Privacy Policy - Guldmann Care-Lift Solutions ULC

Guldmann Care-Lift Solutions ULC (‘Guldmann’, ‘we’, ‘us’ or ‘our’) has a strong focus on confidentiality and data security. This Privacy Policy applies to our processing of personal data, lays down guidelines for how Guldmann processes your personal data and gives you the information you are entitled to receive in accordance with current data protection legislation. Please read this Privacy Policy before you provide any personal data to Guldmann.

Data controller and contact information
The data controller is:

Guldmann Care-Lift Solutions ULC
5716 Coopers Ave, Unit 9
L4Z 2E8 Mississauga, ON
Canada
Phone: +1 877 339 7779
Email: info@guldmann.net

1. Website www.guldmann.com/ca
This section describes the policy that regulates Guldmann’s processing of personal data collected via the website www.guldmann.com/ca.

1.1 Cookies
Guldmann uses cookies on the website www.guldmann.com/ca, in which connection we process your personal data. Guldmann may collect the following personal data about you when you visit our website:
- IP address
- MAC address
- Browsing history
- Information about your use of our website, including click behaviour

We use cookies to collect the above-mentioned personal data. You can read more about the use of cookies in our cookie policy, which is available via this link: www.guldmann.com/ca/cookie-policy/

Your personal data may be processed for the following purposes:
- General marketing purposes
- Product and service development
- Statistics and analysis

Guldmann processes your personal data subject to the following basis:
- Legitimate interest: Part of our processing of your personal data is based on our legitimate interest in making statistics, analyses, providing support as well as improving and developing our products and services (point (f) of Article 6(1) of the General Data Protection Regulation).

- Consent: Guldmann will only use your personal data for direct marketing purposes subject to your prior and explicit consent (point (a) of Article 6(1) of the General Data Protection Regulation).

Cookies are deleted in accordance with our cookie policy, which you can see here. However, the data can be stored for longer in an anonymised format.

1.2 Newsletters and seminar information
Guldmann collects, processes, and stores your personal data for marketing purposes when you sign up for seminar information or newsletters on www.guldmann.com/ca.

Guldmann may collect, process, and store the following types of personal data about you:
- Name, title, organisational affiliation and email address
- Your consent
- Your interests
- Your click behaviour in relation to the issued material

Your personal data may be processed for the following purposes:
- Marketing, including issuing of invitations for future seminars
- Analysis and statistics

Guldmann processes your personal data based on one or more of the following:
- Consent: Guldmann will only use your personal data for direct marketing purposes, including issuing seminar information and newsletters, subject to your prior and explicit consent (point (a) of Article 6(1) of the General Data Protection Regulation).

- Legitimate interest: The processing of your personal data for analysis and statistics purposes is based on our legitimate interest in being able to improve and develop our services (point (f) of Article 6(1) of the General Data Protection Regulation).

Your personal data will be stored as long as your consent to receiving seminar information or newsletters is active.

You can withdraw your consent at any time by clicking on the unsubscribe link at the bottom of each email or by contacting us as described below. However, withdrawal of your consent will not affect the lawfulness of the processing already carried out prior to the withdrawal.

Documentation of your marketing consent will be stored for two years from the withdrawal of your consent to receive direct marketing material. The storage period is determined based on Guldmann's legitimate interest in being able to document that direct marketing has been carried out in compliance with current legislation (point (f) of Article 6(1) of the General Data Protection Regulation).

The data can also be stored for longer in an anonymised format.

1.3 The contact form on the website
Guldmann will collect and process your personal data when you use the contact forms on www.guldmann.com/ca. Guldmann collects, processes, and stores the following types of personal data about you:
- Name, title, organisational affiliation, email address, phone number
- The reason for your inquiry
- Date of your inquiry
- EAN no and any order number if you order service or installation
- Other information you provide in connection with your inquiry

Your personal data will be processed for the following purposes:
- Handling of your inquiry via the contact form
- General communication
- Statistics and analysis

Guldmann processes your personal data subject to the following basis:
- Legitimate interest: We may process your personal information based on our legitimate interest in handling your inquiry, communicating with you, and developing our products and services (point (f) of Article 6(1) of the General Data Protection Regulation).

We may disclose your personal data to external suppliers that, subject to agreement with us, provide the service or installation you order. Disclosure is subject to our legitimate interest in being able to deliver the service you request (point (f) of Article 6(1) of the General Data Protection Regulation).

Your personal data will be stored for one year and will then be erased. However, the data can be stored for longer in an anonymised format.

If you are a customer or employee with one of our customers, suppliers, or other partners, please refer to section 2 below.

2. Customers (consumers) and contact persons at customers, suppliers, and other partners (B2B)
This section describes the policy for how Guldmann processes personal data about the customer (consumers), owners of sole proprietorships or contact persons at suppliers and other partners collaborating with Guldmann (B2B).

2.1 Collection of personal data
Guldmann may collect, process, and store your personal data in the following cases:
- When you, your sole proprietorship or the company you work for enters into an agreement with Guldmann
- When you have expressed interest in Guldmann’s products and services, e.g. by giving Guldmann your business card
- When you collaborate and communicate with Guldmann

2.2 Types of personal data
Guldmann may collect, process and store the following types of personal data about you:
- Name, email address, phone number and similar identification data
- Individual information e.g. preferred language
- Address and delivery address (if you are a private individual or a sole proprietorship)
- Organisational information about the name and address of the company, title, area of expertise, primary place and country of work
- Contractual information such as orders, invoices, contracts and other agreements between your company (or your employer) and Guldmann that may include your contact information
- Financial information such as payment terms, bank information and credit scores

We can receive such information directly from you (mainly via emails and other correspondence with you) or from third parties such as your employer.

2.3 Purposes of processing
Your personal data may be processed for the following purposes:
- General planning, performance and administration of collaboration, including contracts
- Administration, such as processing of payments, evaluation of credit scores, accounting, auditing and provision of support
- Newsletters and other marketing communication
- Processing of inquiries from you
- General communication
- Product and service development
- Statistics and analysis
- Compliance with current legislation and regulations, e.g. fulfilment of our obligations to prevent illegal activities
- Handling of conflicts

2.4 Basis of processing
Guldmann primarily processes your personal data based on one or more of the following:
- Contractual obligations: In some cases, the processing of your personal data is necessary for the performance of a contract with you or your sole proprietorship (point (b) of Article 6(1) of the General Data Protection Regulation).

- Legitimate interest: We may process your personal data based on our legitimate interest in e.g. being able to communicate with you as part of our collaboration, manage daily operations in keeping with legal and fair business methods, including planning, performance and administration of the collaboration or our legitimate interest in e.g. undertaking credit scoring, statistics, analyses, marketing activities (where no consent is required), provide support as well as improvement and development of our products and services. Processing may also be necessary for terms of our legitimate interest in preventing fraud or determining, defending or pursuing claims (point (f) of Article 6(1) of the General Data Protection Regulation).

- Legal obligation: In some cases, it will be necessary to process your personal data in order to comply with legal obligations, such as our obligation to prevent illegal activities (point (c) of Article 6(1) of the General Data Protection Regulation).

- Consent: In special cases and only where no other processing basis is applicable, Guldmann may make a separate request for your consent to process your personal data (point (a) of Article 6(1) of the General Data Protection Regulation). Guldmann will for instance only use your personal data to send you information about our products, newsletters and other marketing material via email subject to your prior and explicit consent, unless legislation allows us to contact you without your consent.

2.5 Storage period
Customers (consumers)
Generally, we will store your personal data for 2 years after our last contact.

Personal data included in bookkeeping documents will be stored in accordance with the requirements provided by national legislation. Data will therefore be stored in compliance with current legislation (point (c) of Article 6(1) of the General Data Protection Regulation).

Personal data stated on order confirmations and invoices will be stored for 10 years after your purchase. The storage period has been determined based on the period of limitation stipulated in the Danish Product Liability Act and storage is therefore done to maintain Guldmann’s legitimate interest in determining, defending or pursuing claims (point (f) of Article 6(1) of the General Data Protection Regulation).

Contact persons at customers, suppliers and other partners (B2B)
Your contact information will be stored for 4 years after our last contact.

Personal data stated on order confirmations and invoices will be stored for 10 years after the time when Guldmann stops selling the product purchased. The storage period has been determined based on the period of limitation stipulated in the Medical Devices Regulation, and storage is undertaken to comply with current legislation (point (c) of Article 6(1) of the General Data Protection Regulation).

3. End users
This section describes the policy that regulates Guldmann's processing of personal data about end-users of equipment produced by Guldmann.

3.1 Collection of personal data
Guldmann may collect, process and store your personal data in the following cases:
- When we receive reports about incidents involving equipment produced by Guldmann
- When we install or provide service on products produced by Guldmann

We may receive the information from you or from our partners that deliver our equipment to you.

3.2 Types of personal data
Guldmann may collect, process and store the following types of personal data about you:
- Contact information such as name, address and phone number
- The Guldmann products you use
- Health details, in special cases

3.3 Purposes of processing
Your personal data may be processed for the following purposes:
- Handling of cases arising out of incidents involving equipment produced by Guldmann
- Delivery of the service requested by you or by our partners that have delivered equipment produced by Guldmann to you.

3.4 Basis of processing
Guldmann primarily processes your personal data based on one or more of the following:

- Legitimate interest: We may process your personal data based on our legitimate interest in being able to deliver a service (installation or service) to you based on a request from you or the partners that have delivered a product produced by Guldmann to you. In this connection, we have a legitimate interest in being able to contact you and in knowing to which product the request relates so that we can deliver the best service possible. Processing may also be necessary in terms of our legitimate interest in defending or pursuing claims (point (f) of Article 6(1) of the General Data Protection Regulation).

- Consent: If you give us unsolicited details about your health that are relevant in connection with the installation or service, we will process such information based on your consent (point (a) of Article 9(2) and point (a) of Article 6(1) of the General Data Protection Regulation).

- Legal claim: If we receive details about your health that are relevant in connection with the installation or service from anyone other than you such as public authorities and where our service is provided in connection with your right to receive aids as prescribed by legislation, we base our processing on the fact that such processing is necessary to ensure that your legal claim for this service is fulfilled. If we receive details about your health in connection with our handling of cases that arise out of incidents involving equipment produced by Guldmann, we base our processing on the fact that such processing is necessary to determine, defend or pursue legal claims (point (f) of Article 9(2) and point (f) of Article 6(1) of the General Data Protection Regulation).

3.5 Storage period
Personal data included in bookkeeping documents will be stored in accordance with the requirements provided by national legislation. Data will therefore be stored in compliance with current legislation (point (c) of Article 6(1) of the General Data Protection Regulation).

Health details being processed in connection with installation or service will be erased immediately after the relevant service has been provided.

Personal data that is processed in connection with cases arising out of incidents involving equipment produced by Guldmann will be stored for 15 years from the time when Guldmann stops selling the product purchased, after which they will be erased.

The storage period is justified in Guldmann's legitimate interest in being able, for security reasons, to see the incident history of Guldmann's products throughout the period in which Guldmann has a worldwide obligation to store information about products and incidents.

The data can also be stored for longer in an anonymised format.

4. Recruitment
When you apply for a job at Guldmann, we process your personal information in connection with the recruitment process. We recommend that you leave out your civil registration number or sensitive personal information, such as personal information that reveals your racial or ethnic background, religion, trade union affiliation, sexuality or health details.

4.1 Types of personal data
Guldmann may collect, process and store the following types of personal data about you:
- Contact information such as name, email address and phone number
- Information stated in an application, CV and any enclosures
- Relevant information that is publicly available on the Internet and social media, including information about previous employment, activities, skills, performance and general appearance
- Results of personality tests, if you have taken any
- Criminal record, if required for the position you have applied for
- References from previous and/or current employers that you have stated in your application or that you have given us permission to contact
- Credit score, if the position you have applied for involves economic responsibility (e.g. bookkeeping or auditing)
- Health details, if the position you have applied for places special demands on your health
- Other information you might give us in connection with the recruitment process

4.2 Purposes of processing
Your personal data will be used to assess whether we want to offer you a position at Guldmann.

4.3 Basis of processing
Guldmann primarily processes your personal data based on one or more of the following:
- Legitimate interest: We may process your personal data based on our legitimate interest in assessing whether we want to offer you employment, including based on the information you provide in your CV, application and any enclosures, based on relevant information that is publicly available on the Internet and social media, results of personality tests, credit scoring, references from persons stated in your application and other information you give us during the recruitment process. Processing may also be necessary in terms of our legitimate interest in defending or pursuing claims (point (f) of Article 6(1) of the General Data Protection Regulation).

- Consent: If we want to obtain references from former and/or current employers that you have not stated as references in your application, we will only do so after obtaining your consent (point (a) of Article 6(1) of the General Data Protection Regulation). If the position you have applied for places special demands on your health, or if we need to see your criminal record, we will obtain your explicit consent before obtaining such information (point (a) of Article 9(2) and point (a) of Article 6(1) of the General Data Protection Regulation).

4.4 Storage period
If you are offered a position at Guldmann, your application and any further relevant personal data collected in connection with the employment process will be stored in your employee folder at Guldmann.

If you are not offered a position, your application and any further personal data collected in connection with the employment process will be stored for a period of 6 months after we have rejected your application, unless you have given us your consent to store such personal data for longer.

Your criminal record will be erased immediately after we have read it.

5. Disclosure to other data controllers and transfer to data processors.
In order to fulfil the above purpose, we may disclose your personal data to third parties that, subject to agreement with Guldmann, provide relevant services. This may be IT providers, mail providers and marketing providers. Such service providers will only process personal data in accordance with our instructions as specified in the concluded data processor agreements.

Guldmann's company structure may change as the company develops, e.g. in connection with a complete or partial sale of the company. Where possession of assets containing personal data is transferred, the processing basis for the related disclosure of personal data is generally point (f) of Article 6(1) of the General Data Protection Regulation, since Guldmann has a legitimate interest in transferring possession of parts of its assets and in undertaking commercial changes.

Besides what has been described above, your personal data will generally not be disclosed to third parties without your consent. However, in some circumstances and subject to legislation, we may be required to disclose your personal data to:
- The police
- Attorneys
- Auditors
- Courts
- Public authorities
- Potential buyers
- Consolidated companies

If possession of your personal data is transferred to data processors or data controllers in countries outside the EU/EEA that do not offer an adequate level of security, such transfer will be based on the European Commission’s standard contracts.

6. Your rights
- You have a right to access the personal data we process about you
- You have a right to object to our collection and further processing of your personal data
- You have a right to have your personal data rectified and erased subject, however, to certain statutory exceptions, including the Danish Bookkeeping Act.
- You have a right to request that we restrict the processing of your personal data
- Under certain circumstances, you may also request a copy of your personal data and that the personal data you have provided us with be transferred to another data controller (data portability)
- You may withdraw any consents you have given at any time. We will then erase your personal data unless we can continue to process your data subject to a different basis. You can unsubscribe from our newsletter by clicking the link at the bottom of the newsletter

7. Questions and complaints
If you have any questions regarding this privacy policy or if you wish to submit a complaint about the way we process your personal data, please contact us at:

Guldmann Care-Lift Solutions ULC
5716 Coopers Ave, Unit 9
L4Z 2E8 Mississauga, ON
Canada
Phone: +1 877 339 7779
Email: info@guldmann.net

If we are unable to resolve your complaint, and you want to pursue the matter, you may submit a complaint to the data protection authority.

8. Amendments to the privacy policy
We reserve the right to amend this privacy policy from time to time. The date at the end of the privacy policy will be updated in connection with amendments. The privacy policy in force from time to time will be available at www.guldmann.com/ca. You will be notified by email of any material amendments.

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May 26th, 2021.

Cookie Policy

+1 877 339 7779

info-canada@guldmann.net