Privacy Notice and Cookie Policy

1. Scope

Combineering (“We”, “Us”, “Our”) respects your privacy and is committed to protecting your personal data.

This privacy notice applies to the processing of your personal data when you visit our website at www.combineering.com, when you contact us by e-mail, post or telephone, when we subsequently provide services to you or when you are providing services to us.

 

 2. Definitions

“Data Protection Laws”

Means applicable law and regulatory requirements relating to the processing, privacy and use of personal data and protection of individuals, including, but not limited to.
(i) Regulation (EU) 2016/679 (“GDPR”)
(ii) Regulation (EU) 2016/679 (“GDPR”) as incorporated into domestic UK law by the European Union (Withdrawal Agreement) Act 2020 and amended by The Data Protection, Privacy and Electronic Communications (Amendments, etc.) (EU Exit) Regulations 2020 (together the “UK GDPR”).
(iii) any legislation enacted in the country of establishment of the data controller in respect of the protection of personal data or any corresponding or equivalent national laws or regulations.
all as amended, updated, or replaced from time to time;

 

3. Our contact details

Name: Combineering Group A/S

Bistrupvej 176

DK – 3460 Birkerød

CVR 29533261

+45 4558 4040

info@combineering.dk

See recital 22 of GDPR. An establishment ‘implies the effective and real exercise of activities through stable arrangements. The legal form of such arrangements, whether through a branch or a subsidiary with a legal personality, is not the determining factor in that respect.

 

4. Type of personal data we collect

The personal data we currently collect may include the following:

  • Contact details, including your name, job title, address, e-mail address and phone number
  • Demographic information, such as postcode, preferences and interests
  • Financial and credit card information
  • IP address
  • Website usage data, such as duration of visit, browser and operating system used, referrer URL, time of server request and content retrieved
  • Information relevant to your enquiry
  • Information pertaining to special offers and surveys
  • Social media interactions

 

5. How we get your Personal Data and why we have it

Most of the personal data we process is provided to us directly by you for one of the following reasons, in accordance with a lawful basis described in Section 6:

  • To fulfil any contracts entered into between you and us, including processing any payments
  • To provide you with information about our products and services that you request from us.
  • To respond to an enquiry or request from us.
  • You wish to attend, or have attended, an event.
  • To send you promotional emails or mailings, or to call you, about products, services and offers that we think might be relevant to you.
  • To contact you for market research purposes.
  • To ask you to complete customer satisfaction surveys to assist us in improving our products and services.
  • To subscribe to our newsletter.
  • You have applied for a job or secondment with us.

We also receive personal data indirectly when you visit our website, for the following reasons:

  • To customise the website for you.
  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
  • To administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • To make the site easier to visit again and more useful to you through the use of cookies.

 

 6. Why we share your information

We may share your information with third parties in the following scenarios:

  • To provide goods or services to fulfil contractual obligations, for example, with transport, shipping or payment service providers.
  • If we are obliged to do so by law, by court order or due to an enforceable official order.
  • To enable other companies within the Reconomy Group to fulfil contractual obligations or provide information to you about similar products or services which you have requested, or which we think may be relevant for you, we will share your information with other companies within the Reconomy Group.
  • To provide you, or permit carefully selected third parties to provide you, by telephone, post or email, with information about other goods and services that are similar to those that you have already purchased or enquired about.
  • To provide you with targeted information about services or products, so you get relevant messages from us.

In the event that we transfer your personal data to a data processor, we will ensure that a data processing agreement (DPA) is in place.

 

 7. Lawful basis for processing

Under Data Protection Laws, the lawful bases we rely on for processing this information are:

  • We have a contractual obligation: We process your personal data to fulfil contractual obligations.
  • We have a legal obligation: We are obligated to retain certain information due to legal requirements, such as for tax and business regulations.
  • We have a legitimate interest.
    The legitimate interests can be our own interests or the interests of third parties. When necessary, we will conduct a Legitimate Interests Assessment, in order to consider the impact that any processing activities could have on individuals, including in the following scenarios:

    • Promotion of our offers and services;
    • Analysis of the use of our website;
    • Social media engagement analysis;
    • Ensuring the confidentiality and integrity of our IT systems; and
    • Cooperation with authorities.
  • You have given consent.
    If you have given us explicit consent to process your personal data, we will process it within that scope and based on your consent. Your consent might refer to, for example, sending a newsletter. You can remove your consent at any time. You can do this by contacting info@combineering.dk.

 

8. How we store your Personal Information

We have implemented appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, unauthorised change or damage. All personal data we collect will be stored on our secure servers. All electronic transactions entered into via our website will be protected by SSL encryption technology.

We will store your personal information for as long as necessary to fulfil the purposes for which we collect the personal data, in accordance with our legal obligations and legitimate business interests.

We may retain any personal data to investigate or defend claims against us, or to prosecute or bring claims against you, us or any third party.

 

9. Your Data Protection Rights

Under Data Protection Laws, you have the following rights:

  • Right of access: You have the right to ask us for copies of your personal information.
  • Right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Right to erasure: You have the right to ask us to erase your personal information in certain circumstances, for example when the organisation no longer needs it for the original reason it was collected, or the organisation has collected or used your data unlawfully.
  • Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances, for example the organisation no longer needs your personal data, but you want the organisation to keep it in order to create, exercise or defend a legal claim.
  • Right to object to processing: You have the the right to object to the processing of your personal information in certain circumstances.
  • Right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You can exercise your rights at any time by emailing us

at info@combineering.dk however there are certain circumstances when a request may be refused, for example when it is manifestly unfounded or excessive, for example when:

  • The individual clearly has no intention to exercise their right of access.
  • The request is malicious in intent and is being used to harass an organisation with no real purpose other than to cause disruption.
  • The request is clearly or obviously unreasonable.; the request should be proportionate when balanced with the burden or costs involved in dealing with the request.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

 

10. EU & UK Representation

Where a UK-established Reconomy entity is processing and monitoring the personal data of individuals in the EU, and is required by Data Protection Laws to designate an EU Representative, the following person is hereby appointed:

Managing Director
Cycleon B.V.
Vliegend Hertlaan 71 14e etage
3526 KT Utrecht
Netherlands

Tel: +31 30 299 5500

Where an EU-established Reconomy entity is processing and monitoring the personal data of individuals in the UK, and is required by Data Protection Laws to designate a UK Representative, the following person is hereby appointed:

Company Secretary
Reconomy (UK) Limited
Kelsall House
Stafford Court
Stafford Park 1
Telford
Shropshire TF3 3BD
UK

Tel: 0800 988 5618
Email: gdpr@reconomy.com

 

11. Use of Cookies

This website uses cookies.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make a user’s experience more efficient, as well as to provide information to the owners of the site. You can find more information about cookies at: www.allaboutcookies.org, www.youronlinechoices.eu and for a video about cookies visit policies.google.com/technologies/cookies.

We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website. If you have any issues regarding your consent, email us at info@combineering.dk.

The cookies used on our website have been categorised as follows, unless otherwise stated data is processed on the basis of Art. 6 Para. 1.1 GDPR.

Category 1: Necessary

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Category 2: Statistics

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Category 3: Preferences

Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

Category 4: Marketing

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. The legal basis for the processing of personal data in connection with Targeting Cookies or Advertising Cookies (if any) is Art. 6 Para. 1.1 GDPR.

Category 5: Unclassified

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

 

12. Cookies we use and why

 

13. Lodging a Complaint

If you are dissatisfied with our actions and wish to make a complaint, this should be made in writing to info@combineering.dk or sent to the following address:

Reconomy (UK) Ltd
Kelsall House Stafford Court
Stafford Park 1
Telford
Shropshire
TF3 3BD

You also have the right to lodge a complaint with your local Supervisory Authority (“SA”) if you are unhappy with how we have used your data. A list of EU SAs is maintained by the European

Data Protection Board (EDPB) and can be accessed here.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113 or 01625 545 745 or email: enquiries@ico.org.uk
ICO website: https://www.ico.org.uk

 

14. Changes to our Privacy Notice & Cookie Policy

Any changes we make to our Privacy Notice & Cookie Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes.