Privacy and cookie policy

August, 2021

We take data protection seriously. We collect and process personal data, so we have drawn up this privacy policy to describe how we process personal data.

RGC Management A/S – c/o Rosengårdcentret (hereinafter referred to as “Rosengårdcentret”) is responsible for the data we collect about you, and we ensure that the personal data is collected and processed in accordance with the legislation from time to time in force.

You can read more about the types of personal data we collect, how we collect this, and the purpose of collecting it here in our general privacy and cookie policy.
In addition, you can read about your rights and other information we are required to give you.

If our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you choose to withdraw your consent, this will not affect the legality of our processing of your personal data on the basis of your previously communicated consent and up to the time of withdrawal. Therefore, any withdrawal of your consent will only take effect as of that time.

We collect personal data in different contexts and, therefore, for different purposes. You can read more below under each category.

Visitors to our website (cookie policy)

When you visit our website, we, and our partners, collect information about you and your device, which is used to recognise visitors and remember settings, prepare analyses, operate the website, customise and improve our content, features and ads to make this more personal and relevant to you. This is done using cookies or similar technology in our app.

Our partners may also use their cookies in anonymised format for analysis for their own purposes. You can read more about the different cookies at the bottom of the page.

We usually collect and process the following information:

  • Technical information about your computer, tablet or mobile phone, including which browser you are using
  • Your IP address
  • Geographical location
  • Pages you click on

We process the data in the light of our legitimate interest in measuring, adjusting and improving our content and functions, and in displaying non-personalised and non-targeted basic ads, as provided for in Article 6(1)(f) of the GDPR, and we collect and process data for personalised marketing on the basis of your consent, cf. Article 6(1)(a) of the GDPR.

Therefore, when you visit our website, you will be greeted by a pop-up message informing you of this. Here you have the option to consent to or opt out of cookie settings. You may withdraw your consent at any time, with future effect.

If you no longer want data to be collected and processed as above, you should change your cookie settings.

You can change or withdraw your consent at any time under cookie settings at the bottom of the page. You can read more about which cookies we use at the bottom of the page.
We store cookie data for different periods of time, depending on the type and purpose. You can see for how long, the purpose, and who sets cookies in the cookie history.

Facebook Messenger

We collect and process the following personal data after you sign up to receive push notifications through Facebook Messenger:

  • Name
  • Gender
  • Location and language

We will send push notifications and use your contact details based on your express consent, as provided for in Article 6(1)(a) of the GDPR and Section 10 of the Danish Marketing Practices Act. You have the right to withdraw your consent at any time and to opt out of our push notifications with future effect.

We also process personal data on the basis of a legitimate interest in processing your data regarding interests and behaviour in order to provide better content, and to improve general marketing; cf. Article 6(1)(f) of the GDPR.

We use this information in order to send you push notifications, to respond to your requests, to track the number of requests, to place general non-personalised and non-targeted marketing, and to improve our communication and analysis/statistics.

If you wish to withdraw your consent, please send us a message via Facebook Messenger containing the text “unsubscribe me now” or via our Messenger menu and “unsubscribe chat”. If you withdraw your consent, you will no longer receive push notifications. We will keep the necessary data to document your registration and consent for push notifications for 2 years after you opt out, to demonstrate and document that we issued push notifications lawfully in accordance with Article 6(1)(c) and Article 17(3)(e) of the GDPR and Section 93(1)(1) of the Danish Penal Code.

Newsletter recipients

We collect and process the following personal data when you sign up to receive our newsletters:

  • E-mail address

We will send newsletters and use your e-mail address based on your express consent, as provided for in Article 6(1)(a) of the GDPR and Section 10 of the Danish Marketing Practices Act. You have the right to withdraw your consent at any time and to opt out of our newsletters with future effect.

We also process personal data on the basis of a legitimate interest in processing your data regarding interests and behaviour (if you have opened the newsletter) for use in marketing; cf. Article 6(1)(f) of the GDPR.

We use this information to send you the newsletters, to track the number of signed-up recipients, for marketing, to improve our communications and for analysis/statistical purposes.
There is a direct link at the bottom of all newsletters to unsubscribe from the newsletter. If you unsubscribe from the newsletter, you will no longer receive the newsletter and we will delete your e-mail address from the contact list used to distribute the newsletters. We will keep the necessary data to document your registration and consent for the newsletter for 2 years after you opt out, to demonstrate and document that we distributed the newsletters lawfully in accordance with Article 6(1)(c) and Article 17(3)(e) of the GDPR and Section 93(1)(1) of the Danish Penal Code.

Competition entrants

Rosengårdcentret runs many competitions of various kinds. The competitions may be devised by us or in cooperation with the shops in Rosengårdcentret.

In connection with competitions, we collect and process the data you submit, or that is necessary to enter the competition. Usually, but not always, this will be:

  • Contact details
  • Age
  • Information mentioned in connection with the competition
  • Other information that you share in connection with your competition entry.

Please be aware that we may also collect and process other data in connection with competitions. You can read more about this under the relevant items, such as “visitors to our website (cookie policy)”, “newsletter recipients”, etc.

The purpose of collecting and processing data relevant to the competition varies according to the particular competition. We will use your contact details to identify you and contact you if you are the lucky winner. In addition, your name and address will be used to ensure that you participate only once, in accordance with our general competition rules, which you agree to by entering. Some competitions may also be associated with marketing purposes, in which case we may contact you for marketing purposes. You will always be required to give express consent to this before you enter the competition, and you will always have the option of withdrawing this consent.

We use your age to determine if you are entitled to enter the competition.

We collect and process this data based on your consent, as provided for in Article 6(1)(a) of the GDPR, the agreement you enter into with us in connection with a competition, including our general competition rules, as provided for in Article 6(1)(b) of the GDPR, and our legitimate interest in the collection and processing of the data for the relevant purpose, as provided for in Article 6(1)(f) of the GDPR; other lawful grounds for data collection and processing may also apply.

Where sensitive personal data is included in the data you provide, we will process this based on your express consent, where applicable combined with your own disclosure of the data, as provided for in Article (9)(1)(a) and (e) and Article (1)(6)(a) of the GDPR.

Competition winners will be contacted directly. Rosengårdcentret reserves the right to publish the winner of a competition or event in newsletters, on our website and on social media. As a competition entrant or event participant, you agree that Rosengårdcentret may display any images submitted/entered and your name, and that your name may be used for promotional purposes, which is also stated in the general competition rules you agree to by entering, in accordance with Article 6(1)(b) of the GDPR.

This personal data will be deleted when it is no longer necessary for the purposes of collection and processing.

If, in connection with a competition, you have agreed that we can contact you, for example for marketing purposes, we will keep the relevant data until you opt out of these communications. If you opt out of receiving our communications, we will no longer contact you and we will delete your contact details from our contact list.

We will keep the necessary data to document your registration and consent for 2 years after you opt out, to demonstrate and document that we distributed the newsletters lawfully in accordance with Article 6(1)(c) and Article 17(3)(e) of the GDPR and Section 93(1)(1) of the Danish Penal Code.

In connection with collecting and handing over any prize, you must bring valid photo ID, such as a passport or driver’s licence. Data from your photo ID that we do not already have will not be stored, as we only ask to see your ID to ensure that the prize is handed over to the legitimate winner and to prevent cheating.

Profile creation and use of the app

Rosengårdcentret collects only such personal data as is relevant and necessary for the various purposes described.

We collect and process the following personal data when you create a profile:

  • Name
  • Date of birth
  • Town and postalcode
  • Phonenumber
  • E-mail address
  • Location data (Bluetooth)

If you create a profile via Facebook, we also collect:

  • Profile picture
  • Facebook user ID

If you create a profile via Apple, we also collect:

  • Apple ID
  • Location data

If you create a profile via Google Apps, we also collect:

  • Google identifier
  • Location data

In accordance with your express consent, when you download our app and use it to create a profile, cf. Article 6(1)(a) of the GDPR, the following processing will also be carried out:

  • We provide you with content and special offers, including details of events, promotions and competitions from Rosengårdcentret and the stores you have selected in the app.
  • Segmented and targeted marketing based on your interests and behaviour in the app, as well as your physical movement inside Rosengårdcentret.
  • You can withdraw your consent at any time. Under your profile settings, you have the option to delete your profile. If you delete your profile, you will no longer be able to access the points you have earned. We will delete unnecessary data within 7 days. We will keep the necessary data to document your registration and consent to the app for 2 years after you opt out, to demonstrate and document that we communicated with you lawfully in accordance with Article 6(1)(c) and Article 17(3)(e) of the GDPR, cf. Section 93(1)(1) of the Danish Penal Code.

We process the data on the basis of our legitimate interest in measuring, adjusting and improving our content and functions, preparing analyses and displaying non-personalised and non-targeted basic ads/promotions/activities, as referred to in Article 6(1)(f).

If you enable Bluetooth, you collect points from selected and non-specified locations in Rosengårdcentret. We will process your data on the basis of the agreement you have entered into with us, cf. Art. 6(1)(b).

You can choose to stop sharing your location with Rosengårdcentret in your own phone settings.

When using the support feature of the app, we collect the following data:

  • Name
  • E-mail address
  • Location data
  • User ID

The data is used to help us deal with your requests and subsequent communications. We will process your data on the basis of the agreement you have entered into with us in accordance with Article 6(1)(b) of the GDPR. Your request and the data collected will be automatically deleted once your request is dealt with and no longer relevant.

Setting up and using guest Wi-Fi

Rosengårdcentret collects only such personal data as is relevant and necessary for our various purposes.

We collect and process the following personal data when you create a profile using the guest network:

  • Name
  • Date of birth
  • Postcode
  • Phonenumber
  • E-mail address
  • IP address
  • Browser history
  • Location data

If you create a profile via Apple, we also collect:

  • Apple ID

If you create a profile via Google Apps, we also collect:

  • Google identifier

When you download and create a profile for our guest Wi-Fi, we process your personal data in accordance with Article 6(1)(b) of the GDPR to give you access and in the light of our legitimate interest in measuring, adapting and improving our content and functions and preparing analyses in accordance with Article 6(1)(f).

We will keep the necessary data to document your activation and consent in relation to guest Wi-Fi for 2 years after you opt out, to demonstrate and document that we have communicated with you lawfully in accordance with Article 6(1)(c) and Article 17(3)(e) of the GDPR, cf. Section 93(1)(1) of the Danish Penal Code. Inactive users will be automatically deleted after 13 months.

General information about the processing of the data we collect

We take great care of your personal data. The data we collect about you is stored and processed in accordance with legislation from time to time in force.

In most cases, giving us personal data or consenting to data collection is voluntary. If you do not wish to share your personal data or consent to the collection of personal data, this may have various implications for you depending on the activity you are carrying out or wish to carry out.

We have taken appropriate technical and organisational measures to safeguard against your personal data being accidentally or unlawfully deleted, published, lost, impaired or falling into the hands of unauthorised persons, being used fraudulently or otherwise being processed contrary to legislation.

We collect, process and store only the personal data necessary for the established purpose. In addition, applicable law, contracts or other legal obligation may require us to process certain types of data.

As our service depends on correct and up-to-date data, we ask you to provide us with relevant changes to your data. You may use the contact details to notify us of changes and we will update your data. If we become aware of incorrect data ourselves, we will update the data to the best of our knowledge and then notify you.

We will keep the data for as long as necessary to fulfil the intended purpose and for as long as it is required by applicable law. Once the data has served its purpose and is no longer needed, we will delete the data to the extent that the law does not require us to store the data for a longer period.

We may share your data with our partners who use it for targeted advertising on our behalf. We also use a number of external companies to store and process data. These companies will process the data solely on our behalf and under express written instructions from us, and only to the extent necessary to fulfil the intended purpose. These companies are not permitted to use the data for their own purposes.

Rosengårdcentret uses Skyfii as its guest Wi-Fi provider. Data is not transferred to locations outside the EU, but Skyfii uses customer service located in Australia. Rosengårdcentret uses the EU Standard Contractual Clauses and has carried out a satisfactory assessment of the level of data protection in the country concerned and has put in place technical measures to ensure that processing is covered by the necessary guarantees, cf. Article 46 of the GDPR.

Your rights

You have a number of rights regarding our processing of information about you. Some of these rights may be limited by legal obligations and other legislation that we are subject to or because processing is not covered by data protection legislation.

Right to inspect data

You have the right to access the data we process about you, as well as various additional information, including where we obtained the data, what we use it for, how long we keep it and who we share it with.

Correction

You have the right to have any incorrect data we hold about you corrected.

Deletion

In special cases, you have the right to erasure of data about you sooner than we would otherwise generally erase it.

Restriction of processing

In some cases, you have the right to have the processing of information about you restricted. If you have the right to have the processing of your personal data restricted, going forward we may only process your data – apart from storing it – with your consent, or, where legal requirements can be established, invoked or defended, or to protect a person or important public interests.

Right to object

You are entitled at any time, for reasons relating to your particular situation, to object to the processing of your personal data on the basis of Article 6(1)(e) or (f) of the GDPR, including profiling based on these provisions. The data controller may no longer process the personal data unless the data controller demonstrates important legitimate reasons for processing that prevail over your interests, rights and freedoms, or unless processing is necessary for the purposes of determining, asserting or defending legal claims.

If personal data is processed for direct marketing purposes, you have the right at any time to object to the processing of your personal data for such marketing, including objecting to profiling where this relates to direct marketing.

Data portability (right to transfer data)

You may in some cases be entitled to receive your personal data in a structured, commonly used and machine-readable format, and to have such personal data transferred from one data controller to another without hindrance, to the extent that this is technically possible for us, and if the data is collected on the basis of your consent or in connection with a contract/agreement you have entered into with us.

Contact options

You may contact us if you believe that we are processing personal data about you in violation of any applicable law or other legal obligation, or if you wish to delete or access any information we may have about you.

When you contact us with a request to correct or delete personal data about you, we will check whether the conditions for such correction have been met and, if so, we will make changes or delete the data as soon as possible.

You can exercise your rights by contacting us on tel. +45 6615 9118, by e-mail to info@rosengaardcentret.dk, or via our contact form https://rosengaardcentret.dk/henvendelse-vedr-persondata/

The data controller is:

RGC Management, c/o Rosengårdcentret Ørbækvej 75 5220 Odense SØ CVR.: 34593442

Appeals

If you are dissatisfied with our processing of personal data or believe that our processing does not comply with applicable law, you may file a complaint with the Danish Data Protection Agency. You can find their contact details on their website: www.datatilsynet.dk