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"Mind your own business"

(External Personal Data Policy) for Searchmind ApS regarding the processing of personal data.

Thank you for visiting our website.

It is important to us that we protect and respect your privacy in connection with your choice to use our services.

In addition to being the preferred provider of online marketing, our primary goal is therefore to handle your personal data responsibly and appropriately, so that you can feel confident using our services.

We hold high ethical standards and have established strict internal procedures to ensure that we process your personal data in the best possible way.

In our privacy policy, you can read the terms for the processing of your personal data and the rights you have in connection with the use of our services.

If you have questions or comments about our privacy policy – or if you would simply like to get in touch with us, please feel free to contact us.

What services do we provide?

Our company provides online marketing, with a primary focus on SEO and SEM.

For this purpose, we collect a range of data about you.

We have elaborated on what we collect, why we do it, what we do to protect your data, where we collect the personal data from, and what rights you have in this regard.

What is personal data?

Personal data can be many things.

It can be a name, address, and phone number. It can also be a photo or an IP address.

Personal data is any form of information that can be used to identify a person. It is therefore not only the individual piece of information that determines whether something can be called personal data.

If several pieces of personal data cannot individually identify a person but can do so collectively, they constitute personal data.

What personal data do we collect?

We collect the following personal data:

  1. Name

  2. Phone number

  3. IP address


We collect your personal data in several ways

We collect personal data about you in the following ways:

  • When you use our website

  • When you use our services

  • When you contact our customer service

  • When you sign up for our newsletter

  • When you provide us with personal data directly

  • When you submit information to third parties with whom we have a partnership

You can read below why we do this and on what basis we do it.

We use your personal data in several ways

Here you can read the following:

  • That we collect and use your personal data for specific purposes

  • That we delete your personal data when they are no longer necessary

  • That we continuously check and update your personal data

  • That we disclose your personal data in necessary cases in order to deliver our service

We collect and use your personal data for specific purposes

The purpose of collecting and using your personal data can be divided into the following categories:

In the first category, there is certain personal data that we need to know about you in order to deliver our service to you. This includes, for example, your name, your phone number and your email address, i.e. necessary identification and contact details.

This thus constitutes our lawful 'legal basis for processing'. If we cannot process this personal data, we cannot deliver our service to you.

It may also be the case that we have another legal basis for processing, e.g. that legislation requires us to register and store certain personal data. This includes, for example, personal data used for our compliance with tax legislation and the Danish Bookkeeping Act.

If we wish to use your personal data in a way other than that for which we collected them because it was necessary, we will inform you of this if the 'scope' of the original purpose is exceeded. We do this before we proceed and at the same time inform you of the reason for doing so.

In the second category, there is certain personal data that we would like to know about you so that we can improve our products, services and otherwise optimise your relationship with us, so that we can offer you exactly the services and products you need.

This also includes the collection of personal data about activity on our website, including IP addresses and the placement of cookies on your computer. This may be necessary for our website to function correctly.

None of the personal data in category no. 2 is strictly necessary for us to deliver our service to you. Therefore, you must provide explicit consent before we may collect and use this personal data.

Our legal basis for processing in this regard is therefore your consent.

Your consent is voluntary and if you have given it to us, you can withdraw it at any time by contacting us at the contact details at the bottom of our privacy policy.

We would like to point out that under applicable Danish legislation, we have the right to contact you as a customer with offers regarding our own products that are similar to those you have previously purchased from us. This applies if we have received your email address in connection with your purchase and regardless of whether you have given specific consent to this. If we contact you with such offers, we will clearly and explicitly present you with the option to opt out of similar communications in the future.

If we wish to use your personal data in a way other than that for which we collected it based on your consent, we will always ask for your renewed consent if the 'scope' of the original purpose is exceeded. We do this before we proceed and at the same time inform you of the reason for doing so.

In the third category, there is certain personal data that we retain so that we can safeguard our interests in the future, should the need arise. Our legal basis for processing is then 'legitimate interests', as this is understood under applicable personal data legislation.

This means, among other things, that based on a specific assessment we retain your personal data for a period of time. The time period and the scope of the personal data in this processing are determined based on the criteria set out in the section 'we delete your information when it is no longer necessary'.

We delete your personal data when they are no longer necessary

We make a discretionary assessment to determine when we no longer need your personal data. When we no longer need the personal data for the purpose for which we collected it, we delete it.

We place emphasis on, among other things:

  • What service we have delivered, e.g. whether we have delivered a product or advice as mentioned in the following sections

  • How long ago we had a relationship with you as an employee, customer, partner or otherwise

  • Whether there has been dialogue or correspondence since then

  • Whether we know that you contact us at regular intervals, e.g. every six months to enquire about your online status, as we want to provide you with the best possible service

  • What responsibility we assume towards you, and what liability we risk in relation to our advice

Some personal data we are required to retain for a minimum of 5 years in accordance with legislation, including the Danish Bookkeeping Act. This includes, for example, personal data used for issuing invoices, so that we can settle tax and VAT correctly and document this to the authorities.

As our service encompasses online marketing for which we have a responsibility towards you or others, we retain certain personal data for a minimum of 10 years as a starting point. This includes, among other things, your contact details.

We do this in order to protect our financial interests and legal position if anyone should claim that we have acted negligently. In such cases, we must be able to document what personal data we have received, what agreement was made with the client and what we have done in relation to the client, so that we can safeguard our interests. We 'cleanse' documents of personal data that are not necessary for this purpose.

We continuously check and update your personal data

We continuously check that the personal data we process about you is not incorrect or misleading.

We do this by establishing internal guidelines for how we verify the accuracy of information.

You can use the contact details at the bottom to notify us of any changes.

We disclose personal data in the following cases:

We do not sell, publish or otherwise pass on your personal data to others, unless:

  • it is necessary for us to perform our service to you, or

  • it is necessary for us to comply with legislation, or

  • you have given us consent to do so, or

  • it is necessary to protect a partner or a third party (there are strict rules in legislation regarding the disclosure of personal data on this basis)

  • it is as part of our use of data processors, both within and outside the EU

If it is necessary. We work with selected and trusted partners to deliver our service to you, including business partners.

We pass on the necessary personal data to them so that we can collectively deliver our service to you.

This may include, for example, specific advice. It may also include the Civil Registration System, so that we can update any changes of name or address in databases about our clients.

If you have given consent. We pass on personal data to companies, organisations or individuals outside our company and group if we have your consent.

If required by law, or to protect ourselves, a partner or a third party. Legislation allows in certain cases for us to disclose personal data without your consent. Sometimes we must do so. Other times we may do so.

To the extent permitted by law, we may disclose personal data for the purpose of protecting or enforcing our rights. The same applies to rights belonging to our partners and third parties.

Examples where this may be relevant include, for instance, the prevention of fraud or other criminal matters.

Our use of data processors, both within and outside the EU. We obtain your consent before we pass on your personal data to partners in third countries, unless the parties in question act as our data processors. A third country may be, for example, certain countries in Africa. The USA is not a third country due to the so-called Privacy Shield agreement between the USA and the EU, provided the company in the USA has joined the Privacy Shield agreement.

If we pass on your personal data to third countries, we have ensured that their level of personal data protection meets the requirements we have set for ourselves in this policy and the requirements to which we are subject under legislation.

You have many rights

In this section you can read that you have a number of rights in connection with our processing of your personal data, including that you have:

  • The right to have incorrect personal data corrected

  • The right to access your personal data and receive a copy

  • The right to have your personal data deleted

  • The right to demand restriction

  • The right to object to processing

  • The right to withdraw consent

  • The right to request information about transfers to countries and organisations outside the EU

  • The right to avoid profiling

  • The right to complain about our processing of your personal data

If you would like to know more or exercise your rights, we ask you to contact us using the contact details at the bottom.

The right to have incorrect personal data corrected

We verify that the personal data we process about you is not incorrect or misleading.

You have the right to have your personal data that we hold corrected (rectified).

The right to access your personal data and receive a copy

You have the right at any time to access the personal data we have registered about you and to receive a copy of that personal data.

You can also be informed of the purposes of the processing, how long we retain your personal data, whether we make automated decisions (including profiling), who we disclose the personal data to and where we obtained the personal data from. This does not apply, however, if you are already aware of the personal data.

We would like to point out that the right of access may be limited out of consideration for the protection of other persons' personal data and our trade secrets.

The right to have your personal data deleted

You can at any time request the deletion of the personal data we hold about you. If we no longer have a purpose for retaining the personal data, we will delete it as soon as possible following your request.

The right to demand restriction of processing

You have the right at any time to request that we restrict the processing of your personal data.

The right to object to processing

You have the right at any time to object to our processing of your personal data. This includes the right to object to our use of personal data for marketing purposes. We will respond to your objection as quickly as possible if you raise one.

The right to withdraw consent

You can at any time withdraw the consent(s) you have given us.

The right to request information about transfers to countries and organisations outside the EU

You have the right to be informed whether we transfer personal data to a country outside the EU.

We can inform you that we transfer personal data to IT companies that act as our data processors in the USA.

All of our data processors in the USA have joined the Privacy Shield agreement and have committed to complying with applicable personal data legislation.

We are therefore able to transfer the personal data to these companies.

The right to avoid profiling and automated decision-making

You have the right at any time to avoid us creating profiles of you and your personal data or making automated decisions.

We can inform you that we do not carry out profiling in our company or make automated decisions.

Complaints

We do everything we can to ensure that your personal data is processed securely and that your rights are protected optimally, and we regularly review our procedures and the handling of personal data.

If, contrary to expectations, you believe that we are not handling your enquiry and your rights in accordance with legislation, we ask you to contact us, preferably by email with the word "complaint" in the subject line.

You can write to us at our email address.

We will then forward your enquiry to a senior member of staff in our company, so that any misunderstandings and misconceptions can be resolved.

If you still believe that we are not handling your enquiry and your rights in accordance with legislation, you can complain to the Danish Data Protection Agency via:

Datatilsynet
Borgergade 28
1300 København K
Telephone: 33 19 32 00

www.datatilsynet.dk

Children

Our company is targeted at adults. We do not knowingly collect personal data from or about children.

We are realistic about the fact that, for example, children's use of electronic devices can never guarantee with 100% certainty that we will not receive personal data about children.

We have endeavoured to set up our systems as best as possible so that we cannot receive personal data from children, and we will immediately delete any personal data if we become aware that we have inadvertently received personal data about children.

If you are a parent or guardian and believe that your child has provided personal data to us, whether knowingly or unknowingly, we ask you to contact us as soon as possible using our contact details at the bottom.

How do we store your personal data?

We are obliged to protect your personal data. Both because it follows from legislation, but also because our own internal ethical rules require us to take good care of your personal data.

We use relevant and appropriate technical and organisational security measures to ensure that no unauthorised access is created to the personal data we store. The purpose of this is to ensure that the personal data is not used, destroyed, altered, published or otherwise misused.

In this section you can read that:

  • We have internal rules on information security in connection with personal data

  • We have implemented IT-technical measures

  • User behaviour is important in ensuring a sufficiently high level of security

  • We notify affected individuals if a risk arises or an actual data breach occurs

We have internal rules on information security, which include guidelines and procedures

This includes, among other things, that personal data is only accessible to the employee(s) who need it.

Included in our information security rules is also that we continuously train our employees in the correct handling of personal data and verify that the rules are being followed by employees.

From an IT-technical perspective, we have implemented the following measures, among others:

  • Installed antivirus on all IT systems that process personal data

  • Installed password protection on computers with regular requirements for renewal

  • Continuous backup of all IT systems that process personal data

  • Restriction of access to personal data so that only employees who need it have access, and only to the extent necessary

  • Monitoring of employees' actual access to personal data through logging and supervision

  • Investigation of whether the personal data we use can be used in anonymised or pseudonymised form. We will do this if it does not have a negative impact on our service and obligations to you

  • Entered into data processing agreements with suppliers who process personal data on our behalf, to ensure that processing takes place in accordance with legislation and our own rules and ethical standards

Risk and disclaimer

The greatest risk of misuse of personal data is caused by human behaviour.

It is both up to the individual to take good care of their own personal data (including never disclosing passwords to others), just as it is up to our company to account for human involvement.

Although we have taken the above-mentioned steps to limit risks in the processing of personal data, this cannot constitute a 100% guarantee that unintended incidents will not occur.

We therefore disclaim any loss resulting from unintended incidents related to our use and processing of your personal data to the extent that we are permitted to do so under applicable legislation.

We cannot therefore be held liable for any loss of any kind arising in connection with the use of our company, our products and services, our website, systems, apps and other software to the extent that we are permitted to do so under applicable legislation.

We recommend that you also take steps yourself to secure your personal data.

You can do this by, among other things, closing your browser after use, by logging out of all accounts after use, by installing antivirus, anti-malware and other software that can improve the security of your computer.

We recommend that you continuously update software, the apps you use, your computer and mobile devices, and never disclose your password to others.

Notifications

As mentioned, we have taken a wide range of steps to ensure the processing of your personal data.

Should our IT systems and other security measures nevertheless be compromised, we will notify you without undue delay if the compromise entails a high risk to your rights and freedoms.

Links to other service providers

Our website may contain links to other websites that do not belong to our company.

We are not responsible for the content of these websites and our personal data policy does not apply to these companies' websites.

Contact details

Our company Searchmind ApS is the data controller, and ensures that your personal data is processed in accordance with legislation:

Searchmind ApS
Address: Klostergade 28, 3. sal
CVR: 3734 0588
Phone: 3012 4272
Email: brian@searchmind.dk
Website: www.searchmind.dk

Updates to this personal data policy

We update our personal data policy when we assess that there is a need to do so. This may be the case, for example, when we offer new services and products.

When we make changes to the personal data policy, we will mention them below.