Data Policy

information about personal data to customers and other business partners

Guidelines for processing of personal data of customers and suppliers in Little Miracles International A/S (”Little Miracles”), Company Registration (CVR) No 34904626.

Overview:

  1. In general
  2. Categories of personal data
  3. The data subjects
  4. For how long does Little Miracles store the data?
  5. Disclosure of data
  6. Legal basis for processing of personal data
  7. Obtaining personal data from a third party
  8. How do we protect your personal data?
  9. Transfer to third countries
  10. Rights of the data subjects
  11. Changes to the processing of personal data
  12. Inquiry to Little Miracles
  13. Complaint to the Data Protection Agency

In general

  • As a consequence of your agreement with Little Miracles, we collect and process personal data about our customers, suppliers and other business partners (collectively referred to as “Business Partners”).
  • These guidelines have been prepared on the basis of the EU General Data Protection Regulation which will enter into force in Denmark on 25 May 2018 and the new Danish Data Protection Act which supplements the rules of the General Data Protection Regulation and the current Processing of Personal Data Act (collectively referred to as ”Applicable Law”).
  • Please find below a specification of the collected data , including how the data are processed, their purpose, the persons who have access to the data and the persons who may be contacted if you have any questions or objections in respect of the data collected.

Categories of personal data

  • Little Miracles only processes personal data that are relevant to the agreed purpose. We primarily process ordinary data such as your name, address, telephone and mobile phone numbers, email etc. If one of our Business Partners is a personally owned and run business, we will also process financial data such as account numbers.

The data subjects

  • Little Miracles only processes personal data that are relevant to the agreed purpose. We primarily process ordinary data such as your name, address, telephone and mobile phone numbers, email etc. If one of our Business Partners is a personally owned and run business, we will also process financial data such as account numbers.

For how long does Little Miracles store the data?

  • Little Miracles deletes personal data when it is no longer necessary for us to process such data. The storage period has been determined in relation to the obligations that Little Miracles is subject to under the applicable rules, including the Danish Bookkeeping Act.
  • During an ongoing customer relationship, as a starting point, we will not delete personal data. When the customer relationship has ceased, we will as a starting point delete all of the customer’s personal data no later than 5 years after the end of the financial year in which the customer relationship has ceased, see the rules of the Danish Bookkeeping Act.
  • In specific cases, Little Miracles is entitled to process personal data for a period longer than 5 years. This may be the case as a consequence of statutory requirements or regulatory requirements or because a dispute is pending.

Disclosure of personal data

  • Little Miracles only discloses personal data if it is necessary in consideration of a contract entered into or in order to fulfil our other obligations.
  • We do for instance disclose contact information to our Business Partners to the extent that it is necessary for Little Miracles to deliver the service agreed.
  • As part of Little Miracles’ administration of the customer relationship, data processors are used to which relevant personal data are transferred as part of the bookkeeping process and/or order processing.

Legal basis for processing of personal data

  • Little Miracles’ processing of personal data is authorized by articles 6 or 9 of the General Data Protection Regulation.
  • Article 6(1)(b) of the General Data Protection Regulation authorizes the processing of the main part of the personal data that we process. Under this provision, we may process personal data if the processing is necessary in order to fulfil a contract.
  • Little Miracles also processes personal data as a consequence of a legal obligation to do so, see article 6(1)(c) of the General Data Protection Regulation.
  • Little Miracles may also process personal data under the so-called data balancing rule, see article 6(1)(f) of the General Data Protection Regulation. One of the legitimate interests that may substantiate the processing is for instance that it may be necessary to disclose contact information to Business Partners in order for Little Miracles to deliver its services. Little Miracles’ legitimate interests must be balanced against the data subjects’ interest in the non-processing of personal data.

Obtaining personal data from a third party

  • If it is necessary in order to deliver a service, Little Miracles may obtain personal data; primarily contact information, from a third party.

How do we protect your personal data?

  • Under the Applicable Law, personal data must be stored securely and confidentially. We store personal data in our IT system, which is operated only by authorized employees.
  • Our security measures are controlled regularly in order to determine if the processing of personal data is handled properly and in consideration of our Business Partners’ interests.

Transfer to third countries

  • Little Miracles uses data processors, which use sub-data processors outside the EEA.
  • In case of transfer to third countries (outside the EEA) the EU Commission’s standard contracts will be used or a standard that ensures in another manner that the level of protection in the third country in respect of the personal data transferred equals the level of protection within the EEA.

Rights of the data subjects

  • Under articles 15-20 of the General Data Protection Regulation the data subject has a number of rights in relation to our processing of your data.
  • Right of access
  • The data subject has the right to obtain from Little Miracles confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, access to the personal data.
  • Right to rectification of personal data
  • The data subject has the right to obtain from Little Miracles without undue delay the rectification of inaccurate personal data concerning him or her.
  • Right of erasure of personal data
  • In some cases, the data subject has the right to obtain from Little Miracles the erasure of personal data concerning him or her without undue delay. The right of erasure will, however, only apply if we do not continue to have a legitimate interest or a statutory obligation to store, including processing, the personal data.
  • Right to restriction of processing of personal data
  • In certain circumstances, the data subject has the right to obtain from Little Miracles restriction of processing of the personal data concerning him or her.
  • Right to object
  • In certain circumstances, the data subject has the right to object to Little Miracles’ processing of the personal data concerning him or her.
  • Right to data portability (transmission of personal data)
  • In certain circumstances, the data subject has the right to receive personal data concerning him or her in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

Change in the processing of personal data

  • We reserve the right to update and change these guidelines for the processing of personal data. If the guidelines are changed, the ”most recently revised” date at the bottom of the page will be changed. These guidelines will be evaluated and if necessary revised annually.

Inquiry to Little Miracles

Complaint to the Data Protection Agency

  • If you wish to complain about Little Miracles’ processing of your personal data, such complaint must be filed with the Data Protection Agency. Please find further information about this procedure on www.datatilsynet.dk, and inquiries can be sent to:

Datatilsynet

Borgergade 28, 5

1300 København K

Telephone: 33 19 32 00

Best regards,

Little Miracles International A/S

Most recently revised: May 2018
Next revision due: May 2019