Data protection policy for Selected Car Group A/S

Version 2.7

Date: 9 March 2023

 

  1. Introduction

It is important to us at Selected Car Group that you as an individual feel comfortable with our processing of the personal data that comes into our possession when you shop or are otherwise in contact with us. This Privacy Policy is in addition to, but does not replace, any other policies or terms and conditions established between us.

 

We take data protection very seriously and if you have any questions about this policy or if you need answers to a specific question or topic in this regard, please feel free to contact us.

 

  1. We are the data controller for your personal data

Selected Car Group (SCG) is responsible for protecting, processing and storing the personal data that you send to us or that is collected by us. We are responsible for your personal data in accordance with the Data Protection Act and the EU Regulation on Data Protection (“Data Protection Regulation” or “GDPR”).

 

Our information is:

 

Selected Car Group A/S

CVR 41723750

Turbinevej 10

5500 Middelfart

 

Email: [email protected]

 

scgroup.dk

scleasing.dk

scinvestment.com

dcworkshop.dk

 

  1. We process and store your data

The data we obtain and collect about you is stored within the European Economic Area (“EEA”), but may also be transferred to and processed in a country outside the EEA. Any such transfer of your personal data will be in accordance with the General Data Protection Regulation (GDPR).

 

SCG only transfers personal data to third countries (outside the EEA) if certain conditions are met. A transfer can, for example, only take place if the EU Commission has decided that the third country in question ensures a sufficient level of protection or has given the necessary guarantees, e.g. by entering into an agreement that includes the EU Standard Contractual Clauses with the recipient of the personal data.

 

We generally store your personal data for 5 years after the financial year in which your agreement has expired. In some cases, there is no right to retain for 5 years, in which case we will not store your information longer than is necessary in relation to the purposes that are the reason for processing. If your agreement does not come to fruition, we will not retain your information, unless there is express authority in other legislation.

 

  1. We take good care of your data

We protect your personal data and have adopted procedures and internal rules on information security, which contain instructions and measures that protect your personal data against unauthorized disclosure and against unauthorized persons gaining access to or knowledge of your data. To avoid data loss, we regularly back up our data sets. We also protect the confidentiality and authenticity of your data using encryption. Your information is stored via technologically secure cloud-based solutions. There are secure firewalls and passwords for all devices, and to the extent that the information is stored physically, it is done in locked archive rooms.

 

In the event of a security breach that results in a high risk to you of ID theft, financial loss or other significant inconvenience, we will notify you of the security breach as soon as possible.

 

When the purpose requires it, your personal data may be shared internally within SCG and with the subsidiaries that currently includes Selected Car Leasing A/S, Selected Car Investment Management ApS, Selected Car Investment ApS DC Workshop ApS. When the purpose requires it, your information can also be passed on to SCG’s owners Selfinvest ApS and LLG A/S. We do not pass on your information to other parts of the group – and of course never to external third parties – unless this is done in compliance with the rules in the Data Protection Regulation and the Data Protection Act.

 

Within the framework of the data protection rules, SCG can also pass on or entrust the information processed about you to authorities and business partners to the extent that this is necessary and legitimate in connection with the conclusion and administration of our agreement.

 

To the extent that the information is processed by public authorities, business partners or data processors on behalf of SCG, the information is encrypted and confidential, and statutory written confidentiality agreements and data processing agreements are in place.

 

We neither sell nor otherwise pass on your data to external third parties unless expressly authorized by law.

 

  1. Processing of your personal data

SCG collects and processes your personal data. The data we collect and process in a given situation varies, but the personal data may include the following:

 

Your personal information, including name, address, phone number, and email address.

Personal information sent to us in letters, chats, SMS and/or e-mails in which we have a legitimate interest to maintain our relationship with you.

Registration information in connection with customer events.

Your clicking behaviour, which is collected via cookies in connection with your use of our websites, cf. section 6.1.

Information you have provided to us in connection with signing up for newsletters, cf. section 6.2.

Information you have provided to us in connection with interaction on social media, cf. section 6.3.

Information you have provided to us in connection with your notification through Trustpilot, cf. section 6.4.

Pictures and/or videos from events and customer events.

Video recordings from our video surveillance of Selected Car Group A/S and Selected Car Group’s subsidiaries’ premises and access roads, facades and outdoor areas, including lattice gates and parking areas.

If you obtain offers via our leasing companies, the leasing company processes more information, including financial information and social security number. The processing is carried out on the basis of necessity, including legal requirements. The leasing company informs you separately about the processing of your personal data.

The information can be combined, and together constitute a treatment.

 

  1. Where does your personal data come from?

In many cases, personal information is provided by you yourself, but can also be collected via various technologies, channels and platforms, for example through public registers.

 

The information can be combined, and together constitute a treatment.

 

When you submit personal data to us and/or when we collect data about you, we inform you about which data we process about you and for what purpose we carry out the processing.

 

The information will either be provided via reference to the relevant privacy policy or in the form of separate information for you, including possibly with a request for your consent to the processing.

 

6.1 Especially about cookies

The information collected via cookies from our website scgroup.dk is processed in accordance with our cookie policy.

 

6.2 Especially about newsletters

By signing up for the newsletter, you accept that your e-mail address and name are registered, just as you accept that we analyze your behavior on the basis of our newsletter. We use information about your email address to send out newsletters. We use your car brand preference ticks to adapt the newsletter to you and for statistical analysis of which car brands our newsletter recipients are interested in.

 

Our processing takes place on the basis of your consent, cf. Article 6, subsection of the Data Protection Regulation. 1, letter a You can withdraw your consent at any time by clicking on the unsubscribe link at the bottom of the newsletter. If you withdraw your consent, we will delete your e-mail address and any other information you may have given us in this connection from our mailing list, and you will no longer receive newsletters from us. We use an external IT service for sending newsletters. The service registers how many and who opens the newsletter, when the newsletter is opened (date and time), whether and how many times the newsletter is forwarded, which links in the newsletter are clicked on, and whether it is done from a mobile device, a browser or an operating system . In other words, IP addresses are collected. Based on the collected information, a report is created through another of our IT suppliers. In the report, we can see how many and who open the newsletter, when the newsletter is opened (date and time), whether the newsletter is shared, which links are clicked on in the newsletter and on our own websites, whether it is done from a mobile device, a browser or an operating system. We use this information to analyze which articles the news readers click on, and organize future newsletters and the structure of the website based on this. The reports and the underlying data are deleted after 18 months. The processing takes place on the basis of our legitimate interest in being able to organize future newsletters based on the information that is collected, cf. Article 6, subsection of the Data Protection Regulation. 1, letter f (the balancing of interests rule).

 

6.3 Especially about social media

When you visit the SCG companies’ profiles on social media, e.g. Facebook/Instagram, Youtube/Google, Vimeo, Sproutvideo and/or LinkedIn, the SCG companies can process the information you have made available via settings on our pages on the said social media media, including your reactions to our posts, your sharing of our posts as well as your possible comments on our posts. The purpose of SCG’s processing of your personal data is marketing, to give you the opportunity to sign up for our newsletters, to answer inquiries, to let you participate in any competitions and to contact you if you win. If the mentioned social media use your personal data collected on one or more SCG profiles for their own use, e.g. to improve their advertising system, they process your personal data as described in their privacy policies, which you can find here: Facebook/Instagram, Google/Youtube , https://vimeo.com/privacy, https://sproutvideo.com/privacy, LinkedIn.

 

The legal basis for SCG’s processing is our legitimate interest in marketing, to answer your inquiry(s), and/or to let you participate in a competition and to contact you if you win, cf. Art. of the Data Protection Regulation. 6 pieces. 1, letter f, as well as giving you the opportunity to sign up for the newsletter if you give your consent, cf. Data Protection Regulation art. 6 pieces. 1, letter a.

 

6.4 In particular about Trustpilot

SCG cooperates with Trustpilot, and can ask them to invite you to submit a review on Trustpilot’s website. In this connection, we leave your name and email to Trustpilot and ask them to collect reviews.

 

To use Trustpilot, you must have a Trustpilot account and as a user of Trustpilot you will be subject to their privacy policy. In this connection, we refer to Trustpilot’s privacy policy (here).

 

  1. Purpose

We process your personal data for the following purposes:

 

Agreements concluded with you

Events and customer events

Video surveillance is carried out and recorded for insurance reasons, to prevent criminal acts and for investigative purposes. The monitoring takes place with respect for the rules in the TV Monitoring Act

Compliance with the Accounting Act

For marketing purposes, including interaction on social media

Sending newsletters if you have given us permission

Compliance with regulatory obligations

The legal basis for our processing of your personal data follows from the legitimate interests pursued with the processing, is based on the transaction(s) entered into between us and/or the interests you have disclosed to us, which may form the basis of a future transaction.

 

Our processing of your personal data depends on the agreement or interaction you have with us. This will most often be on the basis of the contract rule in the Data Protection Regulation art. 6 pieces. 1 letter b or the legal rule in the data protection regulation art. 6 pieces. 1, letter c, but it can also be done on the basis of the consent rule in the Data Protection Regulation art. 6 pieces. 1, letter a and/or the balancing of interests rule Data Protection Regulation art 6, subsection 1, letter f.

 

  1. Principles

The processing of personal data in SCG is in accordance with the following principles:

 

Our processing of personal data always takes place in a legal, reasonable and transparent manner in relation to the registered person.

We only collect personal data for specified, explicit and legitimate purposes.

We only process sufficient and relevant personal data to the extent that it is necessary in relation to the purposes for which it is processed.

We ensure that the personal data is accurate and up-to-date. Inaccurate personal data will be deleted or corrected without undue delay.

We delete personal data that is no longer necessary for the purposes for which the data was processed.

We do not store your personal data longer than necessary for the purpose for which the information was collected.

We process personal data in a way that ensures adequate protection of it.

 

  1. Your rights

According to the Data Protection Regulation, you have a number of rights in relation to our processing of information about you. If you want to exercise your rights, please contact us.

 

Your rights are:

 

Right to see information (right of access). You have the right to gain insight into the information that we process about you, as well as a range of additional information.

Right to rectification (rectification). You have the right to have incorrect information about yourself corrected.

Right to erasure. In special cases, you have the right to have information about you deleted before the time of our normal general deletion occurs.

Right to restriction of processing. In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to have the processing restricted, we may in future only process the information – apart from storage – with your consent, or for the purpose of establishing, asserting or defending legal claims, or to protect a person or important public interests.

Right to object. In certain cases, you have the right to object to our processing of your personal data. You can also object to the processing of your information for direct marketing.

Right not to be subject to automated decisions. SCG does not use automatic decisions.

Right to transmit information (data portability). In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have this personal data transferred from one data controller to another without hindrance.

You can read more about your rights in the Data Protection Authority’s guidance on the rights of data subjects, which you can find at www.datatilsynet.dk.

 

  1. Complaint to the Data Protection Authority

You have the right to lodge a complaint with the Danish Data Protection Authority if you are dissatisfied with the way we process your personal data. You will find information about access to appeal at www.datatilsynet.dk. You can also contact them by letter or email. The Norwegian Data Protection Authority’s contact details are:

 

The Norwegian Data Protection Authority

Carl Jakobsensvej 35

2500 Valby

e-mail: [email protected]