1.          General

At MobileAdds, we want you to feel secure when providing us with personal information. In this privacy policy, we explain how we collect, use, transfer, and store your personal information, and how we ensure that your personal information is handled in accordance with applicable laws. It's important for us that you read and understand this privacy policy and feel confident about how we handle your personal information.

 

2.          Who is responsible for personal data?

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2.1.       MobileAdds APS, with CVR. no. 39005522 and address at Produktionsvej 1, 2600 Glostrup, Denmark (referred to as "MobileAdds" in this policy) is responsible for the processing of your personal information when MobileAdds provides and markets products and services, and in all other contact with MobileAdds, such as visits to our webshop or support requests via email and phone. As the data controller, it is MobileAdds' responsibility to ensure that your information is processed correctly and securely in accordance with applicable laws.

 

2.2.       MobileAdds shares IT infrastructure with certain companies within the MobileAdds group. Business transactions with our customers, including associated personal information and databases covered by this infrastructure, are managed and owned directly by MobileAdds. Therefore, MobileAdds has the ultimate control over your personal information and has ensured control and secure handling of your personal information through agreements with other group companies.

 

3.          What personal information do we process about you?

MobileAdds collects and processes the following categories of personal information about you as a customer or potential customer in connection with your purchases and use of our services, and as we market and sell our products and services.

 

-         Contact information such as name, title, email address, delivery address, invoice address, and phone number.

-         Account information such as customer number, username, password, and registration and modification dates.

-         Customer preferences regarding marketing materials and personal offers.

-         Identification number, i.e., CVR number.

-         Order information such as order number, ordered products or services, order date, price, any discounts, and purchase history.

-         Payment information such as payment method, card number, cardholder, transaction time, amount, IP address, and payment history.

-         Financial information such as credit information.

-         Correspondence and other information related to support cases such as audio recordings of calls, notes, and email messages when contacting customer service.

-         User-generated data about your interaction with MobileAdds' marketing materials and websites, such as IP address, device information (technical information about the computer, mobile phone, and other devices you use, e.g., web browser settings, time zone, operating system), location information, responses to surveys, and click and visit history indicating which of our products or offers you have been interested in, how you interact with our newsletters, which of our events you have signed up for and participated in, and the results of customer satisfaction or market surveys.

-         Behavior and/or preferences such as event participation, ratings of customer experiences with MobileAdds, and interactions in stores to evaluate suspicions of crime.

 

4.          From which sources do we collect information about you as a customer?

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4.1.       MobileAdds collects your personal information directly from you when you place an order, visit MobileAdds' website, participate in our events, click on links in our digital marketing materials that we have sent to you, are in contact with our customer service, or contact MobileAdds and when you otherwise interact with MobileAdds and provide information about yourself. In these cases, personal information is collected so that you can enter into agreements with MobileAdds, and so that MobileAdds can deliver its products and services to you.

4.2.       If you have a MobileAdds account, MobileAdds also collects information about you when you register the account and during the period when you are the account holder, e.g., your purchase history, your behavior on MobileAdds' website, your customer choices regarding receiving marketing materials, and which offers you have shown interest in by visiting our webshop and reading or clicking on links in our digital marketing.

4.3.       In addition to the information that MobileAdds collects from you, we may also collect personal information from another, i.e., from a third party. We obtain information from public records via third-party services for address updates to verify that we have the correct contact information for you. We obtain information about creditworthiness from credit rating agencies, public registers, or banks. We also collect information for marketing purposes from social media.

4.4.       MobileAdds also collects certain personal information via cookies, which log your behavior on our website, and thus which content you prefer. You can find more information on how we use cookies in MobileAdds' cookie policy.

5.          Why do we process your personal data?

MobileAdds collects and processes information about you for various purposes. These purposes determine the limitations on how we may use your personal information. Below, we explain the purposes of our processing and provide examples of the processing activities that occur under each purpose. Please note that some of your personal information may be processed for multiple purposes.

A)   Managing orders and purchases

Processing personal data for this purpose includes activities such as identifying you, sending order confirmations, assessing available payment methods (based on contact information, ordered items, payment history, and financial information), handling payment transactions for ordered products and services, delivering orders, sending delivery notifications, and handling complaints and warranty issues regarding purchased products and services.

 

Our collection and processing of the information required to manage your orders and purchases are necessary for us to fulfill our obligations under MobileAdds' terms of trade. If we do not receive this information from you, we cannot fulfill our obligations, and we may reject the order or purchase.

B)   Offering and managing your MobileAdds account

 

We process personal data for this purpose to, for example, grant you access to log into your account, verify your identity, create your personal pages, maintain accurate contact information, manage your marketing material preferences and personalized offers, facilitate shopping in our web store with pre-filled information and saved digital shopping carts, facilitate handling cases and complaints, and enable you to track your order and payment history.

 

Read more about registering MobileAdds accounts in our terms of trade. Our collection and processing of the information required to offer and manage your MobileAdds account are necessary for us to fulfill our obligations. If we do not receive this information, we cannot fulfill our obligations, and we may reject the registration of the account or close the account.

 

C)   Providing personalized information and offers and a personalized experience in our web store for you, who have a MobileAdds account

At MobileAdds, we want you to have the best possible experience when visiting our website and when we communicate with you. Therefore, we process personal data for this purpose to improve your user experience by creating, offering, and providing you with personalized content in our communication and marketing via mail, email, SMS/MMS, and phone with tailored benefits and offers, recommendations, event invitations, and other information that we believe is relevant to you, as well as reminding you of abandoned digital shopping carts. To enable this, analyses of the information collected by MobileAdds, such as address, order history, and user-generated data, are conducted.

 

Our collection of personal information for this purpose is necessary for us to fulfill our obligations under these terms. If we do not receive this information, we cannot fulfill our obligations, and we may then limit offers and other benefits linked to your account.

D)  Providing personalized information and offers and a personalized experience when we communicate with you, who do not have a MobileAdds account but have signed up for an event, competition, and/or other marketing activities

At MobileAdds, we want you to have the best possible experience when visiting our website and when we communicate with you. Therefore, we process personal data for this purpose to improve your user experience by creating, offering, and providing you with personalized content in our communication and marketing via mail, email, social media, SMS/MMS, and phone with tailored benefits and offers, recommendations, event invitations, and other information that we believe is relevant to you. To enable this, analyses of the information collected by MobileAdds, such as age, residence, order history, and user-generated data, are conducted.

 

E)   Marketing and providing information about products and services

We process personal data for this purpose to inform you by email, social media, SMS/MMS, and phone about the products, services, and offers sold by the MobileAdds group, display recommendations, remind you of abandoned digital shopping carts, and invite you to events, competitions, and market and customer satisfaction surveys.

 

F)    Handling cases received by MobileAdds customer service or other support functions

Processing personal data for this purpose includes MobileAdds activities such as communicating, confirming customer identity, handling complaints and other support cases, answering questions received by customer service or other support functions via email, phone, or digital channels, correcting incorrect information, providing technical support, and managing customer relationships.

G)  Fulfilling legal obligations imposed on the MobileAdds group

Personal data is processed for this purpose so that the MobileAdds group can fulfill legal obligations under laws and regulations, judgments, and authority decisions. Examples of such obligations are product liability and product safety, such as communicating and providing information about product warnings and product recalls (e.g., in the case of a defective product) and storage conditions according to the accounting law. If the information collected by MobileAdds within the scope of this purpose is not provided, we cannot fulfill our legal obligations, and we may then reject your order, purchase, or other activity that gives rise to our legal obligations.

 

H)  To prevent abuse of MobileAdds accounts and to prevent and investigate suspicion of theft and fraud as well as to establish, exercise, or defend legal claims.

Processing personal data for this purpose includes, among other things, preventing inappropriate use of any MobileAdds account and preventing, investigating suspicion of theft and fraud. When you want to pay for goods by invoice, we therefore conduct a fraud check where we analyze which products you want to buy, delivery address, the value of the products, etc. We identify patterns of behavior that often occur in connection with fraud, and then a manual check is conducted to assess the risk of an attempted fraud. Suspicion of an illegal act and attempts at an illegal act may be reported to the police.

 

I)     Assessing, developing, and improving the services, products, and systems of the MobileAdds group for our customers in general

Processing personal data for this purpose includes activities such as making our web store and other services more user-friendly, developing or highlighting digital features, improving our customer offerings (e.g., developing services and products), preparing documentation to improve the goods and logistics flow (e.g., to be able to prepare forecasts for purchases, inventory, and deliveries), developing and improving the company's range and resource efficiency, and improving our IT system, preparing statistics for market and customer analyzes, and business follow-up, and business and method development related to orders and purchases, automatically archiving behavior that may need to be investigated for security reasons, and enabling customers to influence the assortment offered by MobileAdds. To fulfill this purpose, MobileAdds also conducts general analyses in aggregated form, i.e., not on an individual level, of, among other things, click and

6.          What is the legal basis for our processing of your personal data?

For MobileAdds to have the right to collect and process your personal data, there must be a legal basis for each purpose for which the information is processed. The legal basis upon which we base our processing is described in this section. Note that several legal bases may apply to the same processing activity.

 

A)     Legal obligation

This basis entails that our processing is necessary to fulfill a legal obligation imposed on MobileAdds, such as documenting payment information to comply with the requirements of the accounting legislation.

B)   Contractual obligations

This basis entails that the processing is necessary to either fulfill an agreement with you as a customer or to enter into agreements at a later time. For you, as the holder of a MobileAdds account, this means that by accepting the Terms and Conditions, you have entered into an agreement with MobileAdds, which sets the framework for the processing of your personal data to offer, manage, and administer our services linked to the account, such as analyzing your personal characteristics to provide you with personalized benefits and offers. When ordering or purchasing, we process your information to fulfill the obligations under MobileAdds' terms of trade. MobileAdds may need to, for example, record your contact information so that we can fulfill our obligation to deliver products or services, and obtain credit information if you choose invoice as the payment method, so that we can check your ability to pay.

C)   Legitimate interest

This basis entails that our processing is based on a so-called balancing of legitimate interests. This means that the processing takes place because MobileAdds assesses that we have legitimate interests in processing your personal data, which outweigh your interest in not having the personal data processed. On this basis, we process, among other things, your personal data to prevent inappropriate use of any MobileAdds account and to prevent, detect, and investigate illegal activities in our business activities. If we determine that an illegal act or attempted illegal act has occurred and we file a police report, MobileAdds will also continue to process your personal data in order for us to establish, defend, or assert legal claims.

D)  Consent

This basis means that we process your personal data when you consent to the processing. You have the right to withdraw your consent at any time. Withdrawal of your consent does not affect the lawfulness of the processing based on consent prior to withdrawal.

 

7.          How long do we retain your personal data?

7.1.       MobileAdds retains your personal data for as long as necessary to fulfill the purpose for which the information is processed. The duration of the retention of personal data depends on the purpose for which the information is processed. In addition, MobileAdds may retain the information longer if necessary to establish, defend, or assert legal claims, for example, if there is an ongoing dispute or if a report of an illegal act has been submitted to the police authorities. We regularly review our information and delete personal data that is no longer necessary.

7.2.       MobileAdds stores personal data linked to your MobileAdds account for as long as you actively interact with MobileAdds in various ways. If you have been inactive for a certain period, the account will automatically be closed, and the personal data that we have collected and processed to maintain the MobileAdds account and the services linked to the account relationship will be deleted. Read more about this and how we define inactive customers in the terms of trade.

 

8.          Who do we share your personal data with?

8.1.       MobileAdds may transfer your information to other companies so that you can take advantage of our offers, products, and services. The recipients of your personal data can either be data processors for MobileAdds, i.e., companies that process your information on our behalf and in accordance with our instructions, or independent data controllers, i.e., companies that are independently responsible for the processing of your information because they have a direct relationship with you as a customer, for example, Nets.

8.2.       MobileAdds may also transfer your information to authorities if necessary to comply with laws, regulations, or authority decisions, or for MobileAdds to establish, defend, or assert legal claims.

8.3.       Depending on the contact you have had with MobileAdds, such as whether you are the holder of a MobileAdds account or receive marketing material, MobileAdds may transfer your personal data to the following recipients:

-      Other companies within the MobileAdds group, which act as data processors for MobileAdds, so that we can fulfill the various purposes stated in this policy. The legal basis for the transfer of personal data to our group companies is the same as for our own processing.

-      Analysis and marketing companies that provide services such as automated marketing tools, analytics, communication, print, and distribution to you as a MobileAdds account holder and/or if you have signed up for an event, competition, and/or other marketing activities. These recipients help MobileAdds analyze your information and inform about and market the products and services that MobileAdds sells. The information provided includes contact information, account information, customer choices, order information, and user-generated data. The transfer is based on the legal basis of legitimate interest as well as our contractual obligations to you as the holder of a MobileAdds account.

-      State authorities, such as the police authorities or the tax authorities, to whom we are required to transfer your information according to legal requirements or authority decisions, or to whom we transfer information due to suspicion of an illegal act or attempted illegal act. The categories of information transferred include contact information, identification number, account information, order information, payment information, and user-generated data. The transfer is based on legal obligations imposed on MobileAdds, or for MobileAdds to establish, defend, or assert legal claims.

8.4.       If you place an order or make a purchase with MobileAdds, we may also transfer your personal data to the following recipients within the framework of handling your orders and purchases based on our contractual obligations to you as the legal basis:

-      Logistics companies and freight forwarders that assist us with shipping goods so that we can deliver our products to you. We transfer contact information and order information to these recipients.

-      Partners and providers of payment solutions, such as card issuing companies, banks, credit institutions, and other financial actors, who ensure that you can make payments and offer you various financing solutions. The personal data transferred includes contact information, identification number, and payment information.

-      Credit rating agencies, credit reporting agencies, or banks that provide us with information so that we can check your creditworthiness, such as credit information, when you apply for credit in connection with handling your orders and purchases.

-      Companies that provide financial services, such as accounting and collection companies, which ensure that MobileAdds receives payment for delivered products and services in connection with the handling of your orders and purchases. The personal data transferred includes contact information, identification number, order information, and payment information.

 

9.          Where do we store your personal data?

 

MobileAdds will primarily process your personal data within the EU/EEA. However, we may also transfer your personal data to a country outside the EU/EEA if we need to share your information with MobileAdds' suppliers or partners located outside or storing personal data in a country outside the EU/EEA. If your personal data is transferred to a country outside the EU/EEA, MobileAdds will take the necessary measures to legally transfer the personal data by ensuring that your personal data is processed securely and with a level of protection that is comparable to the protection offered within the EU/EEA, for example, by entering into an agreement with the recipient, including the EU Commission's standard contractual clauses.

 

10.       What rights do you have as a registered customer?

MobileAdds is responsible for ensuring that your personal data is processed in accordance with applicable law. In this section, your rights in connection with our processing of your personal data are described. Upon your request or on our own initiative, we will correct, anonymize, delete, or supplement information that is found to be incorrect, incomplete, or misleading. If you have any questions regarding this or wish to exercise your rights, please contact us. See the contact information at the bottom of this policy.

 

a)      Right to access your personal data

At MobileAdds, we are transparent about how we process your personal data. If you wish to have insight into our processing of your personal data, you have the right to demand information about the processing, including a copy of your personal data being processed, a so-called register extract. This includes information about purposes, categories of personal data, categories of recipients of the personal data, storage period or the criteria for determining the storage period, information about where the information is collected from, and the existence of automated decisions including information about the logic behind and the significance of the processing. Please note that upon a request for access, we may ask for additional information about you to ensure that we provide the information to the correct person and which information you want to receive. The register extract is free of charge, but for repeated requests, MobileAdds is entitled to charge an administrative fee of DKK 100.

 

b)      Right to correction of your personal data

It is very important for us to collect correct and up-to-date personal data. If the information we have about you is incorrect, you have the right to demand that it be corrected. You also have the right to supplement any incomplete personal data, e.g., if we have the correct street address but are missing the house number. Upon your request, we will correct any incorrect or incomplete information about you as soon as possible.

 

c)       Right to deletion of your personal data

We respect that the personal data we process about you are information we have borrowed from you. You therefore have the right to demand that MobileAdds delete your personal data if the information has been processed unlawfully, needs to be deleted to fulfill a legal obligation that MobileAdds is subject to, is no longer necessary for the purposes for which they were processed, or if you object to a balancing of legitimate interests made by MobileAdds and there is no legitimate interest for MobileAdds or a third party that outweighs yours (see section f) below for information on the right to object). However, we may not always be able to comply with your request, as there may be cases that give us the right to continue processing, e.g., if the information is processed to fulfill a legal obligation as a legal basis, such as requirements under the Accounting Act, or if the information is necessary for MobileAdds to establish, defend, or enforce legal claims.

 

d)      Right to data portability

You have the right to receive a copy of the personal data concerning you in a structured, commonly used, and machine-readable format and, in certain cases, to have the information transmitted to another data controller. However, this right only applies to information that you have provided to MobileAdds and that we process on the basis of your consent or contractual obligations towards you as a legal basis.

 

e)      Right to restrict processing

You have the right to demand that our processing of your personal data be restricted in certain situations, which means that the information may only be processed for certain purposes. For example, you can demand a restriction of incorrect information when you have requested correction. While MobileAdds investigates the correctness of the information, the processing of it will be restricted. When restricting processing, personal data should only be processed, in addition to storage, as follows:

i. The data subject has consented to processing

ii. MobileAdds needs to exercise or defend legal claims

iii. To protect the rights and freedoms of another data subject or legal person

iv. For important public interest reasons in the European Union or Member States

 

f)        Right to object to certain types of processing

When MobileAdds processes your personal data based on balancing of legitimate interests as a legal basis or for direct marketing purposes, you have the right to object to our processing. You can object to MobileAdds' balancing of interests if you have personal reasons related to the situation. In such an objection, MobileAdds assesses whether we have legitimate interests for the processing that outweigh your interest in protecting your privacy. If this is the case, MobileAdds may continue to process your personal data despite your objections to the processing. You can object to direct marketing and analyses carried out for direct marketing purposes without stating any reasons. You control this yourself via the settings on My Pages, where you choose whether you want to receive marketing material and personalized offers. Additionally, you have the opportunity to opt out of marketing with each individual digital marketing communication. If you opt out of direct marketing, we will cease processing your personal data for this purpose as well as all types of direct marketing activities such as sending newsletters and offers. If you only opt out of personalized offers, the marketing material to you will be generic, as we have difficulty assessing which marketing is relevant to you if we are not allowed to analyze your personal characteristics. Read more about how we tailor our offers and communication to your personal characteristics, and how to opt out of such processing in our terms and conditions.

 

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10.2.   If you believe that we are handling your personal data incorrectly, you are welcome to contact us. Our contact information can be found at the bottom of this policy. You also have the right to lodge any complaints regarding the processing of your personal data with the Danish Data Protection Agency, which is the responsible supervisory authority for the processing of personal data in Denmark.

 

11.       How do we protect your personal data?

You should always feel secure when providing personal information to us. MobileAdds has therefore implemented appropriate technical and organizational security measures to protect your personal data against unlawful or accidental disclosure, use, access, destruction, alteration, or damage to your personal data. For example, all customer information is stored in a database protected by a firewall and access control, so only employees of the MobileAdds group who need access to your information to perform specific tasks have such access.

 

12.       Overview of our processing of personal data

Below, we have provided an overview of our processing of personal data to clarify for you which categories of personal data we process for our various purposes, what legal basis forms the basis for our processing, and how long we retain the information. This way, you can easily see which processing activities we carry out and why we do it.

 

 

Purpose

Legal Basis

Categories of Personal Data

Retention Period

To handle your orders and purchases Contractual obligations according to MobileAdds' general terms of sale

Contractual obligations according to MobileAdds' general terms of sale

-  Account information

-  Identification number

-  Order information

-  Payment information

-  Financial information

Up to five years after your order is paid and delivered or as long as the defective product is not rectified. If the warranty period for a purchased product or service is longer, then after this period has expired or as long as the warranty claim is ongoing.

To offer and manage your MobileAdds account

Contractual obligations according to the terms of the MobileAdds account

-  Contact information

-  Account information

-  Identification number

-  Order information

-  Payment information

-  User-generated data

-  Customer choices

As long as you have a MobileAdds account or as long as there is a legal claim.

To provide personalized information and offers, and a personalized shopping experience on our website, if you have a MobileAdds account

Contractual obligations according to the terms of the MobileAdds account

-  Account information

-  Order information

-  Payment information

-  User-generated data

-  Customer choices

As long as you have a MobileAdds account or as long as there is a legal claim

To market and provide information about products and services

Legitimate interes

-  Contact information

-  Account information

-  Order information

-  User-generated data

-  Customer choices

Two years after you last clicked on a link in our communication to you, or as long as there is a legal claim.

To handle cases received by customer service and other support functions

Contractual obligations according to the terms of the MobileAdds account for you as an account holder

-  Contact information

-  Account information

-  Identification number

-  Order information

-  Payment information

-  User-generated data

-  Correspondence and other information about support cases

Five years after the last contact in the case or as long as the defective product is not rectified. If the warranty period for a purchased product or service is longer than five years, then after this warranty period has expired or as long as the warranty claim is ongoing

To fulfill legal obligations such as requirements in the accounting law, product liability, and protection of your personal data in our systems

Legal obligation

-  Contact information

-  Account information

-  Identification number

-  Order information

-  Payment information

-  Correspondence and other information about the support case

As long as we are required to keep the information according to applicable law or authority decision or as long as there is a legal claim

To prevent abuse of MobileAdds accounts and to prevent and investigate suspicions of theft and fraud as well as to establish, exercise, or defend legal claims.

Legitimate interest

-  Contact information

-  Account information

-  Identification number

-  Order information

 

-  Payment information

-  Behavior and/or preferences

-  User-generated data

During the period when the necessary checks are conducted. If the processing leads to a police report, the information will be stored for as long as necessary to complete the report and establish, defend, or assert legal claims

To assess, develop, and improve the services, products, and systems of the MobileAdds group for our customers in general.

Legitimate interest

-  Contact information

-  Account information

-  Order information

-  Payment information

-  User-generated data

-  Behavior and/or preferences

-  Customer choices

-  Correspondence and other information about the support case

As long as you have a MobileAdds account if you are an account holder.

Five years after you last interacted with MobileAdds if you are not an account holder of a MobileAdds account, for example, visited our website, logged into a previous MobileAdds account, or clicked on a link in our communication to you, or as long as there is a legal claim

 

13.       Application and modification of the privacy policy

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13.1.   The most recently updated version of MobileAdds' privacy policy is always available on our website. Our privacy policy applies at all times, in the form and with the content published on the website.

13.2.   MobileAdds has the right to update the privacy policy at any time. If the privacy policy is changed, the updated policy will be published on the MobileAdds website. Additionally, you will be informed that the privacy policy has been changed when you log in to your MobileAdds account. We may also inform you via email if there are significant changes to the privacy policy. If you cannot accept the changed policy, you can close your MobileAdds account by contacting customer service (see contact information at the bottom of this policy).

14.       Contact information

Do not hesitate to contact us if you have any questions about this privacy policy, if you want to know more about our processing of your personal data, or if any information is incorrect and you would like us to correct it.

-            Are you representing a company? Please contact our customer service at 70 500 005 or send an email to info@mobileadds.dk

-            You can also contact our special employees who work with processing personal data via email at christian@mobileadds.dk for the Data Protection Officer, Christian Kofoed.

 

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