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Privatlivspolitik

1.
INTRODUCTION
Privacy and data protection are important to CO:PLAY (“CO:PLAY”, “we” or “us”), and in this Privacy Policy, we will explain how we process personal data concerning our clients, users of CO:SPACE, Persons to whom the clients’ matters pertain to and recipients of our newsletter. If you are neither a client to CO:PLAY or have dealings with one of CO:PLAY’s clients, you may find information about how we processes personal data for other, non-client related, activities in connection to where this Privacy Policy is available. When we process personal data, CO:PLAY is, in most situations, a personal data controller, which means that we are determining the purposes and means for processing the personal data, and consequently bears the responsibility under applicable data protection laws. 
2.
CONTACT INFORMATION TO CO:PLAY  
CO:PLAY
ADVOKATPARTNERSELSKAB
CVR-nr. 41110546 
Phone +45 7027 8899 
Email gdpr@coplay.law 
Address Strandvejen 58, 1. 2900 Hellerup Denmark
3.
THE PERSONAL DATA WE PROCESS 
In the table below, we set out what types of personal data we process, the purposes for doing so, and the legal grounds upon which we base the processing. 
PERSONAL DATA 
PURPOSE 
LEGAL GROUND 
Contact information:
‍
- Full name
- Email address 
Purpose (1):
registering companies as clients and contact persons at the client company. The contact persons may vary from matter to matter.

Purpose (2):
registering natural persons as clients.

Purpose (3):
invoicing clients. Purpose (4): complying with bookkeeping legislation. 
Legal ground (1, 2, 3):
fulfilment of a contractual obligation.

Legal ground (3, 4):
complying with a legal obligation. 
Contact information:
‍
- Full name
- Email address
- Street address
- Personal identification number 
 
Purpose (1):
to carry out controls to ensure that there is no conflict of interest. 

Purpose (2):
invoicing clients. 

Purpose (3):
complying with bookkeeping legislation.
Legal ground (1):
the processing is a necessary step to take in order to enter into a contract, which the person has requested.

Legal ground (2):
fulfilment of a contractual obligation.

Legal ground (3):
complying with a legal obligation. 

Anti-money laundering (AML) information:

- A copy of the passport, or another similar document that can be used for identification.
- An assessment if the person is a politically exposed person. 
Purpose:
‍
complying with AML legislation. 
Legal ground:
‍
complying with a legal obligation. 

Information for CO:SPACE profiles: 
- Full name
- Email address
- Company
‍
Optional information:
- Profile picture, title, department, office address, office phone, mobile phone, secretary (name and e-mail), biography, specialities, experience, social media, messaging, links. 

Purpose (1):
setting up personal profiles in our digital tool CO:SPACE to clients.

Purpose (2):
(a) administrate users of CO:SPACE,
(b) enable the provision of CO:SPACE, and
(c) authorise and monitor access of files and content CO:SPACE. 
Legal ground (1):
fulfilment of a contractual obligation.

Legal ground (2):
The processing is based on CO:PLAYS’s legitimate interests. The legitimate interest of CO:PLAY is to provide CO:SPACE to our clients as part of CO:PLAY’s activities as a law firm, and the assignments for which the client has engaged CO:PLAY. It is necessary for the identity of the users of CO:SPACE can be verified. 
Newsletter:
- Full name
- Email address
- The company you work at or represent - Title 
Purpose:
to sent you emails regarding legal news and invitations to events held by CO:PLAY. You have given us your consent to provide marketing from us by signing up for our newsletter on our website. 
Legal ground:
consent. 
Registration to events:
- Full name
- Email address
- The company you work at or represent - Title 

Purpose (1):
to record your attendance.

Purpose (2):
to send you emails regarding the event you are attending. 
Legal ground:
by attending an event, you accept our processing of your personal data for our fulfilment of the contractual obligation. 
Contact information:
- Full name
- Email address 

Purpose:
to help you when you ask us for things, such as if you want to borrow a conference room or want us to send you a presentation that we have held. 
Legal ground:
the processing is necessary for the legitimate interest of the client or person to whom we want to deliver a service. 
Information in connection with legal matters:
‍
given the nature of a law firm’s daily activities, it is not possible to provide an exhaustive list of types of personal data that will be processed. The below list is intended as an example:

- Contact information
- Meeting notes, and other notes
- Mentions of persons in documents that CO:PLAY drafts
- Additional information that is required when handling the client’s case - Your vehicle’s registration number when you visit us and need to use our parker lots
Purpose:
to handle the client’s matter according to the client’s instructions and in accordance with the ethics rules provided by the Danish Bar and Law Society.
Legal ground can be one or more of the following (regular personal data): Legal ground:
‍
The processing is a necessary step to take in order to enter into a contract, which the person has requested;

‍Legal ground:
‍
Fulfilment of a contractual obligation;

‍Legal ground:
‍
The processing is necessary in order to protect the vital interests of the client;

‍Legal ground:
‍
Complying with a legal obligation;

‍Legal ground: The processing is necessary for the purpose of the legitimate interest of the client (legitimate interests could be e.g. debt collection, establishing of rights etc.)

‍Legal ground (special categories of personal data, and personal data relating to criminal convictions and offences):

Legal ground:
‍
CO:PLAY will process the aforementioned categories of personal data when doing so is necessary for the establishment, exercise or defence of legal claims. 
We cannot provide our services to our clients unless the contact information and AML information are provided to CO:PLAY. Regarding the registration to our events, it is most likely that you have provided us with this information yourself, but it is also possible that a colleague of yours has given us your contact information. You have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the Processing based on the consent before its withdrawal, and in some cases, we may continue processing your Personal Data based on other legal grounds, except for direct marketing. If you object to the Processing of your Personal Data conducted on the basis of our legitimate interests, we may cease processing your data for those purposes. 
4.
RECIPIENTS OF PERSONAL DATA, AND TRANSFERS OF PERSONAL DATA 
The personal data may be transferred to the following categories of recipients:

- Courts, and similar judicial entities;

- Recipients whom CO:PLAY has been directed by the client to transfer information to;

- Public authorities, such as “SKAT” (the Danish tax authorities) and the State Prosecutor for Serious Economic and International Crime;

- Companies that provide services upon which CO:PLAY relies for its core activities (such as data management services, digital infrastructure and other service providers). 
‍
CO:PLAY does not transfer personal data to countries outside of the EU/EEA unless this is necessary to carry out the assignment given by a client. If this is the case, and there is no decision from the European Commission that the country which the personal data will be transferred to provides adequate data protection legislation to ensure the safety of the personal data, CO:PLAY will use relevant safeguards to ensure the safety of the personal data. If you want to know more about the safeguards we may use, please contact us. 
5.
ENCRYPTION
CO:PLAY uses encryption to the extent necessary. If we transfer sensitive personal data or confidential information, we will use encryption in the transport layer as a starting point. If, given the circumstances of a specific transfer, we find that encryption is also required in the data layer, we will contact you to agree on how the transfer will be done. If you wish to transfer personal data to us encrypted in both the transport and data layer, please contact us before the transferring. 
6.
STORAGE AND DELETION OF PERSONAL DATA 
CO:PLAY stores all client related information, and personal data therein, for as long as there are legitimate purposes. There is no general duration of this storage, but we base our assessment on i.a. the guidance from the Danish Bar and Law Society about this issue, which as a main rule can entail storage for up to ten (10) years, after completion of the relevant assignment.

Personal data collected only within the purpose of sending marketing to you will be stored up to two (2) years after we have used the personal data in accordance with this purpose unless we have other legitimate purposes.

CO:PLAY uses professional services to destroy physical documents that ensure the integrity and confidentiality of the information contained in the documents. For handling digital information, we use professional service providers that are specialised in accommodating the needs for digital integrity and confidentiality. 
7.
YOUR RIGHTS
CO:PLAY is a law firm and is as such subject to rules of professional secrecy. This means that CO:PLAY as the main rule is not allowed to disclose information relating to the clients’ matters to anyone but the client.

The rights that a person has in regards of their personal data which is being processed by CO:PLAY are not absolute, meaning that certain criteria must be at hand for the right to be exercised. Also, there are exceptions to some of the rights. CO:PLAY will accommodate requests to the extent that we are obliged under data protection laws.

A person has the following rights regarding personal data concerning them:

- Access: meaning that you have the right to information about the processing, access to the personal data in question, and the right to obtain a copy of your personal data.

- Rectification: meaning that CO:PLAY must correct the personal data if it is incorrect.

- Erasure: meaning that CO:PLAY must erase the personal data in certain circumstances, such as if there is no purpose for processing it any longer.

- Object to processing: meaning that you have a right to object to CO:PLAY’s processing of personal data, for example, if we are marketing ourselves directly to you, we must stop doing so if you object to it.

- Restriction of the processing: meaning the right to have CO:PLAY restrict the processing of personal data, but not delete it.

- Data portability: meaning that if you want CO:PLAY to transfer the personal data to another personal data controller, we can help accommodate this request.
‍
Also, you have the right to lodge a complaint at the supervisory authority, if you believe that CO:PLAY’s processing of personal data infringes applicable data protection laws. The supervisory authority in Denmark is Datatilsynet. If you are not based in Denmark, you may contact the supervisory authority that is relevant to you. 

NEWBANKING IDENTITY
We use NewBanking Identity as a third party service provider of a solution to store your personal information. All data is stored while encrypted and cannot be accessed or processed by anyone other than those you explicitly give permission to access your data. You can administer the information you share when you are using NewBanking by logging into your account here.

You can also download the information associated with your NewBanking account through www.NewBanking.com. Here you can read NewBankings Privacy Policy
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