Privacy Policy

This privacy policy explains how Secomea A/S (company registration no. 31 36 6038) (hereafter “Secomea”, “we” or “us”) processes personal data, when

• you visit Secomea’s website
• you receive marketing communication
• you contact our business
• you interact with us as a contact person at external parties, e.g., suppliers or at customers.

In these situations, Secomea will, as a data controller, collect and process personal data about you for different purposes, depending on the relationship with you as a data subject. Please see a description of how we process your personal data in section 1 below.

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and the Act on supplementary provisions to the Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“the Danish Data Protection Act”) require Secomea to provide information to you as a data subject about how Secomea collects, processes, and discloses personal data, which categories of personal data Secomea processes, and the purposes for such processing.

1. Overview of processing activities

Website administration 

We process your personal data for the ongoing operation of the website. In connection with your use of our website, personal data will be collected and processed in connection with our and third parties’ use of cookies. We employ third-party tools to monitor and analyze the use of our websites, and to automate certain processes related to the development and operation of our websites, including tools provided by HubSpot used for analytics, tracking, and site functionality.

The purpose of the processing of personal data is also: 

• Optimisation of our visitors’ use of the website and optimisation of the functionality of the website
• Optimisation of the performance of associated applications
• Preparation of demographic and user-related statistics for the optimisation of the website
• Targeting of ads and optimisation of their efficiency

You can read more about how we use cookies in our cookie policy here.

We process personal data concerning the visitors to our website.

Sources from where we collect your personal data:

• Directly from your device, e.g. tablet or smartphone
• Through third-party cookies.

We process the following categories of personal data:

Technical data:

• IP address
• Browser type and version
• Device type, operating system and screen resolution
• Time and duration of visits
• Pages viewed and navigation patterns on the website
• Referring website URLs
• Cookie identifiers and other unique online identifiers

Interaction and usage data:

• Clicks, scrolling behaviour and browsing actions
• Downloads and forms submitted
• Engagement with email communications (opens, clicks, replies), where applicable

Profile and contact data (when voluntarily submitted):

• Name
• Email address
• Country
• Phone number
• Company name
• Job title

The legal bases on which Secomea processes your personal data are:

• Your consent, cf. article 6(1)(a) of the GDPR, section 6(1) of the Danish Data Protection Act and the Danish Cookie Order section 3, when using cookies on the website.
• The processing is necessary for the purposes of legitimate interests pursued by Secomea, cf. article 6(1)(f) of the GDPR, and section 6(1) of the Danish Data Protection Act.

Our legitimate interest is:

• Optimisation of our website and to ensure the functionality of our website
• Preparation of statistics
• Targeting of ads
• Researching the market

We may disclose your personal data to our suppliers, e.g., IT-suppliers, who assists our business or other Secomea group companies.

However, we may exchange information with other external parties, companies, and organizations if we are legally obliged to do so or if it is necessary to in order for us to establish, exercise or defend a legal claim or to protect the rights, property or safety of the Secomea, customers, or others.

Cookies:

• Google Analytics
• Google Ads
• LinkedIn Analytics
• LinkedIn Ads
• Microsoft Advertising
• FacebookConnect
• HubSpot
• Salesloft
• Zoominfo
• Teamtailor
• Reddit Ads

We retain personal data for as long as necessary to fulfill the stated purposes.

As a main rule, we process your personal data for up to two (2) years, unless continued storage is necessary, e.g. for the establishment, exercise, or defense of any legal claim, or if we are otherwise obliged to do so.

The storage and deletion of data is handled according to the below manner:

• Cookies are deleted upon expiry of their lifetime.
• Session cookies are deleted automatically when the user closes the browser, while permanent cookies only are deleted after a longer time interval or when the user deletes them. 
• Permanent cookies are stored until users delete them.
• Permanent cookies are renewed when users visit the website.

Please see our cookie policy for further description of specific retention periods for separate cookies.

Marketing and newsletters

We process personal data for marketing purposes, including sending relevant communication to you regarding our business and services.

We may also contact you to seek feedback on our products and services or for market or other research purposes.

We use HubSpot as our CRM and marketing automation system to manage marketing communications, track engagement, personalize your experience, and automate related marketing processes.

In this regard, we use personal data to:

• Send you marketing communications that are relevant to your interests.
• Personalize your experience on our website by displaying content that is tailored to your needs.
• Segment our audience for targeted marketing campaigns.
• Analyze the effectiveness of our marketing campaigns.

Newsletters:

We process your personal data when sending newsletters to you that you have signed up to receive. We also process and store your consent for receiving marketing material from us.

Please note that you can always unsubscribe from our marketing communication by clicking the “unsubscribe” link at the bottom of our emails.

Social media:

We may implement social media buttons and certain other widgets that allow our users to interact and share content. Your interaction with a widget generally allows the third party to collect some information about you, for example, your IP Address. In certain cases, the third party might be able to identify you through its widget even if you do not use it but visit another site that also uses the widget.

Mentioned below are the partners whose widgets are used on our site: 

• Facebook
• YouTube
• Twitter / X
• LinkedIn
• Vimeo
• Reddit

We process the following categories of personal data of Individuals who receive marketing communication:

• Name
• Email address
• Phone number
• Company name
• Job title
• Your feedback on our products and services
• Behavior and preferences on our website (pages visited, downloads, time spent on website)
• Engagement with Secomea email campaigns (opens, clicks, replies)

We process your personal data on the basis of your consent, cf. article 6(1)(a) of the GDPR and section 6(1) of the Danish Data Protection Act, and section 10 of the Danish Marketing Practices Act.

The processing is necessary for the purposes of legitimate interests pursued by Secomea, cf. article 6(1)(f) of the GDPR, and section 6(1) of the Danish Data Protection Act. Our legitimate interest is to send you marketing, including newsletters and other relevant material regarding our business and services. Our legitimate interest is also to collect feedback and carry out market and other research and analysis activities relating to our business and marketing activities, including marketing campaigns.

We may disclose your personal data to our suppliers, e.g., IT- and CRM-suppliers, who assists our business, or other Secomea group companies.

Partners whose widgets are used on our site: 

• Facebook
• YouTube
• Twitter / X
• LinkedIn
• Vimeo

We retain personal data for as long as necessary to fulfill the stated purposes.

As a main rule, we process your personal data for up to three (3) years, unless continued storage is necessary, e.g. for the establishment, exercise, or defense of any legal claim, or if we are otherwise obliged to do so.

Newsletters:

We process your personal for as long as you wish to receive newsletters from us, and up to two (2) years from the time you have revoked your consent to receive newsletters.

Other communication with us 

We process your personal data in order to communicate with you, e.g. via email or when contacting us via contact forms on our website, etc.

We process the following categories of personal data of individuals who contact our business:

• Ordinary personal data
• Name
• E-mail
• Phone number
• Information provided by filling in contact forms on the website and additional information provided when communicating through the website.

The processing of the personal data is necessary for the purposes of legitimate interests pursued by Secomea, cf. article 6(1)(f) of the GDPR, and section 6(1) of the Danish Data Protection Act. Our legitimate interest is to be able to communicate with you.

We may disclose your personal data to our suppliers, e.g., IT-suppliers, who assists our business, or other Secomea group companies.

However, we may exchange information with other external parties, companies, and organisations if we are legally obliged to do so or if it is necessary to in order for us to establish, exercise or defend a legal claim or to protect the rights, property or safety of the Secomea, customers, or others.

We retain personal data for as long as necessary to fulfill the stated purposes.

As a main rule, we process your personal data for up to two (2) years, unless continued storage is necessary, e.g. for the establishment, exercise, or defense of any legal claim, or if we are otherwise obliged to do so.

External parties

We process personal data to interact and communicate with external parties regarding our business and services, and to handle and administrate our relationship with external parties, e.g. conclusion, ongoing administration, and termination of agreements with external parties, etc.

We process the following categories of personal data of contact persons at external parties, e.g., suppliers, customers, advisors, etc.:

• Name 
• Email address 
• Phone number 
• Company name 
• Job title 

The processing is necessary for the purposes of legitimate interests pursued by Secomea, cf. article 6(1)(f) of the GDPR, and section 6(1) of the Danish Data Protection Act. These legitimate interests relate to interacting and communicating with contact persons at external parties, e.g. suppliers, customers, or advisors, etc., regarding our business and services as well as ongoing administration and handling of Secomeas relationship with external parties.

We may disclose your personal data to our suppliers, e.g., IT-suppliers, who assist our business, or other Secomea group companies.

However, we may exchange information with other external parties, companies, and organizations if we are legally obliged to do so or if it is necessary to in order for us to establish, exercise or defend a legal claim or to protect the rights, property or safety of the Secomea, customers, or others.

We retain such personal data for as long as necessary to fulfill the stated purposes.

The personal data are as a main rule stored three (3) years from the end of the financial year in which the last sale transaction was made with the supplier or the customer.

2. Other processing activities

In relation to the above-described processing activities, Secomea also processes personal data for the purpose of complying with data protection legislation and other legitimate interests, cf. section 6(1) of the Danish Data Protection Act and Article 12 of the GDPR. This may include processing in connection with:

• Compliance with documentation requirements
• Compliance with principles and legal bases for processing personal data
• Implementing, maintaining and testing technical and organisational security measures
• Investigating and reporting suspected or known personal data breaches
• Handling requests and complaints from data subjects and others
• Handling inspections and inquiries from supervisory authorities
• Handling disputes with data subjects and third parties

3. How Secomea collects personal data

Personal data is primarily collected by Secomea directly from you as a data subject or your device.

When Secomea collects personal data directly from you for any of the purposes outlined above in Section 1, you provide the personal data on a voluntary basis. Whether or not you are under an obligation to provide such personal data will depend on the specific circumstances.

The consequences of not providing the personal data are that Secomea cannot fulfill the abovementioned purposes, including that Secomea cannot fulfill our obligations to you.

4. Withdrawal of consent

When the processing or transfer of personal data are based on your consent, which will be collected separately, you have the right to withdraw your consent to the processing, disclosure or transfer of your personal data. If you withdraw your consent, this will not affect the lawfulness of the processing and disclosure prior to the withdrawal, but Secomea will no longer use your consent as a legal basis for any processing of your personal data.

Please contact us here or use the contact details below if you wish to exercise this right related to any consents, which Secomea may have obtained from you.

5. Transfer of personal data to data processors

Secomea uses data processors who provide systems and services to Secomea to assist our business. As part of the provision of systems and services, these data processors may process and store your personal data on our behalf.

These data processors include the following categories:

• IT service providers who offer cloud services, IT systems, and tools, and store personal data
• Providers of online communication and file storage platforms

We use the following service providers as a data processor on our behalf:

• Salesforce CRM
• HubSpot Marketing
• Microsoft suite and Microsoft Data Visualization applications such as PowerBI

6. International transfers of personal data to recipients (both ‘data controllers’ and ‘data processors’) in countries outside the EU/EEA

Any transfer of personal data to recipients in countries outside the EU/EEA or international organisations will be based on a legal basis in Chapter 5 of the GDPR. 

Secomea may transfer your personal data to countries outside EU/EEA, where the European Commission has decided that the country offers an adequate level of data protection, pursuant to article 45 of the GDPR (“Adequacy Decision”)

When transferring your personal data to countries outside the EU/EEA, which are not deemed by the EU Commission to ensure an adequate level of data protection comparable to the GDPR standard, the legal basis for transferring the personal data is the European Commission’s Standard Contractual Clauses (“SSC”) in order to ensure an adequate level of data protection.

Secomea uses HubSpot with data hosting located within the European Union, and personal data processed through HubSpot is stored on servers in Europe.

HubSpot participates in the EU–US Data Privacy Framework (DPF). Where HubSpot processes personal data under the DPF, the transfer is based on this adequacy decision. For processing activities or sub-processors not covered by the DPF, SCCs will apply.

You can access the European Commission’s SCCs on the Commission’s website and/or obtain a copy of the SCCs entered into with the relevant recipients by contacting marketing@secomea.com.

Secomea notes that the US and other third countries may not ensure a level of protection equivalent to that in the EU/EEA. In such cases, supervisory authorities or public bodies may have access to personal data without effective remedies.

Secomea may transfer or allow limited access to personal data to the United States of America in connection with the following processing activities:

• Cookies
• Cloud storage
• E-mail marketing
• Marketing automation and CRM services provided by HubSpot (limited access and sub-processor activities, while primary data hosting is located within the EU)

7. Rights of the data subject

Subject to the conditions set out in the applicable data protection legislation, you as a data subject enjoys the following rights in respect of the personal data that Secomea hold:

• The right to request access to the personal data
• The right to rectify or correct the personal data
• The right to erase the personal data
• The right to restrict the processing of the personal data
• The right to have the data provided to you in a portable form
• The right to object to the processing of the personal data

You also have the right to complain to the competent supervisory authority, such as the Danish Data Protection Agency. Please consult their website for how to submit a complaint at www.datatilsynet.dk.

Right to object

Legitimate interests

You have the right to object, on grounds relating to your particular situation, at any time to our processing of personal data which uses legitimate interests as a legal basis for the processing (as set out in Article 6(1)(f) of the GDPR) as indicated above under section 1. Where you have exercised this right to object, Secomea will no longer process the personal data on the legal basis of legitimate interests unless Secomea can demonstrate compelling legitimate grounds for the processing, which override your interests, rights, and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.

Direct marketing

If personal data is processed for the purpose of direct marketing, you have the right at any time to object to the processing of your personal data for such marketing, including the right to object where the processing amounts to automated profiling of your personality, preferences or characteristics to the extent that it relates to direct marketing. If you object to processing for the purpose of direct marketing, the personal data may no longer be processed for this purpose.

8. Contact

Please contact Secomea if you have any questions regarding the protection of your personal data or if you wish to exercise any legal rights set out in this privacy policy.

Secomea A/S
Pakhus 47-Sundkaj 125
2150 Nordhavn, Copenhagen
Denmark

Company registration no.: 31 36 60 38 

E-mail address: info@secomea.com 

Phone number: + 45 88 70 86 50