Privacy Policy

Introduction

Source2Sea A/S respect your privacy and the personal data we are provided in the course of operating our business.

This policy accounts for the personal data that we receive about you via our website and sub domains, in commercial contexts, e.g. from email correspondence and in relation to recruitment.

The personal data processed and how we use it when you visit our websites and sub domains

‍

Purposes

We use cookies to improve your user experience and the functionality of our website, to compile statistics, to target advertisements to your needs, and to remember your preferences. You can read more about our use of cookies in our cookie policy below.

Categories of personal data we process

• Consent status
• Consent ID
• The type of device you use to access our websites
• The operating system and version
• Your IP address
• Your general geographic location as indicated by your IP address
• Your browser type
• The content you view
• Time stamp

Legal basis

Processing of technically necessary cookies is necessary for us to provide the core functionalities of our website, and our legal basis for this processing is our legitimate interests in providing a technically well-functioning website, cf. GDPR art. 6(1)(f).

Our legal basis for processing of functionality, statistical, and marketing cookies is your consent, cf. GDPR art. 6(1)(a). You may at any time withdraw your consent, which you can do via the cookie banner on our websites and in your browser settings.

Storage period

Personal data collected via cookies during visits to our websites are stored for different periods of time depending on the type and purpose of the cookie. For details, see the cookie declaration in the cookie banner on our websites.

Commercial, incl. email correspondence with contacts at users

Purposes

We will process personal data about you i) when you communicate with us in the context of our contractual relationship with the company you are employed at, e.g. in relation to feedback, complaints and comments from you via the application, or records of any online, paper or in-person correspondence and interactions between us, ii) in the context of the conclusion or termination of a contract, and/or iii) when we maintain and update our list of contact persons and contact details and/or customer relation management system information.

Categories of personal data we process

• Your name
• Email address
• Job title and company you are employed at
• Phone number used to call us (if you have communicated with us by phone)

Legal basis

The legal basis for the processing of your personal data is our legitimate interests, which, in our view, are not overridden by your fundamental rights and freedoms as provided in GDPR art. 6(1)(f). The legitimate interests pursued by us are the performance of our contractual obligations, the making, maintenance, and strengthening of our customer relationships, the invoicing of the services provided by us to the company you are employed at, and documentation purposes where an agreement is concluded by email.

In certain cases, the processing of your personal data is necessary to comply with a legal obligation imposed on us, for example in connection with the storage of bookkeeping materials. In such cases, the legal basis is GDPR art. 6(1)(c).

Storage period

Generally, we retain your personal data until we receive information that you are no longer affiliated with our customer or vendor. If your personal data is part of contract materials or correspondence material to the contract, we retain this information for up to five years after the relevant contract or order terminates or expires. Personal data in bookkeeping materials such as invoices is retained for five years from the end of the financial year to which the material relates.

Recruitment

Purposes

The purpose of the processing is recruitment, i.e. hiring of new employees and ensuring that we find suitable candidates for the positions in question.

Categories of personal data we process

• Your name
• Email address
• Application
• CV
• Transcripts and attachments
• Information from your LinkedIn profile
• Possibly references from previous employers

Please do not provide us with any sensitive personal data, e.g. information on your health, political views etc.

Legal basis

We process the personal data for recruitment purposes to pursue our legitimate interests, such as administration of recruitment process and evaluation of the job applicants, including to hire the most suitable candidate for the specific position, cf. GDPR art. 6(1)(f). If you are chosen for one of our vacancies, processing will also be necessary in order to take steps at your request prior to entering into an employment contract and the processing of your personal data is based on GDPR art. 6(1)(b).

Storage period

We will delete your personal data as soon as possible but may keep records of the recruitment process for up to six months after a completed recruitment process to respond to and defend against potential legal claims.

Sources of personal data

We collect much of the personal data that we hold about you directly from you or your interactions with us and our application. We may also receive your personal data from other sources, including business partners, sub-contractors in technical, payment and delivery services, social media, advertising networks, analytics providers, and search information providers.

Recipients of personal data and data transfers

Your personal data may be shared with business partners and other third parties which we are not affiliated with for business purposes, such as social media providers and public authorities.

Your personal data may also be shared with certain third parties acting as our data processors, when they process personal data under our instruction and on our behalf. This is for example the provider of the technical solution behind our websites, Microsoft which we use for emails, and our newsletter service provider.

In certain cases, your personal data is transferred to countries outside the EU/EEA. Transfers to so-called insecure third countries can be made based on different transfer tools, whereby a mechanism has been established to ensure adequate protection of the rights of the data subjects, such as the European Commission's Standard Contractual Clauses (SCCs) with the recipient and the EU–U.S. Data Privacy Framework. For further information on transfer tool, including copy, please contact us at legal@wrist.com.

Protection and storage

Emails are stored in Microsoft Outlook on our own servers. Personal data may be transferred to our CRM system, ERP system, or other systems protected by appropriate organizational and technical security measures such as access control, anti-virus software and firewalls.

We have taken reasonable measures to ensure deletion or anonymization of your personal data when it is no longer needed for the purposes for which it was collected and subsequently processed.

Rights

In accordance with the GDPR, you have a number of data subject rights:

• The right to request access to your personal data (GDPR, art. 15)
• Rectification of your personal data (GDPR, art. 16)
• Erasure of your personal data (GDPR, art. 17)
• Limitation of the processing of your personal data (GDPR, art. 18)
• Data portability (GDPR, art. 20)
• The right to object to the processing of your personal data (GDPR, art. 21)

If you wish to exercise your rights, please contact us at legal@wrist.com.

If you want to file a complaint regarding our processing of your personal data, you can contact the Danish Data Protection Agency (contact information available here).