Privacy Policy

 

The purpose of this policy

KLAR Advokater P/S ("KLAR") processes personal data about you in a range of different situations. We process such data when you enter into a client relationship with us and we provide you with legal advice, or if you otherwise come into contact with us, for example as a party or a witness in a case involving one of our clients, or when you visit our website or apply for a job with us. 
 

We are generally obliged to inform you whenever we process your personal data. However, there are certain cases in which we are prevented from fulfiling this duty to inform. This occurs namely in cases where we are bound by a duty to maintain confidentiality and in situations where other interests considerably outweigh your right to be informed. 
 

This privacy policy contains information on how KLAR processes personal data, which you can read more about below.



Data Controller

The legal entity which is the data controller for the processing of personal data undertaken by KLAR is:
 

KLAR Advokater P/S
Company Registration No: 32 28 22 88
Indiakaj 12
DK-2100 København Ø
 

You can contact us with any questions regarding data protection at:
 

Telephone: +45 7228 9100
E-mail: ngj@klaradvokater.dk



Personal data processing

You can read more about how we process personal data in the table below:

 

Purpose

Data Subject

Category of Personal Data

Legal Basis

Source

Retention Period

Manage client relationships, including the establishment of new clients and cases, provide advice, issue invoices, undertake quality assurance and control.

Clients, including employees of clients.

Non-sensitive  personal data such as names, titles, addresses, telephone numbers and e-mail addresses.

The processing is necessary for the performance of contracts with our clients or in order to take steps at the request of the clients prior to entering into contracts, cf. General Data Protection Regulation article 6, paragraph 1, point b.
 

Moreover, such processing is also necessary in order for us to pursue our legitimate interests in managing client relationships, fulfiling contracts with our clients, administering and developing our business and services, and handle the operation and maintenance of IT systems that are used as a part of our management of client relationships, cf. General Data Protection Regulation article 6, paragraph 1, point f.
 

Clients, including employees of clients.

11 years, calculated from the end of the calendar year in which the client relationship is terminated, unless 
specific circumstances require a shorter or longer storage period.

Conduct our anti-money laundering procedure.

Clients, including ultimate owners and daily management.

Non-sensitive  personal data that is included in documents such as passports, driving licences or health insurance cards, including name, address, place of birth, nationality and civil registration number. We store copies of identification documents presented to us such as passports, driving licences or health insurance cards.

We process personal data in accordance with the Act on Measures to Prevent Money Laundering and Financing of Terrorism (the Anti-Money Laundering Act) to which KLAR is subject. We process personal data in accordance with the due diligence procedures set out in the Anti-Money Laundering Act, cf. sections 11–21, cf. section 10, especially section 11, paragraph 1, number 1, point a, which are necessary in order to comply with a legal obligation that KLAR is subject to, cf. General Data Protection Regulation article 6, paragraph 1, point c and article 87, cf. Data Protection Act section 11, paragraph 2, number 1.
 

Clients, including owners and daily management and the employees of clients.

Five years, calculated from the time when the client relationship terminates or when the individual case is closed, unless specific circumstances require a longer storage period.

Providing legal advice.

Clients, parties, partners, witnesses and the employees of these persons.

Non-sensitive  personal data, such as name, position, organisation, address, e-mail address, telephone number and if concretely required, civil registration number as well.

Any sensitive personal data and personal data about criminal convictions and offences.

However, we generally do not want to receive sensitive personal data and personal data about criminal convictions and offences. If such data are received in this context, we delete them immediately, unless we have a substantive reason for processing them.

We process non-sensitive personal data about our clients which is necessary for the performance of contracts with our clients and to provide legal advice, cf. General Data Protection Regulation article 6, paragraph 1, point b. 
 

We process non-sensitive personal data on counterparties, the employees of clients and counterparties and witnesses if this is necessary in order for our clients and KLAR to pursue legitimate interests in managing the clients’ interests, cf. General Data Protection Regulation, article 6, paragraph 1, point f.
 

We process and forward civil registration numbers to public authorities for purposes such as making registrations on behalf of clients on websites such as virk.dk, tinglysning.dk or minretssag.dk which are required for the purpose of unique identification, cf. General Data Protection Regulation, article 87, cf. Data Protection Act section 11, paragraph 2, number 3. 
 

In cases where we do process sensitive personal data or personal data regarding criminal convictions and offences pertaining to clients, counterparties and the employees of clients or counterparties, is such processing necessary in order for a legal claim to be established, exercised or defended, cf. General Data Protection Regulation article 9, paragraph 2, point f.
 

Clients, parties, witnesses and their advisors or employees, and otherwise from publicly available sources.

11 years, calculated from the end of the calendar year in which the client relationship is terminated, unless specific circumstances require a shorter or a longer storage period.

Administration of visitors to klaradvokater.dk.

Visitors to klaradvokater.dk.

Non-sensitive  personal data.

We process personal data if we have the visitor’s prior consent, cf. General Data Protection Regulation article 6, paragraph 1, point a.

You can read more about how KLAR uses cookies in our Cookie Policy.
 

The visitor.

You can read more the different cookies used in our Cookie Policy.

Recruitment.

The applicant.

Non-sensitive  personal data, including name, address, telephone number, e-mail address, educational background, professional experience and any other personal data that the applicant provides, as well as references.
 

Personal data about criminal offences, including the applicant’s criminal record.

Processing of non-sensitive personal data is necessary in order for KLAR to pursue its legitimate interests in being able to recruit applicants to positions at KLAR, cf. General Data Protection Regulation article 6, paragraph 1, point f.
 

We will also process personal data that is necessary in order to take steps at the request of the applicants prior to entering into a contract, cf. General Data Protection Regulation article 6, paragraph 1, point b.
 

We process personal data that is collected from references provided that the applicant has consented to this, cf. General Data Protection Regulation article 6, paragraph 1, point a.
 

We process personal data on criminal records if it is necessary for the purpose of a legitimate interest in ensuring that the applicant is suited for the position at KLAR that is being recruited for, cf. General Data Protection Regulation, article 10, cf. Data Protection act section 8, paragraph 3. This is applicable in relation, for example, to KLAR’s compliance with the Anti-Money Laundering Act.
 

The applicant and any references (if consent has been attained) and data that is otherwise publicly available.

Six months after the date on which the applicant has received notice that their application has been rejected, unless the applicant has given consent for a longer storage period.

Courses, networks and similar events at KLARParties with which we have business relations.Non-sensitive personal data such as name, position, e-mail, telephone number and organisation.

Processing of personal data in connection with enrollment of courses, networks and similar events at KLAR is necessary to keep in touch with the participants and for the performance of contracts with participants, cf. General Data Protection Regulation article 6, paragraph 1, point b.The processing is also necessary in order for KLAR to pursue its legitimate interests in being able to evaluate the course or the event, cf. General Data Protection Regulation article 6, paragraph 1, point f.
 

The relation in question or the relations employer.The processing of personal data will continue until the individual course, network or event has been completed and evaluated, and so we can invite the parties with which we have business relations to similar in the future.

Marketing activities, such as sending out newsletters, invitations to various events and other forms of direct communication.

Parties with which we have business relations.

Non-sensitive  personal data such as name, position, e-mail address, telephone number and organisation.

If we have been in contact with you in one form or another, then we consider that we have a legitimate interest in processing your personal data so that we can maintain our relationship and market our services, while also ensuring that the messages we send to you are as relevant as possible, cf. General Data Protection Regulation article 6, paragraph 1, point f.
 

Processing of personal data in connection with sending out our newsletter is undertaken on the basis of your consent, cf. General Data Protection Regulation article 6, paragraph 1, point a. 
 

The relation in question or through publicly available sources such as LinkedIn or Facebook or through the website of the data subject’s organisation.

Until the relation him/herself requests that we stop.

With regards to our newsletter, processing will continue until the relation withdraws their consent.



 

Transfer and hand over of personal data


KLAR is bound by a statutory obligation to maintain confidentiality and will not generally transfer your personal data to third parties.
 

We only transfer personal data to our auditors and to other professional advisors in certain cases, e.g. so that auditors can perform audits or so that we can receive professional advice from other consultants and advisors. In addition, we also transfer personal data to courts, clients and third parties in cases where it is necessary to do so in order for a legal claim to be established, exercised or defended.
 

We also use external suppliers, such as IT suppliers, accountants, etc. which may receive personal data in connection with the assistance they provide to us. KLAR enters into data processing agreements with external suppliers which process personal data on behalf of KLAR in order to ensure that all necessary security measures are adopted by our external suppliers. 

We do not transfer personal data to countries outside of the EU/EEA unless such a transfer is being made to a client, counterparty or court.



Security of processing

As a law firm, we are obliged to protect the confidentiality, privacy and accessibility of client’s and other business relations data, including personal data. KLAR places a high level of priority on client confidentiality and information security and we are strongly committed to ensuring the continuous protection of personal data. We have implemented security measures that shall ensure the data protection of both client information and personal data as well as other confidential information. We regularly conduct internal reviews in order to ensure that we have an adequate degree of security in place and that we are complying with our policies.


 

Your rights as a data subject


As a data subject, you have a range of basic rights. These rights can be restricted however; for example, in cases where the access to personal data that you would otherwise be entitled to receive would entail violating the rights and freedoms  of another or violating our duty of confidentiality as legal professionals.
 

Withdrawal of consent

In cases where our processing of your personal data is based on your consent, you are entitled to withdraw such content at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. In order to withdraw your consent to our processing of your personal data, we ask that you contact us.
 

If you no longer wish to receive e-mails containing information and marketing materials from KLAR, you can easily unsubscribe from the mailing list by replying to an e-mail you have received from us with the message "unsubscribe from marketing content" and to unsubscribe from our newsletter, click the "unsubscribe from newsletter" link in the last issue of the newsletter you have received.
 

Right to access

You are entitled to be informed as to whether or not KLAR is processing personal data about you and if so, you are entitled to find out what types of personal data we process and what purpose we process them for and you are entitled to receive a copy of such data.


Right to rectification

You are entitled to have any incorrect or incomplete personal data rectified. If the personal data is disclosed  to others, we will ensure that the recipients are informed of any corrections, provided this is possible and legal.


Right to erasure

You are entitled to have personal data that KLAR is processing on you deleted. If the data has been disclosed to others, we will ensure that the recipients are informed of any deletion, provided this is possible and legal.


Right to restriction of processing

You are entitled to have the processing of your personal data restricted so that the data can only be stored by KLAR. If the data has been disclosed to others, we will ensure that the recipients are informed of any restrictions, provided this is possible and legal.


Right to data portability

In certain cases, you are entitled to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and to transmit  those data to another controller.


Right to object to KLAR’s processing

In certain cases, you are entitled to object to our processing of your personal data.

 

Changes to this privacy policy

Transparency is an ongoing commitment and we therefore update this privacy policy on a continuous basis. The privacy policy was last updated on 24 August 2018.


 

Contact and complaints

If you would like to complain about KLAR’s processing of your personal data, we ask that you send an e-mail with the details of your complaint to ngj@klaradvokater.dk. We will address your complaint and get back to you.
 

You are also entitled to complain to the Danish Data Protection Agency (Datatilsynet):
 

Danish Data Protection Agency
Borgergade 28, 5.
DK-1300 København K.

Telephone: +45 33193200
E-mail: dt@datatilsynet.dk

For more information about how to complain to the Danish Data Protection Agency, please refer to the agency’s website: www.datatilsynet.dk.


 

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