Updated 16 September 2022
1. We are the data controller
Kaufmann is the data controller in the processing of the personal data you have left behind or given us.
Our legal information is as follows:
Axel Kaufmann ApS
Maren Smeds Gyde 9
8000 Aarhus C
CVR: 19 09 81 92
E-mail: [email protected]
2. The purpose of and the legal basis of the processing of your personal data
In connection to our services being delivered, we can process the following data concerning you:
2.1 Users of the Kaufmann homepage
2.2 Customers of www.kaufmann-store.com
2.2.1 Which of your personal data do we process?
Kaufmann processes, depending on the circumstances, your identity and contact information, purchase history and card information in connection to online orders. The personal data are categorized as general information and covered by Article 6 in the General Data Protection Regulation.
2.2.2 What is the purpose of the processing of your personal data?
The processing is carried out for the purposes of confirming orders, delivering goods, collecting payment, providing customer service and, where applicable, crediting. We also use the information about the digital behaviour of each online customer on our website to obtain general statistical knowledge about the use of the digital platforms by online customers.
Finally, we use the information about each online customer's purchases to obtain general statistical knowledge about online customer behaviour for the purpose of developing and improving our stores, product range and offers.
Finally, Kaufmann is using the information about the single online customer’s purchase(s) to create general statistical knowledge about the behavior of online customers with the purpose of developing and improve Kaufmann’s stores, assortment and offers.
2.2.3 On what legal basis do we process your personal data?
Processing in the context of an online transaction is generally based on Article 6(1)(b) of the GDPR, whereas processing for static purposes is based on Article 6(1)(f). Our legitimate interests consist in optimizing our stores, product range, offers, and digital platforms and services. The interests of the data subject's privacy and freedoms are overridden by our legitimate interests, as it must be considered a reasonable expectation on the part of customers that we carry out such statistical processing.
2.2.4 When is your personal data deleted?Personal data concerning customers in Kaufmann’s online store are deleted three years after the last order is completed or annulled. Information that falls under the obligation to maintain accounting records are however deleted only five years after the end of the accounting year, in accordance with the General Data Protection Regulation, Article 6(1)(c), and § 10 of the Danish Bookkeeping Act.
2.3 Members of Kaufmann’s newsletter service, customers club and account
2.3.1 Which of your personal data do we process?If you sign up for our newsletter, customers club, or if you participate in one of our competitions, in connection to that we will process your personal data with the purpose of sending you newsletters and invitations, storing receipts from your purchases, and other data concerning our services and business.
Depending on the circumstances, we process your profile data, including but not limited to your name, e-mail address, date of birth, home store, and phone number. The personal data are categorized as general information covered by the General Data Protection Regulation, Article 6.
2.3.2 What is the purpose of the processing of your personal data?
The processing is carried out for the main purpose of maintaining and managing a membership programme. As part of the membership programme, we also process personal data for the purpose of segmenting each customer's shopping profile and behaviour in order to target offers and marketing. Finally, we use the data to maintain and develop our stores, product range, and digital platforms and services.
2.3.3 On what legal basis do we process your personal data?
The legal basis for the processing concerning memberships, newsletters, or participation in competitions is your consent, cf. the General Data Protection Regulation, Article 6(1)(a). The consent can always be withdrawn.
The processing of personal data for statistical purposes is based on the General Data Protection Regulation, Article 6(1)(f). Our legitimate interest consists of optimizing our physical stores, goods selection, offers, and digital platforms and services. Our legitimate interest takes priority over a registered person’s privacy and freedom, as it must be considered a reasonable expectation among the members that we does perform such statistical processing.
2.3.4 When is your personal data deleted?
The data are stored for as long as you are a member of our customers club. The data are automatically deleted after two years inactivity (during which you have not opened our newsletter).
You can always withdraw your consent and have your data deleted by contacting us at [email protected].
2.4 Persons who contact Kaufmann’s customer service
2.4.1 Which of your personal data do we process?
Kaufmann processes personal data that Kaufmann receives by phone or in written requests from a customer, a member, or another person, including but not limited to name, email address, and phone number.
2.4.2 What is the purpose of the processing of your personal data?
The processing of telephoned or written requests is with the purpose to manage, and if possible, solve, the issues the requests concern, as part of Kaufmann’s regular customer service.
2.4.3 On what legal basis do we process your personal data?
The legal basis for the processing is Article 6(1)(f) of the Data Protection Regulation.
Our legitimate interests are to manage, maintain, follow up and, as far as possible, resolve the matters to which the request relates. Our legitimate interests prevail over the data subject's privacy and freedoms, as it must be considered a reasonable expectation on the part of the persons making the enquiry that we carry out the processing operations mentioned.
2.4.4 When is your personal data deleted?
We keep telephone records and written enquiries until all dealings between us and you have been completed. The default is that the information is deleted within 2 years after the enquiry has been handled.
2.5 Video surveillance
2.5.1 Which of your personal data do we process?
Kaufmann processes visual material from the video surveillance of Kaufmann’s facilities, including stores, warehouses, and offices. The absolute majority of the personal data are categorized as general information covered by Article 6 of the General Data Protection Regulation.
2.5.2 What is the purpose of the processing of your personal data?
The purpose of the processing is to establish a safe and secure environment for Kaufmann’s employees, suppliers, and customers, to prevent and solve criminal activities, to protect Kaufmann’s assets and values, and offer documentation for insurance purposes, including but not limited to documentation in connection to accidents and damages, and to prevent and solve unauthorized intrusions on Kaufmann’s properties.
2.5.3 On what legal basis do we process your personal data?
The legal basis for the processing is as a standard base point the General Data Protection Regulation, Article 6(1)(f). Kaufmann’s legitimate interest in the processing is to fulfill the purposes mentioned above. Kaufmann’s legitimate interest takes priority over a registered person’s privacy and freedom, as it must be considered a reasonable expectation among the persons that find themselves on Kaufmann’s facilities.
If the visual material from the video surveillance shows anything punishable by law (or contains sensitive information), the legal basis for the processing is the Danish Data Protection Act § 8(3-5), respectively the General Data Protection Regulation, Article 9(2)(f).
2.5.4 When is your personal data deleted?
Video surveillance at Kaufmann is subject to an independent internal policy. From this it is apparent that, among other things, all recordings are automatically deleted at the latest 30 days after being recorded, unless the recordings are to be used as documentation in connection to concrete issues regarding potentially criminal offenses.
We use external partners and suppliers for, for example, operation, development, hosting, IT systems, etc., and we therefore disclose your personal data to them. Our partners and suppliers are data processors for us, and they only process personal data on our behalf and in accordance with our instructions.
We may also disclose your information to external third parties if we are instructed to do so or it is part of the service we provide to you. This may be, for example, to the police or the tax authorities.
Where possible for the purposes of the specific service, personal data is provided in pseudonymised form. This means that the personal data can no longer be attributed to a specific person without the use of additional information known only to Kaufmann.
Apart from the cases mentioned, your personal data will not be disclosed to a third party without your permission, with the exception of disclosure if we sell (parts of) the company.
4. Third countries
We may transfer personal data to data processors established outside the EU/EEA (third countries), including SalesForce, which provides marketing services that we use. SalesForce processes data for us and is based in the United States.
The data processor agreement has been concluded on the basis of the EU standard contractual clauses as set out in Article 46(2)(c) of the Data Protection Regulation. The necessary and adequate safeguards required by the Data Protection Regulation are therefore met and the level of protection of the processing of personal data meets the same requirements as any of our data processors within the EU.
You can read more about the guarantees in the EU Standard Model Clauses.
Kaufmann maintains high standards of security, also when it comes to protecting your personal data. Therefor, we have a series of internal procedures and policies to ensure that we live up to our high security standards, and by that fulfill the demand placed by the General Data Protection Regulation regarding implementing suitable technical and organizational security measures. By that, we are doing our best to secure the quality and integrity of your personal data.
6. Storing and deleting personal data
We will delete your personal data when we no longer need to process it to fulfil one or more of the purposes set out above. In assessing how long we need to keep your personal data, we will give decisive weight to the purpose(s) for which the personal data in question is processed.
However, specific legal provisions, for example the Accounting Act and the Money Laundering Act, may give us the obligation and the right to keep the personal data for a longer period of time. Personal data may also be kept for longer if it is anonymised.
7. Your rights
In accordance with the General Data Protection Regulation, you have a series of rights with regards to our processing of your personal data.
7.1 Right of access by the data subject
You have the right to access the personal data we process concerning you and a series of additional data.
7.2 The right to object
In some situations, you have the right to object to our otherwise legal processing of your personal data. You can also object to the processing of your personal data for direct marketing.
7.3 The right to rectification
You have the right to have incorrect data concerning yourself rectified.
7.4 The right to restriction of processing
In some situations, you have the right to restrict the otherwise legal processing of your personal data. If you have the right to restrict the processing, we will in the future only be allowed to process data (apart from storage) with your consent, or if legal requirements can be established, invoked, or defended.
7.5 The right to erasure
In exceptional cases, you have the right to have information about you deleted before the time of our general deletion period. If you request it (and you are entitled to erasure), we will delete the personal data we have recorded about you without undue delay.
For example, you are not entitled to erasure if we are obliged to carry out further processing or if the processing is necessary for the fulfillment of a contract with you.
7.6 The right to data portability
In some circumstances you have the right to data portability. Data portability means that you can send us a request for a copy of your personal data in a structured, commonly used, and machine-readable format, and request that we transmit those data to another data controller.
You can read more about your rights in the Danish Data Protection Agency’s guide to the rights of the registered, which you can find at www.datatilsynet.dk.
7.7 If you wish to invoke your rights
If you wish to exercise your rights as described above, please feel free to contact us at any time at [email protected] We ask that when making an enquiry about your rights, you provide us with sufficient information to enable us to process your enquiry, including your full name and email address, so that we can identify you and respond to your request. We will respond to your request as soon as possible.
8. The right to withdraw consent
If we process your personal data on the basis of your consent, you can always withdraw your consent. You can do this by contacting us at [email protected].
If you withdraw your consent, we will stop processing your personal data. Withdrawal of your consent will not affect the lawfulness of the processing we have carried out on the basis of your previously given consent. Therefore, if you withdraw your consent, it will only take effect from that moment.
9. Links to other websites
Our website may contain links to other websites or to integrated websites. We are not responsible for the content of other companies' websites or for their personal information collection practices. Therefore, when you visit other websites, you are encouraged to read the owners' policies.
11. Appeal procedure
If you are unhappy with the manner in which, or with the purposes for which, we process your personal data, you are always welcome to contact us at [email protected].
You also have the right to file a complaint with the Danish Data Protection Agency:
Carl Jacobsens Vej 35
Phone 0045 3319 3200
E-mail: [email protected]