Privacy Policy

Guldmann A/S (‘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 details
The data controller for your personal data is:

V. Guldmann A/S
Graham Bells Vej 21-23A
8200 Aarhus N
Denmark
Central business register no.: 27706746
Email: info@guldmann.com

1. The website www.guldmann.com
This section contains the policy for Guldmann's processing of personal data collected via the website www.guldmann.com.

1.1 Cookies
Guldmann uses cookies on the website www.guldmann.com, in which connection your personal data is processed. 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 the following link: www.guldmann.com/int/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: https://www.guldmann.com/int/cookie-policy

Personal data collected via cookies is stored for up to 14 months from the time it is collected. However, the data may 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. 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 may 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 before 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 Contact details on the website
When you contact us via the contact details provided on www.guldmann.com, Guldmann collects and processes your personal data. 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
• Other information you provide in connection with your inquiry

Your personal data will be processed for the following purposes:

• Handling 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).

Your personal data will be stored for one year and will then be deleted. However, the data may 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.

1.4 Ordering goods on the website
When you use the product order form or the service and installation order form at www.guldmann.com, Guldmann collects and processes your personal data. Guldmann collects, processes and stores the following types of personal data about you:

• Name, title, organisation affiliation, email address, telephone number, delivery address
• Reference
• Date of your inquiry
• Central business register no., reference and, if applicable, requisition number
• Product numbers, as well as the number of items that you order
• Other information you provide in connection with your order

Your personal data will be processed for the following purposes:

• Processing and fulfilment of your order
• Statistics and analysis

Guldmann processes your personal data on the following basis:

• Legitimate interest: We process your personal data on the basis of our legitimate interest in being able to contact you in relation to the fulfilment of the agreement entered into between Guldmann and the company or authority you represent, as well as our legitimate interest in gathering statistics and conducting analysis in order to develop and improve our services (point (f) of Article 6(1) of the General Data Protection Regulation).

We may disclose your contact details to external suppliers who, in agreement with us, will deliver the goods you order. Disclosure is subject to our legitimate interest in being able to deliver the product you request (point (f) of Article 6(1) of the General Data Protection Regulation). We may also disclose your contact details to external installers who, in agreement with us, will install your products as requested (point (f) of Article 6(1) of the General Data Protection Regulation).

Your personal data will be stored in accordance with section 2.5 below. However, the data may be stored for longer in 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 business partners (B2B)
This section contains the policy for Guldmann's processing of personal data about customers (consumers), owners of sole proprietorships or contact persons at suppliers and other business partners who co-operate 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, telephone number and similar identifying data
• Individual information, e.g. preferred languages
• 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 ranking

We may 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 ratings, 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 Legal basis for processing
Guldmann primarily processes your personal data on one or more of the following bases:

• 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 rating, collecting statistics, conducting analyses and marketing activities (where no consent is required); and provide support as well as improvement and development of our products and services. Processing may also be necessary in 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 basis for processing 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 and other business partners
We store your personal data in accordance with the retention requirements of the local bookkeeping legislation, after which your personal data is stored (see point (c) of Article 6(1) of the GDPR). Your personal data will be permanently deleted before the end of the 16th year after your purchase. This final deletion time has been set on the basis of Guldmann's ability to fulfil the special obligations arising from MDR and FDA, as well as Guldmann's legitimate interest in being able to meet requirements under product liability legislation and applicable tax legislation (see point (c) and (f) 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
• Which Guldmann products you use
• Data concerning health, 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 work (an 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 data about your health that is 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 claims: If we receive data about your health that is relevant in connection with the installation or service from anyone other than you such as the municipality and where our service is provided in connection with your right to receive aids as prescribed by legislation, such as the Danish Social Services Act, 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 data 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
We store your personal data in accordance with the retention requirements of the local bookkeeping legislation, after which your personal data is stored (see point (c) of Article 6(1) of the GDPR). Your personal data will be permanently deleted before the end of the 16th year after purchase. This final deletion time has been set on the basis of Guldmann's ability to fulfil the special obligations arising from MDR and FDA, as well as Guldmann's legitimate interest in being able to meet requirements under product liability legislation and applicable tax legislation (see point (c) and (f) of Article 6(1) of the General Data Protection Regulation).

Data concerning health being processed in connection with an installation or service will be deleted immediately after the relevant service or service programme 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 it will be erased. The storage period is justified by 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 world-wide obligation to store information about products and incidents.
The data can also be stored for longer in anonymised format.

4. Recruitment
When you apply for a job with Guldmann, we process your personal data in connection with the recruitment process. We recommend that you leave out your social security number or sensitive personal information, such as personal information that reveals your racial or ethnical background, religion, trade union membership, sexual orientation or data concerning health.

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 telephone number
• Information stated in an application, CV and any enclosures
• Relevant information that is publicly available on the internet and social media, including in particular information about previous employment, activities, skills, performance and general conduct
• 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 ratings, if the position you have applied for involves financial responsibility (e.g. bookkeeping or auditing)
• Data concerning health, if the position you have applied for places special demands on your health
• Other information you give us in connection with the recruitment process

4.2 Purposes of processing
Your personal data will be used to assess whether we wish 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 ratings, references from persons stated in your application and other information you give us during the recruitment process. Processing may also be necessary for our legitimate interest in defending or enforcing legal claims (point (f) of Article 6(1) of the General Data Protection Regulation). If we need to see your criminal record as part of our assessment, this is processed on the basis of our legitimate interest in assessing whether we can offer you a position (section 8(3) of the Danish Data Protection Act or point (f) of Article 6(1) of the General Data Protection Regulation).
• Consent: If the position you have applied for places special demands on your health, we will obtain your explicit consent before collecting 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 information collected in connection with the employment process will be stored in your employee folder with us.

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 approx. 6-12 months (depending on the country) 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 purposes, we may provide access to your personal data to third parties who, based on a contractual relationship with Guldmann, provide relevant services. These may be IT providers, email providers and marketing providers. Such service providers will only process personal data in accordance with our instructions as specified in the data processing agreements concluded.

Guldmann’s company structure may change as the company develops, e.g. in connection with a complete or partial sale of the company. In the case of partial transfer of assets containing personal data, 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
• Lawyers
• Auditors
• Courts of law
• Public authorities
• Potential buyers of all or parts of Guldmann's business
• Consolidated companies

If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA that do not have an adequate level of protection, such transfer will be based on EU-U.S. Data Privacy Framework or the EU Commission's standard contractual clauses, a copy of which you can obtain by contacting us as indicated below.

6. Your rights

• You have a right to access to 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 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 to receive a copy of your personal data, and request transmission of the personal data you have provided us with to another data controller (data portability)
• You may withdraw any consent 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 about this Privacy Policy or if you wish to complain about the way we process your personal data, you are welcome to contact us:

V. Guldmann A/S
Graham Bells Vej 21-23A
8200 Aarhus N
E-mail: info@guldmann.com

If your complaint is not resolved by us and you want to take the matter further, you can complain to the Danish Data Protection Agency:

Danish Data Protection Agency
Carl Jacobsens Vej 35
2500 Valby
Telephone number: 33 19 32 00
Email: dt@datatilsynet.dk

***

March 20th, 2024.

Relevant links: