookkeeping rules such as the Danish Bookkeeping Act and the Danish Tax Control Act.
4. RECIPIENTS OF YOUR PERSONAL DATA
Where relevant, we may disclose or transfer your personal data to intra-group companies, affiliates of Naver Energy, vendors, business partners or other collaborators for business purposes, including delivery of products and services, legal matters and maintenance of our internal IT systems, etc.
Certain recipients process personal data on our behalf, i.e., as data processors. These third parties may, therefore, only process your personal data in accordance with our instructions and are, therefore, not permitted to process your personal data for their own purposes.
To the extent that we disclose or transfer your personal data to third parties who may use your personal data for their own purposes, such disclosure or transfer will only take place if it is in accordance with applicable law.
5. TRANSFER OF YOUR PERSONAL DATA TO A THIRD COUNTRY (OUTSIDE OF EU/EEA)
In certain situations, your personal data may be transferred to a country outside of EU/EEA, for instance to an affiliate of Naver Energy or a vendor. We will ensure that such transfer is carried out in accordance with applicable data protection law. This entails that any party outside of EU/EEA that comes in possession of your personal data must ensure an adequate level of protection, for example, by entering into the EU standard contractual clauses.
If you wish to obtain a copy of the appropriate safeguards provided for such a transfer, please contact us through the abovementioned e-mail.
6. STORAGE OF YOUR PERSONAL DATA
Naver Energy will only store your personal data for as long as necessary to fulfil the abovementioned processing purpose(s).
We will store your personal data until the termination of the contractual relationship between us and the company which you represent, as long as we communicate, or until a legal claim can no longer be established.
If there is an actual or potential legal dispute with the company you represent, your personal data will be retained as long as necessary for this purpose. Hereafter, your personal data will be deleted.
In addition, we will store personal data, necessary for bookkeeping purposes in accordance with the special rules on the retention of bookkeeping material in the Danish Bookkeeping Act, i.e., for 5 years. If the personal data is included in accounting material which is subject to other (foreign) legislation, the personal data will be processed as long as required under the said legislation.
7. YOUR RIGHTS AS A DATA SUBJECT
We have implemented appropriate organisational and technical measures in order to protect your personal data and ensure your rights as a data subject.
As a data subject, you have a number of rights. Please note that certain limitations may apply in this relation, e.g., when your right to obtain information is found to be overwritten by essential considerations of private interests. If you have any questions about your rights as a data subject, please contact us through the abovementioned means of contact.
According to the GDPR, you have the following rights:
Right of access: You have the right to request access to the personal data Naver Energy has stored concerning you. Naver Energy must provide a copy of the personal data undergoing processing free of charge and by electronic means if the request has been submitted in a commonly used electronic form.
Right to rectification: You have the right to rectify inaccurate personal data concerning you, including the completion of incomplete personal data.
Right to erasure (Right to be forgotten): Under certain circumstances, you have the right to erasure; meaning that, upon your request, we must erase the personal data stored concerning you.
Right to restriction: Under certain circumstances, you have the right to restrict our processing of personal data concerning you.
Right to data portability: You have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format. Where the processing is based on your consent or a contract and the processing is carried out by automated means, you have the right to transmit this personal data to a third party without hindrance by Naver Energy.
The right to object: Under certain circumstances, you have the right to object to our processing of personal data concerning you at any time.
If the processing of your personal data is based on your consent, you may withdraw your consent at any time. Please note that this does not affect our processing of your personal data prior to the withdrawal of your consent. Further, we may in some cases continue to process your personal data on another legal basis.
8. QUESTIONS AND COMPLAINTS
Further, you have the right to file a complaint with the Danish Data Protection Agency at any time. Please see the contact information below.
Danish Data Protection Agency (Datatilsynet)
Carl Jacobsens Vej 35
2500 Valby, Denmark
Phone: +45 33 19 32 00
Last updated: August 2022
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