This privacy policy explains how Interfocus (“we”, “us” or “our”) collects and processes your personal data in connection with our training and coaching services, or if you are a blogger on our website.
DATA CONTROLLER CONTACT INFORMATION
The legal entity responsible for the processing of your personal data is:
Interfocus
CVR no: 43470027
Ringkobingvej 3, 5. 1
DK-8000 Aarhus C
Denmark
If you have inquiries and/or questions to our processing of your personal data, please contact us at:
info@interfocus.dk
CATEGORIES OF PERSONAL DATA WE MAY PROCESS
Depending on the information available about you, we may collect and process the following categories of personal data about you:
| Category of personal data collected | What this means |
|---|---|
| Students | – Private contact details (name, home address, email, private phone number etc.). – Date of birth – Nationality – Educational background – National Identification Number |
| Coachee | – Private contact details (name, home address, email, private phone number etc.). – Psychological profile – National Identification Number |
| Bloggers | – Private contact details (name, home address, email, private phone number etc.). – Blogging experience |
SOURCES OF YOUR PERSONAL DATA
We collect and process personal data that you have provided in communications with us, including via email or phone. In addition, we may collect and process personal data from:
- Current/former place of work or place of education (references)
- Other relevant third parties
PURPOSE AND LEGAL BASIS FOR OUR PROCESSING
In the following we have described the purposes and legal bases for our processing of your personal data:
| Purpose | Categories of personal data | Our legal basis for processing this data |
| Carrying out training | Non-sensitive personal data | Performance of or entering into a contract (GDPR Article 6(1)(b)) Legal obligation (GDPR Article 6(1)(c)) Our or a third party’s legitimate interests (GDPR Article 6(1)(f)) |
| Sharing course data with Fundación estatal para la formación en el empleo | Non-sensitive personal data | Legal obligation (GDPR Article 6(1)(c)) Our or a third party’s legitimate interests (GDPR Article 6(1)(f) |
| Coaching | Non-sensitive personal data | Performance of or entering into a contract (GDPR Article 6(1)(b)) Our or a third party’s legitimate interests (GDPR Article 6(1)(f)) |
| Sensitive personal data (psychological test) | Consent (GDPR Article 9(2)(a)) | |
| Bloggers | Non-sensitive personal data | Performance of or entering into a contract (GDPR Article 6(1)(b)) Our or a third party’s legitimate interests (GDPR Article 6(1)(f)) |
SHARING OF YOUR PERSONAL DATA
We may share your personal data with the following recipients:
- Your employer(s)
- Fundación estatal para la formación en el empleo External teachers
- LearnDash (the Learning Management System)
- Data processors, including website providers, IT security provider
TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA and Switzerland
As a starting point, your personal data will only be processed and stored within the EU, namely in Denmark and Spain, unless otherwise stated.
To the extent your personal data is transferred to countries outside the EU/EEA, we will only transfer the personal data after having provided one of the following safeguards:
- Adequacy decision by the EU Commission.
- EU Commission’s Standard Contractual Clauses
In some cases, we may rely on your consent for the transfer of your personal data to countries outside the EU, or if one of the limited and relevant exceptions third country transfers in the GDPR apply. You can contact us for more information on the relevant safeguards or legal basis.
How long will we STORE YOUR PERSONAL Data
We will not store your personal data for longer than necessary.
To the extent that personal data is included in accounting material, the personal data will be stored for 5 years calculated from the end of the year to which the accounting material relates to meet the requirements of the Danish Bookkeeping Act.
In all other cases, the personal data will be stored for 4 years.
YOUR RIGHTS
- Request access to and to receive a copy of your personal data.
- Right to have your personal data rectified.
- Right to have your personal data deleted.
- Right to have the processing of your personal data limited.
- Right to data portability.
- Right to object to the processing of your personal data.
- Right to not be subject to automated decision making, including profiling.
- Right to withdraw your consent.
- Right to complain to the relevant supervisory authorities.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us as provided for in Section 1.
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal data, please contact us as provided for in Section 1. We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, as listed here.
OBLIGATION TO PROVIDE PERSONAL DATA AND CONSEQUENCES FOR FAILING TO DO SO
You are not required to provide us with your personal data.
Where we need to process your personal data, either to comply with law or to perform the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to provide you with our services.
AUTOMATED DECISION-MAKING
Your personal data will not be used for automated decision-making.
CHANGES TO THIS PRIVACY POLICY
Changes to this privacy policy will be posted on our webpage.
We encourage you to visit our webpage regularly to keep yourselves updated on any such changes.
Last updated: 4 March 2024