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Privacy policy of Accura Advokatpartnerselskab

1 DATA CONTROLLER ETC.

When you use Accura Advokatpartnerselskab's ("Accura") websites or otherwise contact us, Accura as data controller will process various personal data about you.

In this privacy policy, you can read more about how we process data about you. This privacy policy applies to our collection and processing of personal data in connection with your use of www.accura.dk and www.accura.eu, when you contact us, and when we receive data about you from a third party.

You are always welcome to contact us at compliance@accura.dk if you have any questions concerning the way we process personal data. Also see clause 9, in which we describe your rights and provide you with our additional contact details.

2 DATA PROCESSOR

In certain situations, Accura acts as data processor on behalf of our clients. This is the case, for example, if Accura provides a virtual data room to our clients. When Accura acts as data processor, we only act according to the data controller's instructions and in accordance with the data processor agreement setting out the terms of the processing activities. This privacy policy does not apply to the processing activities carried out by Accura as data processor.

3 PURPOSES, LEGAL GROUND AND CATEGORIES OF PERSONAL DATA

In connection with our provision of advice and services to you, we process data for the following purposes:

Legal advice
When you contact us, e.g. by e-mail, your enquiry may sometimes contain personal data, such as contact details, your affiliation with a certain business or other personal data, which you may disclose to us. In certain situations, we may also receive personal data about you from third parties, such as your employer or your colleagues. Such data may include your contact details and information about your affiliation with your employer.

We process such data e.g. to be able to handle and respond to your enquiry and to be able to advise you or the business with which you are employed. If our advice is directed at you as a natural person, the processing of your personal data is authorised by section 6(1) of the Danish Data Protection Act, cf. article 6(1)(b) of the General Data Protection Regulation. If we have not concluded an agreement directly with you concerning legal advice, e.g. if you are an employee with or otherwise represent a business to which we provide legal advice and if, in that connection, we process your personal data, we are authorised to do so by section 6(1) of the Danish Data Protection Act, cf. article 6(1)(f) of the General Data Protection Regulation. In that case, our legitimate interest is that it is necessary to process your personal data to comply with our agreement with the business you represent.

In specific situations, there may be cases where we process sensitive data and/or data concerning criminal offences. The processing of such personal data is authorised by section 7(1) or section 8(5) of the Danish Data Protection Act, cf. article 9(2)(f) of the General Data Protection Regulation.

In accordance with the Danish Anti-Money Laundering Act, we as a law firm are obligated to comply with several obligations in connection with our provision of legal advice. In that connection, we may be obligated to process personal data about you, including data about your name, civil registration (CPR) number, passport number, etc. The personal data, which we process to comply with our obligations under the Danish Anti-Money Laundering Act, will be processed only for this purpose. The processing of such personal data is authorised by section 6(1) of the Danish Data Protection Act, cf. article 6(1)(c) of the General Data Protection Regulation, and section 11(2)(i) of the Danish Data Protection Act, cf. the Danish Anti-Money Laundering Act.

Newsletters
If you sign up to receive one of our newsletters, we will register your e-mail address and any other contact details which may constitute personal data to be able to send you our newsletters. In some cases, we also register other information which you specifically provide to us to be able to customise the news we send to you.

The processing of such personal data is authorised by the consent you give us when you sign up to receive our newsletter; see section 6(1) of the Danish Data Protection Act, cf. article 6(1)(a) of the General Data Protection Regulation.

You may withdraw your consent at any time if you no longer wish to receive newsletters from us. This is done by contacting us using the contact details set out in clause 9.

Our websites
Our websites use cookies and similar technologies to collect and process data about how our visitors use our websites and services. Additional information about our use of cookies and similar technologies is provided in our cookie policy.

When cookies and similar technologies are stored on your terminal equipment, your personal data may be processed, such as data about your IP address. The processing of such personal data is authorised by section 6(1) of the Danish Data Protection Act, cf. article 6(1)(f) of the General Data Protection Regulation. Our legitimate interest is that the data is necessary for us to prepare statistics on our visitors' use of our websites and optimize our websites.

4 DISCLOSURE OF AND MAKING AVAILABLE PERSONAL DATA 

We will generally not disclose personal data comprised by this privacy policy to third parties without your consent, unless we are required to do so by law, or if such disclosure is necessary to pursue the purposes we have described above. The recipients may include the police, the Danish Tax and Customs Administration (SKAT), public authorities, other law firms (including abroad), external business partners, the opposing party in legal proceedings, Danish or foreign courts or arbitration tribunals. In that case, such disclosure is authorised by section 6(1) of the Danish Data Protection Act, cf. article 6(1)(f) of the General Data Protection Regulation, or section 6(1) of the Danish Data Protection Act, cf. article 6(1)(c) of the General Data Protection Regulation.

In several cases, we leave the processing of your personal data to our data processors. This is the case, for example, when we allow our data to be hosted by an external service provider. Our data processors only process your personal data according to our instructions, and we always conclude data processor agreements with our data processors.

If we deposit client funds on a client account, we are obligated to disclose the client's identity so that the custodian bank can perform the obligations to which it is subject under the Danish Anti-Money Laundering Act. Making available personal data is authorised by section 6(1) of the Danish Data Protection Act, cf. article 6(1)(c) of the General Data Protection Regulation, cf. the Danish Anti-Money Laundering Act.

5 TRANSFER TO THIRD COUNTRIES

In certain situations, we transfer your personal data to recipients outside the EU and EEA. Such transfer will be made if we use data processors and/or subprocessors located outside the EU and EEA. This may also be the case if any opposing parties, advisors or authorities represented in a case are located outside the EU and EEA.

Under article 13(e) and (f) of the General Data Protection Regulation and article 14(e) and (f), we must inform you that, as at 25 May 2018, Accura has the following categories of recipients in third countries:

Data processor (indicated by number) and subprocessor (indicated by letter) in third countries (the country is stated in parenthesis):

1. Enalyzer
    a. Microsoft Azure (USA)
    b. Zapier (USA)
    c. Airtable (USA)

2. Campaign Monitor
    a. Amazon Web Services Inc. (USA)
    b. E-Hawk LLC (USA)
    c. Mixpanel, Inc. (USA)
    d. Slack Technologies, Inc. (USA)
    e. Google, Inc. (USA)
    f. Segment.io
Inc. (USA)
    g. Optimizely, Inc. (USA)
    h. PayPal, Inc. (USA)
    i. Salesforce.com
, Inc. (USA)
    j. Marketo, Inc. (USA)
    k. MaxMind, Inc. (USA)
    l. Equinix, Inc. (USA)
    m. Sift Science, Inc. (USA)

3. Kilgray Ltd. (Ungarn)
    a. APH Inc.d(b/a Condero (USA)

4. Re-Index
    a. Mailgun Technologies Inc. (USA)

5. Penneo
    a. Amazon Web Services (USA)

6 STORAGE AND DELETION

We will generally process your personal data only for as long as there is an existing customer relationship between you or the business you represent and us. After that, we store the personal data for a period of up to ten years, depending on the specific data, to comply with our duties under the Code of Conduct for the Danish Bar and Law Society and the Danish Limitation of Claims Act.

If your enquiry does not concern a customer relationship, we will store the personal data for a period of up to five years after your enquiry has been completed.

Personal data which we have procured in accordance with the Danish Anti-Money Laundering Act and the Danish Bookkeeping Act are stored for a period of five years after the customer relationship has ended and will then be erased.

7 YOUR RIGHTS

Under chapter III of the General Data Protection Regulation, you have several rights in relation to our processing of data about you.

You must contact us if you want to exercise your rights.

Right of access
You have the right to access the data which we process about you and several other data.

Right to rectification
You have the right to request rectification of inaccurate data about you.

Right to erasure
In special situations, you have the right to request erasure of data about you before we are generally obligated to erase such data.

Right to restriction of processing
In certain situations, you have the right to request restriction of the processing of your personal data. If you have the right to request restriction of the processing, we will in future only be able to process your personal data – except for storage – with your consent or for the establishment, exercise or defence of legal claims or for the protection of a person or important public interests.

Right to object
In certain situations, you have the right to object to our otherwise lawful processing of your personal data. You may also object to the processing of your personal data for direct marketing purposes.

Right to data portability
In certain situations, you have the right to request that we send your personal data in a structured, commonly used and machine-readable format and that we transmit those data from one data controller to another without hindrance.

You can read more about your rights in the Danish Data Protection Agency's guidance on the data subjects' rights, which is available on www.datatilsynet.dk.

For purposes of making such enquiries, please use the contact details set out in clause 9.

8 SPECIAL CIRCUMSTANCES RELATING TO LAW FIRMS

In certain situations, your rights as a data subject under the Danish data protection legislation does not apply to Accura's processing of your personal data.

Under the Danish Administration of Justice Act and the Code of Conduct for the Danish Bar and Law Society, Accura is subject to a duty of confidentiality and, therefore, we may omit to inform you of our processing of your personal data if we assess that the nature of such data is confidential.

Furthermore, Accura may omit to observe our duty to provide information to you if you already have knowledge of the data with which we are otherwise obligated to provide you or if the provision of information to you proves to be impossible, would involve disproportionate effort or would impair the achievement of the purposes of our processing.

Accura may also omit to observe our duty to provide information to you or omit to give you access to your personal data if we assess e.g. that the consideration for your interest in receiving the data is subordinate to decisive considerations for private interests.

9 CONTACT DETAILS

If you have any questions, comments or requests concerning the processing of your personal data, you are welcome to contact us at any time at:

Accura Advokatpartnerselskab
CVR no.: 33 03 90 18
Tuborg Boulevard 1
DK-2900 Hellerup
E-mail: Compliance@accura.dk
Tel.: +45 39 45 28 00

If you wish to file a complaint about our processing of your personal data, please contact:

The Danish Data Protection Agency
Borgergade 28, 5
DK-1300 Copenhagen K
E-mail: dt@datatilsynet.dk
Tel.: +45 33 19 32 00
Fax: +45 33 19 32 18

See also https://www.datatilsynet.dk/om-datatilsynet/kontakt/