Commencement 20-08-2018This Data Protection and Privacy Policy (the
'Policy') describes how CompanYoung A/S
(
'us',
'we' or
'our') If you are a visitor to a CompanYoung Website, or a customer's use of CompanYoung Services, or a direct user of a service then you must accept that the
following privacy policy presented in this document includes your use of any
CompanYoung website or service.
At CompanYoung, we respect our customers’ and users’ privacy and we recognize the
importance of policies that protect the personal information we process about you.
Our privacy policies are designed to help you understand what information we collect
about you, how we use it, and who it is shared with. This privacy policy covers all our
websites and services.
In this Privacy Policy 'Websites' refers to CompanYoung websites (including, but not
limited to www.companyoung.com, companyoung.dk, youngcrm-platform.com,
elevplads.dk and any further URLs, mobile or localized versions and related domains
and subdomains), and 'Services' means CompanYoung’s proprietary systems, its user
interface and business interface (including, but not limited to YoungCRM.com,
CYJobAPI.com and any further URLs, mobile or localized versions and related domains
and subdomains) in each case regardless of format, they can be provided in now or in
the future. Websites and services are collectively referred to herein as 'services'.
The Policy is prepared and made available to comply with the General Data Protection
Regulation (2016/679 of 27 April 2016) (the 'GDPR') and the rules included herein on
information to be provided to you.
2. Collecting personal data with cookies
By visiting and using our website(s), personal data collected with cookies will be processed. Information about this processing can be accessed here:https://companyoung.com/om-os/cookiepolitik/
3. Types of personal data processed
We process personal data about you when this is necessary and in accordance with the
applicable legislation. Depending on the specific circumstances, the processed
personal data include the following types of personal data:
- a) IP addresses
- b) telephone number
- c) email
- d) name
- e) address
- f) payment card details
- g) age
- h) National identification number
- i) password
Registration and contact information: We collect information about you when you (a) si
gn up to use one of our services or (b) otherwise disclose contact information to us via
email, forms or other services. The information you provide includes, but is not limited
to, first and last name, email address, address and telephone number, IP and other rel
evant information you give us.
Payment Information: When you purchase services from CompanYoung, we also collec
t transaction information, which may include your credit card information, billing and p
ostal address and other payment-related information (“Payment Information”). When y
ou make a purchase in our services, all credit card information you provide as part of y
our payment information is collected and processed by our payment processor Stripe t
hrough their Stripe Checkout service. We never receive or store your full credit card inf
ormation. Stripe undertakes to comply with the Payment Card Industry Data Security St
andard (PCI DSS) and to use industry standard security measures. Stripe can use your
payment information in accordance with their own privacy policies here: https: //strip
e.com/us/checkout/legal.
Technical, Usage and Location Information: We automatically collect information about
how you interact with the services: for example, the IP address from which you access t
he service, the date and time, information about your browser, operating system and c
omputer or device, pages that are shown and elements clicked. We may also collect loc
ation information including location information that is automatically provided by your
computer or device. We use cookies and similar technologies to collect some of this inf
ormation. For more information, see CompanYoung’s Cookie Policy, which is located at
the bottom of all websites or click the link above.
Profile Information: We collect all the information you put into your profile: including, b
ut not limited to demographic information, quiz results, work experience, education an
d CV, as well as other relevant information.
When relevant, personal data is collected directly from you or from external sources. W
e may collect information when you interact with our ads and other content on third p
arty websites or platforms: for example, social networking sites. This can include infor
mation such as "Likes", profile information gathered from social networking sites or th
e fact that you have seen or interacted with our content. This collection is based on a c
onsent required by 3rd-party platforms, or a consent given to it (see our website’s use
of cookies).
If we need to collect more personal data than specified above, we will inform you by
updating this Policy
4. Purposes of processing the personal data
We will only process your personal data if we have a legitimate purpose and in that
case in accordance with the rules of the GDPR. The personal data we collect about you
is processed for the following purposes:
- a) To deliver products or services.
- b) To improve our products, services, or website.
- c) To provide service messages and information.
- d) To respond to inquiries or complaints.
- e) To provide support and service messages, including responding to questions and complaints and sending updates about our products and services.
- f) To send newsletters and direct marketing (such as e-mails, MMS', direct messages on social media, etc.)
- g) To store personal data to comply with applicable legislation requirements such as
bookkeeping acts.
In addition to the above, we also process for the following purpose(s): We use your info
rmation for the following purposes:
1. To provide, maintain and improve services and our other products, including improvi
ng certain features and functionalities in our services (e.g. by remembering your infor
mation so you will not have to enter it again during this or a subsequent visit);
2. To process with your inquiries and otherwise provide customer service;
3. To process your payments, we share and use payment information as described abo
ve
4. In order to control unauthorized use or misuse of the services or otherwise detect, in
vestigate or prevent activities that may be unlawful or otherwise violate our policies;
5. To analyse trends, administer or optimize services, monitoring of use or traffic patter
ns (including tracking users' movements around the service) and gather demographic i
nformation about our user base as a whole;
6. To communicate directly with you, including sending you newsletters, promotions an
d special offers or information about new products and services. Your opt-out options f
or advertising communication are described in Section 7 (Erasure and retention of pers
onal data);
7. To provide advertising for you, including showing and managing ads on the services
or on 3rd-party websites and to customise ads based on your interests and browsing hi
story. Please see Section 7 for details on how you manage the ads you see;
8. To match you with relevant job openings and opportunities, and contact you if appro
priate.
9. To allow employers to get in touch with you about career opportunities if they find y
our CV relevant.
10. To recommend appropriate career opportunities.
11. To improve our recommendations and matching tools.
5. Legal basis for processing personal data
We only process your personal data when we have a legal basis to do so in accordance
with the GDPR. Depending on the specific circumstances, the processing of personal
data is done on the following legal basis:
a) The processing is necessary for the performance of a contract to which the data
subject is a party in accordance with GDPR, Article 6(1)(b), the first indent.
b) The processing is necessary in order to take steps at the request of the data
subject prior to entering into a contract in accordance with GDPR, Article 6(1)(b),
last indent.
c) The processing is necessary to comply with applicable legislation in accordance
with GDPR, Article 6(1)(c).
d) The processing is necessary for the purposes of the legitimate interests where
such interests are not overridden by the interests or fundamental rights and
freedoms of the data subject which require protection of personal data in
accordance with GDPR, Article 6(1)(f).
If we send you direct marketing, including by email, we will ask for your prior consent
in accordance with the applicable rules such as marketing acts.
6. Disclosure and transfer of personal data
We only transfer personal data to other entities when legally permitted or required.
Our organization is part of a concern or a group of companies where, depending on
the circumstances, personal data is shared.
We transfer personal data to the following recipients from the EU/EEA:
a) Processors
b) Suppliers
We do not sell, trade, share or transfer your personal information to third parties
except in the following limited circumstances:
We may share your personal information with our parent, subsidiary and affiliated
companies, if this is necessary to achieve an agreement between us and the customer;
We may share your personal information with 3rd-party service providers to enable
such parties to provide services that help us with our business activities, which can
help us, for example, with marketing, advertising for our products/services, or
providing, maintaining and improving the features and functionalities of the services.
For example, we may provide our service providers with personal information for
direct mailing of our newsletters or announcements about our product/services;
We may share your personal information when in good faith we are certain that
access, use, retention or disclosure of such information is necessary to (a) satisfy any
applicable law, regulation, legal processes or requests from the government or other
state authorities, (b) enforce a customer agreement, including investigation of potential
violations hereof, or (c) protect against imminent threat of harm to our, our users’ or
the public’s rights, property or security as required by applicable laws;
We may share your personal information with third parties (including our service
providers and government agencies) to detect, prevent or otherwise address fraud,
security or technical issues;
We may share your personal information with our partners, who offer a service to you
jointly with us: for example, when we are running a cross-promotion;
We may share your payment information to process your payments;
We may share and/or transfer your personal information if we are involved in merger,
acquisition, bankruptcy or any form of sale of some or all of our assets;
We may share your personal information with a third party if we have your consent to
do so.
We may share your personal information with potential and interested employers, if
they are considering offering you a career opportunity, but only if you have given us
permission to do so. This can always be changed in the settings of the particular
CompanYoung service you use;
We may also share aggregate or anonymized information with third parties for other
purposes. Such information does not identify you individually but may include use,
display and technical information such as the types of offers our customers and users
in general use, the configuration of their computers and performance statistics
associated with the use of services that we gathered through our technology. If we are
required by applicable law to treat such information as personal information, we will
only disclose it as described above. If a piece of information cannot be classified as
personal data by law, we can process and forward such information for any other
reason.
From time to time we use external companies as suppliers to assist us in delivering our
services. The external suppliers will not receive or process personal data unless the ap
plicable law allows for such transfer and processing. Where the external parties are dat
a processors, the processing is always performed on the basis of a data processor agre
ement in accordance with the requirements hereto under GDPR. Where the external p
arties are data controllers, the processing of personal data will be performed based on
said external parties’ own data privacy policy and legal basis which the external parties
are obligated to inform about unless the applicable legislation allows otherwise.
We transfer personal data to countries or international organisations outside the EU/
EEA. Personal data is transferred to the following countries not subject to an article 45
adequacy decision: USA
We only use subcontractors with headquarters in the USA if they appear on the "data p
rivacy framework list". All our subcontractors have data centers in the EU, which we us
e. We do not have data centers located in the United States..
Such transfers are based on the standard contractual clauses about data protection m
ade or approved by the EU Commission and possibly approved by a national data prot
ection agency, ensuring a sufficient level of protection.
If you have any questions about our use of processors, cooperation with other
controllers, including our subsidiaries, or the transfer of data to third countries, you
may contact us for more information or documentation of our legal basis for such
transfers.
7. Erasure and retention of personal data
In general, we strive to always ensure that personal data is deleted as soon as it is no l
onger necessary for the processing purposes described above. Personal data collected
and kept to comply with the Danish Bookkeeping Act is kept for 5 years after the accou
nting year in which the data was collected. Personal data about commercial customers
is kept for as long as the customer relationship is active and the data is relevant to ope
rate the customer relationship and ensure contractual performance of our obligations.
If you are not part of an organization that is customer with us, personal data about you
processed in our CRM system (where you may be saved as a "contact" if you have enga
ged in our marketing offerings) are erased after 12 months of inactivity. If you have any
questions about our retention of personal data, please contact us via the e-mail addres
s mentioned in the last section of this Policy.
Opting Out:
When we ask for specific information, we give you the option of refusing to have your p
ersonal information used for certain purposes. If you decide to opt out, we cannot prov
ide certain features of the service to you.
Communication Settings:
If you no longer wish to receive our newsletter or advertising, you can opt out of receivi
ng them by following the instructions in such communications or in the services thems
elves. However, note that you may not opt out of certain service-related communicatio
ns. Contact legal@companyoung.com if you have doubts.
Blocking Cookies:
You can remove or block specific cookies using the settings in your browser, but the se
rvices cease to function properly if you do so. For more information, see CompanYoun
g’s Cookie Policy, which is located at the bottom of all websites.
How We Respond to ‘Do Not Track’ Signals:
Your browser may have a ‘Do Not Track’ setting, which, when activated, causes your br
owser to send a you may not track HTTP header file or ‘signal’ to each site you visit. At
present, the website reacts to this signal, but not our other services. There are a numb
er of features that are necessary for the functionality of our services that prevent the u
se of ‘Do Not Track’ signals.
8. Data subject rights
As a data subject under GDPR, you have a number of rights.
- 8.1.1 You have the right to request access to the personal data we process about you,
the purposes we process the personal data, and whether we disclose or transfer
your personal data to others.
- 8.1.2 You have the right to have incorrect information rectified.
- 8.1.3 You have the right to have certain personal data deleted.
- 8.1.4 You may have the right to restriction of our processing of your personal data.
- 8.1.5 You may have the right to object to our processing of your personal data based
on reasons and circumstances that pertain to your particular situation. Objection
can also be to the processing of personal data for the purpose of direct
marketing.
- 8.1.6 You have the right not to be subject to a decision based solely on automated
means, without human interference unless the decision (1) is necessary for
entering into, or performance of a contract between you and the Organization,
(2) is authorised by law, or (3) is based on your explicit consent.
- 8.1.7 If the processing of your personal data is based on your consent, you are
entitled to withdraw such consent at any time. Withdrawal of your consent will
not affect the lawfulness of the processing carried out prior to your withdrawal.
- 8.1.8 You are entitled to receive personal data which you have provided to us in a
structured, commonly used, and machine-readable format (data portability).
- 8.1.9 You can always lodge a complaint with the data protection authority.
Your rights may be subject to conditions or restrictions. Accordingly, there is no
certainty that you will be entitled to for example data portability in the specific
situation; it will depend on the circumstances of the processing.
More information about data subject rights can be found in the guidelines of the
national data protection authorities.
Please use the contact details below if you want to use your rights.
We try to meet your wishes about our processing of personal data, but you can always
file a complaint to the data protection authorities.
9. Changes to this Policy
We reserve the right to update and amend this Policy. If we do, we correct the date and
the version at the top of this Policy. If we make significant changes, we will provide
notification by way of a visible notice, for example on our website or by direct
message.
10. Contact
You may contact us at the below specified email if you:
a) disagree with our processing or consider our processingof your personal data
infringeson the law,
b) havequestions or comments to this Policy, or
c) want toinvoke one or more of your rights as a data subject described in this Policy.
If you have questions or comments to this Policy or if you would like to invoke one or
more data subject rights, please contact us at legal@companyoung.com.