Privacy Policy

Last updated: 31-05-2022

When you, e.g., contact us, make a purchase on behalf of or otherwise represent one of our customers, partners and/or vendors, etc., we may collect and process your personal data. The data controller is the company within the Cotes Group which you are associated or have been in contact with, as further described below: 

Cotes is committed to ensuring that your personal data is stored and processed in accordance with the relevant rules on data protection, including the General Data Protection Regulation ("GDPR") and the Danish Data Protection Act. 

The purpose of this privacy policy is to describe how we process your personal data and your rights in this connection. 

If you have any questions about this privacy policy or wish to exercise your individual rights described below, please feel free to contact us at info@cotes.com 

The personal data that we collect about you will typically include your name, job title, telephone number and e-mail address, which we may receive as part of the regular course of business relations or correspondence through phone or e-mail. 

We do not process special categories of personal data (sensitive personal data) regarding representatives of our business partners. 

We will mainly collect and process your personal data for purposes of improving or facilitating an existing or future cooperation, or fulfilling an existing B2B contract between one of the companies within the Cotes Group and the company you represent. In this connection, processing of personal data will typically be required where you contact us for a specific purpose or with a specific request or in an existing business relationship. 

We will also collect and process your personal data for bookkeeping purposes and to invoice services provided to the company you represent and vice versa.  

Further, we will collect and process your personal data for the defence of legal claims, e.g., claims related to existing warranties and product liability. 

The processing of your personal data is necessary for the purposes of our legitimate interests which are regarded not to be overridden by your interests or fundamental rights, cf. Article 6(1)(f) of the GDPR. Such legitimate interests include:  

• fulfilment of contractual obligations with the company you are representing;  
• maintaining and enhancing customer relationships; 
• invoicing for products and services provided to/by companies within the Cotes Group and vice versa;  
• communicating with you as a representative of one of our business partners;  
• maintaining documentation of events, correspondence, etc. in case of a specific dispute, claims and/or damages, or otherwise for the establishment, exercise, or defence of/against legal claims. 

Furthermore, certain processing is necessary in order to comply with our legal obligations, cf. Article 6(1)(c) of the GDPR, namely retaining bookkeeping material pursuant to applicable bookkeeping rules such as the Danish Bookkeeping Act and the Danish Tax Control Act. 

Where relevant, we may disclose or transfer your personal data to intra-group companies, affiliates of the Cotes Group, vendors, business partners or other collaborators for business purposes, including delivery of products and services, legal matters and maintaining of our internal IT systems, etc. 

Certain recipients process personal data on behalf of us, i.e., as data processors. These third parties may, therefore, only process your personal data in accordance with our instructions and are, therefore, not permitted to process your personal data for their own purposes.  

To the extent that we disclose or transfer your personal data to third parties who may use your personal data for their own purposes, such disclosure or transfer will only take place if it is in accordance with applicable law.  

In certain situations, your personal data may be transferred to a country outside of EU/EEA, for instance to an affiliate of the Cotes Group or a vendor. We will ensure that such transfer is carried out in accordance with applicable data protection law. This entails that any party outside of EU/EEA that comes in possession of your personal data must ensure an adequate level of protection, for example, by entering into the EU standard contractual clauses.  

If you wish to obtain a copy of the appropriate safeguards provided for such transfer, please contact us through the abovementioned e-mail. 

The Cotes Group will only store your personal data for as long as necessary to fulfil the abovementioned processing purpose(s).  

We will store your personal data until the termination of the contractual relationship between us and the company which you represent, as long as we communicate, or until a legal claim can no longer be established.  

If there is an actual or potential legal dispute with the company you represent, your personal data will be retained as long as necessary for this purpose. Hereafter, your personal data will be deleted.  

In addition, we will store personal data, necessary for bookkeeping purposes in accordance with the special rules on the retention of bookkeeping material in the Danish Bookkeeping Act, i.e., for 5 years. If the personal data is included in accounting material which is subject to other (foreign) legislation, the personal data will be processed as long as required under the said legislation. 

We have implemented appropriate organisational and technical measures in order to protect your personal data and ensure your rights as a data subject.  

As a data subject, you have a number of rights. Please note that certain limitations may apply in this relation, e.g., when your right to obtain information is found to be overwritten by essential considerations of private interests. If you have any questions about your rights as a data subject, please contact us through the abovementioned means of contact.  

According to the GDPR, you have the following rights: 

• Right of access: You have the right to request access to the personal data the Cotes Group has stored concerning you. The Cotes Group must provide a copy of the personal data undergoing processing free of charge and by electronic means if the request has been submitted in a commonly used electronic form. 
• Right to rectification: You have the right to rectify inaccurate personal data concerning you, including completion of incomplete personal data. 
• Right to erasure (Right to be forgotten): Under certain circumstances, you have the right to erasure; meaning that, upon your request, we must erase the personal data stored concerning you. 

• Right to restriction: Under certain circumstances, you have the right to restrict our processing of personal data concerning you. 
• Right to data portability: You have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format. Where the processing is based on your consent or a contract and the processing is carried out by automated means, you have the right to transmit this personal data to a third party without hindrance by the Cotes Group.  
• The right to object: Under certain circumstances, you have the right to object to our processing of personal data concerning you at any time. 

If the processing of your personal data is based on your consent, you may withdraw your consent at any time. Please note that this does not affect our processing of your personal data prior to the withdrawal of your consent. Further, we may in some cases continue to process your personal data on another legal basis.  

Further, you have the right to file a complaint with the Danish Data Protection Agency at any time. Please see the contact information below.  

Danish Data Protection Agency (Datatilsynet) 

Carl Jacobsens Vej 35 

2500 Valby, Denmark 

Phone: +45 33 19 32 00 

E-mail: dt@datatilsynet.dk 

Website: www.datatilsynet.dk 

This privacy policy will be updated on a regular basis and when necessary due to changes in applicable law and practice, thus, we recommend to you keep yourself updated regularly.  

The effective date of the most recent update of this privacy policy: 

31 May 2022 

Last updated: 28-05-2018

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