Privatlivspolitik

This Privacy Policy explains how WRO Danmark (in this policy also referred to as we, our, us) processes personal data for persons interacting with WRO Danmark and their rights in relation to the personal data we hold.

Personal data we hold is for persons interacting with us through our website and other communications channels, purchasing items and services from us, and attending our events (including work shops, demonstrations, competitions and information meetings).

We process data in compliance with Danish legislation and the EU General Data Protection Regulation (GDPR)[1].

The data controller for the processing of personal data under this policy is WRO Danmark.

 

How and why we process personal data and with whom we share it

We will process personal data either in ways persons in dialogue with us and participants and attendees to our events have consented to, or because it is otherwise necessary for a lawful purpose.

We set these out as follows:

For the purposes of organizing and delivering events. This includes corresponding with persons that have registered interest to attend or participate in events (both pre- and post-event information).

As part of this process, we will expect to share your personal data with:

our agents, contractors and service providers (including providers of accommodation, catering, transport, IT and other support services) where applicable and where it is necessary for them to receive the information;
our bank and payment providers;
sponsors, co-organisers or partners who are involved in the delivery of an event;
relevant professional bodies or institutions where membership or affiliation affects your entitlement to attend (or results in a discount on) an event.
For the purposes of providing paid goods and services.

As part of this process, we will expect to share your personal data with:

our bank and payment providers.
For the purposes of providing information about WRO Danmark and other WRO organisations.

 

Other legitimate interests

Personal data will also be processed because it is necessary for WRO Danmark’s legitimate interests or the legitimate interests of a third party. This will always be weighed against data subjects’ rights, interests and expectations. Examples of where we process data for purposes that fall under legitimate interests include:

filming, photographing or otherwise recording events and publishing such content on our website, social media accounts, brochures, articles and other formats where it would not be necessary, appropriate or practicable to obtain specific consent (for example, we may seek specific consent for prominent or impactful uses with naming of the persons identifiable in the material);
analysing and improving the use of our communication channels, including our website and social media;
using digital tools to monitor the impact of our marketing communications (such as using email tracking to record when an email we send you has been opened);
analysing who is attending our events, including so that we can monitor the success of our outreach programs and understand trends in participation.

 

How we collect personal data

We collect personal data from the following sources:

completed forms in relation to attending or participating in an event;
completed forms in relation to requesting information;
completed forms in relation to purchasing goods or services;
interact with one of our representatives or employees during an event
completed surveys and feedback forms;
communication with us by post, email, online chat, social media, telephone or another format;
visiting WRO Danmark’s or the event website, including when you search, register or sign-up for an event;
from third parties such as our payment provider who will confirm details of your payment.

 

What categories of personal data de we collect

We collect the following categories of personal data:

Identification, background and contact details

biographical information such as name, title, gender and date of birth;
images, audio and likeness (as captured in photographs or on recordings we make of the event, and on CCTV where the event is hosted at our premises);
contact details including address, email address, online chat or social media account details and phone number;
information about team participation and nationality.
Online and transactional

details of IP address, browser type and operating system when visiting our website;
events that persons have attended in the past or for which persons are registered to attend in the future;
payment details and financial transactions in relation to Events;
records of communications sent by us or received by us.
Special categories

We may also collect the following special categories of personal data where it is necessary for the purposes set out in this Notice (please also see the section on Special categories of personal data for details about how we process this data):

information concerning your health and medical conditions (e.g. disability and dietary needs);
criminal acts caught on our CCTV cameras.
In addition, as most of the participants in our events are minors, we process data about children.

 

Legal basis for processing of personal data

Legal obligations

Your personal data will be processed for compliance with the WRO Danmark’s legal obligations. For example:

for the detection and prevention of crime and to assist the police and other competent authorities with investigations;
to submit contractually obliged information to sponsors;
to comply with tax legislation, safeguarding duties and subject access requests of others.
In this respect, we may in specific circumstances need to share personal data with third parties who have made legitimate requests under data protection or freedom of information law; the police and other law enforcement agencies; immigration authorities; tax authorities and the WRO Danmark’s external auditors.

Processing where consent has been given

Personal data will also be processed by WRO Danmark where we have your consent.

Examples where consent would be sought include where the law or some other protocol requires that we obtain your consent (for certain marketing or fundraising communications) or where, having balanced the our legitimate interests against data subjects’ rights, interests and expectations, we feel it is appropriate to obtain consent for our processing, rather than rely on the legitimate interests basis.

Where applicable, consent will always be specific and informed, and the consequences of consenting or not, or of withdrawing consent, will be made clear.

Special categories of personal data

In addition to the above, WRO Danmark may process types of personal data that the law considers to fall into a special category (such as race, religion, health, sexual life or criminal record). This will be under the following circumstances:

where data subjects have provided explicit consent. Examples might include where information has been provided on dietary requirements, allergies or where we have been informed by a data subject of the requirement for wheelchair access;
where such processing is necessary for the establishment, exercise or defence of legal claims (including sharing with the WRO Danmark’s insurers and legal advisers) or the prevention or detection of crime (for example, detecting criminal actions through the use of CCTV or reporting allegations to the police);
where it is in the data subject’s vital interests to do so but the data subject is incapable of giving consent, for example to inform a specified emergency contact, health or emergency services in the event of illness or other emergency.

 

Data subject rights

Data subjects have the right to contact us

to request that we erase their personal data;
to request that we restrict our data processing activities in relation to their personal data;
to receive from us the personal data we hold about them, which they have provided to us;
including for the purpose of transmitting that personal data to another data controller; and
to require us to correct the personal data we hold about them if it is incorrect.
Please note that only limited images and recordings are labelled with the attendees and participants that figure in them, and as such we can only provide insights as above to images and recordings where we can identify data subjects through labelling.

If you have any questions about these rights or how your personal data is used by us, you should contact WRO Danmark using these contact details: bir@eskills.dk.

 

How long do we keep personal data for

Images and recordings may be kept indefinitely by WRO Danmark.

For bookkeeping, administrative and audit purposes information about registered participants and attendees may be kept for up to five years after the conclusion of the event as well as for parties involved in financial transactions

 

Data processors acting on our behalf

Eskills.dk performs most secretarial and administrative tasks on behalf of WRO Danmark, and as such act as data processors for WRO Danmark and has access to all data held by WRO Danmark.

[1] Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).