Last update: 27 February 2019
WHO ARE WE? (OUR IDENTITY & CONTACT DETAILS)
This app is provided to you, the user, by ALK e-com A/S, CVR No. 39266881, having its registered office at Bøge Allé 6-8, 2970 Hørsholm, Denmark (“ALK e-com” or “we” ).
Our Phone Number: 040-703845-402
You can contact our Data Protection Officer via this link.
WHAT DATA IS USED & WHY
WHAT DATA WE PROCESS
We may process the following kinds of personal data about you:
First name, last name, email address, date of birth, gender, behavioral analytical data, geographical location, users’ pollen log including date and time, whether notifications are on or off, whether permission has been given to receive newsletters and any health data you have provided.
Data is usually collected directly from you. There is no obligation to provide the data if you do not want to.
HOW WE PROCESS YOUR PERSONAL DATA
In general, we only process your data where this is required for our legitimate business purposes, where we are required to do so due to relevant laws or where you provide us with your data voluntarily (i.e. by providing your consent).
We only process sensitive personal data, such as health data, where this is permitted by relevant laws or where you give us your express and informed consent.
We will not knowingly collect online data about children (minors) through the app, and in other situations we collect such data only where relevant and permitted by law.
We always need a reason ("purpose") and a legal basis, both as permitted by law, to process your personal data.
Any data used by the app will either be stored on your device, outside of our control, or used by Google Analytics, as described below.
When using the app, you will be asked for permission to process your data and access your location whilst using the app in order to give you more accurate air quality and pollen data and to personalize your experience while using the app. You do not have to give such permission if you do not want to, in which case your location will not be used. You can change your preference at any time in your settings. You can also download and delete the data the app has collected about you at any time in your settings, except any data we must retain for legal purposes (as detailed in the ‘ERASURE’ section below). This will not include deletion of any anonymized data used for statistical purposes.
The app will remember your settings, which you may change, and which will be deleted when you delete the app and related data from your device.
PURPOSE FOR WHICH WE WILL USE YOUR PERSONAL DATA
To enable you to install the app, create a profile, share information and receive information, services or other offers tailored to your needs.
Necessary for our legitimate interest (to provide the app)
Performance of our contract with you
To resolve issues or to provide answers to your enquiries (as relevant).
Necessary for our legitimate interest (to help improve the app)
Performance of our contract with you
To personalize the user experience, customize your content and provide personalized offers to you.
Necessary for our legitimate interest (to provide a better product and service)
To track the performance of the app and user behavior so that we can improve the user experience.
Necessary for our legitimate interest (to improve and develop our product and service)
DURATION OF RETENTION
Data will only be retained for as long as you wish (see “what are your rights” section below) or as long as we believe is relevant to the business situation or service, whichever is the earlier.
This app uses Google Analytics. Please refer to “How Google uses data when you use our partners' sites or apps” for further information, (located at www.google.com/policies/privacy/partners/).
WHO WILL WE DISCLOSE YOUR PERSONAL DATA TO (RECIPIENTS OF PERSONAL DATA)
i. ALK’S EMPLOYEES & EXTERNAL PROCESSORS
The recipients of your personal data will be employees of entities belonging to ALK Group and external processors providing specific services and processing personal data on our behalf and only in accordance with our instructions. They will receive your personal data only on a need-to-know basis, being subject to the obligation of confidentiality and after signing appropriate legal documents. The complete list of entities forming ALK Group is available here. No personal data will be disclosed to third parties outside of the European Economic Area.
ii. INDEPENDENT THIRD PARTIES
We may disclose your personal data to third parties (such as attorneys) when this would be necessary for the establishment, exercise or defence of legal claims or to public authorities, when required by laws, or, when needed, to independent third party auditors.
We implement reasonable technical and organisational security measures to prevent unauthorized use or misuse of the app and any associated data. We also recommend that you restrict access to the mobile device on which the app is used with an access protection (e.g. pin code or fingerprint scan).
WHAT ARE YOUR RIGHTS?
If you wish to exercise any of your rights please contact us using our contact details provided at the beginning of this policy.
i. ACCESS AND RECTIFICATION
You may access your data, as well as have inaccurate data rectified.
You are entitled to obtain a copy of your data, which will be provided to you in such a way as to respect the rights and privacy of other persons.
You are also entitled to ask us to provide you with any relevant details concerning the processing of your personal data.
ii. DATA PORTABILITY
You are entitled to receive data you have provided to us in a portable format (structured, commonly used and machine-readable format) and to have such data transferred to you or, when feasible, directly to another entity or person you expressly choose.
Please note, that the data will be provided to you in such a way as to respect the rights and privacy of other persons.
iii. RIGHT TO OBJECT
You may object to the processing of your personal data which is processed based on our legitimate interests and there is something particular about your situation which makes you want to object to processing on the grounds that you believe it impacts on your fundamental rights and freedoms. You also have the right to object when such data is processed for direct marketing purposes without giving any reasons.
iv. RIGHT TO WITHDRAW CONSENT
If you have given consent to use your personal data to us, you have the right to withdraw your consent at any time. For this purpose, you may address us at firstname.lastname@example.org or please contact us using our contact details.
Your withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
v. ERASURE (‘RIGHT TO BE FORGOTTEN’)
You may ask for your personal data to be deleted and no longer processed at any time. However, we may not always be able to comply with your request for erasure for specific legal reasons (e.g. if some data still needs to be stored for tax reasons) in which case, we will notify you of these reasons and give you an indication of when that data is likely to be deleted. Note that the right to erasure does not apply to anonymous statistical data (which will not contain any personal data).
vi. RESTRICTION OF PROCESSING
Instead of erasure, you may ask to have your data restricted. Further processing of restricted data may take place only with your consent or for reasons expressly stipulated by applicable law(s).
If the restriction would not be possible, because of justified legal reasons, you will be expressly informed about such reasons, as well as before the restriction is lifted.
If you wish to complain, please contact us using our contact details or send an email at email@example.com.
viii. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
If you believe that the processing of your personal data infringes EU law, you are entitled to lodge complaints with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement.
CHANGES TO THIS NOTICE