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PRIVACY POLICY

General

This Privacy Policy applies to all collected and processed personal data that you have provided to us or we have collected as a part of delivering our services/products. “Personal data” means any information relating to an identified or identifiable natural person.

Identity of the data controller

If there are any questions regarding this Privacy Policy, you may contact us using the information below.

Kontolink ApS
Copenhagen Fintech
Applebys Plads 7,
1411 København K
CVR: 39638827

We are processing your personal data in accordance to the General Data Protection Regulation (GDPR) and any national regulation applicable to us.

Purpose of processing

Non-sensitive personal data
We collect the following non-sensitive personal data about you when you sign up as a customer/user

• NAME
• E-MAIL
• COUNTRY
• BANK ACCOUNT DETAILS
• WORKPHONE

We process non-sensitive personal data on the basis of Article 6 in the GDPR, more specifically, our legal basis for collecting and processing personal data is for each service outlined below:

The processing of your data is based on Consent – processing is based on an obtained consent from you.

If the processing is based on your consent, you may at any time withdraw your consent by contacting us.

Use of personal data

We only process your personal data as stated in this privacy policy and we do not use your personal data for any other purpose than explicitly described above or communicated directly to you elsewhere.

We process your personal data in a lawful, fair and transparent manner. The data we collect is solely used for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

All use of your personal data is relevant and limited to what is necessary in relation to the purposes for which they are processed.

Security

When we store and process personal data that we have received from you, we always take every step possible to store it in a secure manner. However, we cannot guarantee that your data is 100% secure as we cannot guarantee that the data will not be accessed or otherwise misused as a result of an unlawful act or similar. We do take all necessary precautions to keep your data safe. When you give us access to- or transfer personal data to us – you do so at your own risk.

To further increase the level of security, we have “deletion policies” in place. Personal data is kept for a maximum period of 24 months from after the purpose of the processing has ended.

Access to your information

Right to access
GDPR Article 15: You have the right to obtain a confirmation from us as to whether or not personal data concerning you is being processed, including information on the purpose-, categories-, recipients-, and time of storage of the processing.

Right to rectification
GDPR Article 16: If you figure out, that the data that is being processed about you is inaccurate or incomplete, you have the right to get that data rectified. We will communicate any rectification or erasure of personal data to any recipient to whom the personal data has been originally disclosed, unless it proves impossible according to Article 19.

Right to erasure and restriction of processing
GDPR Article 17: You also have the right to get your personal data erased, if the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed. Please see Article 17 for the full list of reasons for your right to erasure.

GDPR Article 18: You have the right to restrict the processing of your personal data if it is (i) inaccurate; (ii) unlawful; (iii) the purpose of the processing has changed; or (iv) you have objected to the processing according to Article 21.

Right to data portability
GDPR Article 20: You have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format. You can also request that we transmit your data to another party.

Right to object
GDPR Article 21: You have the right to object to the processing of your personal data if it is being used for profiling or direct marketing purposes.

Sub-processors

We use data processors to be able to deliver our services and run our business. We have listed the various categories of handling, its purposes and the supplier in the below list.

mLab.com, USA – Database Hosting
Google.com, Irland – Hosting, e-mail services
Nordic API, Denmark – bank transaction supplier.

Contact information, requests & complaints

If you want to exercise any of your above rights, please contact our data protection responsible:

Kontolink ApS
Copenhagen Fintech
Applebys Plads 7,
1411 København K
CVR: 39638827
Attn: Kim Agger

If you find that your personal data has been processed in a way that does not meet the requirements of the GDPR and if you want to file a complaint, you have a specific right to lodge a complaint with the relevant supervisory authority.

Last updated on 14-09-2018

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