1. Basic Principles
The purpose of communicating the policy on data protection adopted by Danes Worldwide is to orient our members, newsletter subscribers, and instructional program students and their parents about the methods of collection, protection, and use of personal data.
We fully abide by all requests for confidentiality with respect to personal data. We recognize the need to protect data appropriately and to manage in a secure and legal manner all the data we have collected. We take care to collect only the types of data indicated in this policy and to use such data only for the purposes indicated herein.
Should we receive data respecting individuals from sources other than the individual in question (e.g. from our local representatives or from external partners or other organizations), we notify him or her directly. We never provide personal data to external partners, but we do pass on basic data such as name, email address, membership number, and phone numbers to Danes Worldwide local representatives.
We do not under any circumstances pass on sensitive personal data to local representatives. We do pass on information to external partners upon obtaining a prior agreement from you in which you provide an explicit permission for us to communicate your information to an external expert advisor, usually by means of forwarding an email message.
Danes Worldwide strives to protect your personal data regardless of the origin of the data, the method of storage, or the means of transmission to a third party.
“Personal data” refers to all information required to identify an individual, including but not limited to his or her first and last names, residential address or other postal address, email address or other contact details, be they related to the individual’s residence or place of work.
“Sensitive personal data” refers to details such as health or religious orientation.
You may contact our inhouse legal advisor or our data management coordinator to obtain guidance with respect to specific types of data or to inquire about our policy on personal data, our business practices with respect to personal data, our purposes in collecting data, or other relevant topics.
2. Types of Personal Data, Purposes for Collection, and Deletion
Underneath is an overview of our activities related to data management, specific types of data, and specific reasons for deletion.
a) Membership of Danes Worldwide
When a membership in Danes Worldwide is established, certain types of data are collected (basic data):
- Email address (for the purpose of sending out newsletters)
- Postal address (for the purpose of sending out the DANES magazine)
- Date of birth
- Telephone numbers
- Skype ID
- Job title (for e.g. statistical purposes)
In addition, we maintain a log of purchases made.
Such information is required for our work to deliver the services to which you are entitled as a member and to support your interests as a Dane living outside Denmark.
When you sign up as a member of Danes Worldwide, you may advise us about your special interests. Such information is used for statistical purposes to enable us to tailor our services, and it may be used for disseminating marketing materials in conformance with applicable legislation. Marketing is discussed in more detail in section 3.
We maintain basic member data for the duration of the membership. Five years after a membership lapse, the data is erased unless we are in possession of your explicit permission to keep your contact information for a longer period.
b) Instructional Offerings from the Danes Worldwide Summer School – Summer School and Online Courses
We collect the following data when you purchase any instructional product or service:
- Email address
- Postal address
- Telephone numbers
In addition, we collect information about your child’s level of skill in Danish so as to be able to tailor our instructional offerings.
In order to provide appropriate instruction, we need to know certain other details such as, for example, whether your child is dyslexic.
During the process of purchasing Summer School related offerings, you will be asked to provide relevant health related and other details required to provide a safe environment and to enable our professional staff to teach at a suitable level. Without such details, we would not be able to deliver what you have purchased, including a high level of quality in our instruction and a safe experience for your child during Summer School.
A successful Summer School experience for your child requires that our staff are informed about such aspects as allergies or prescription medication. With such information, we are in a position to plan for dietary adjustments and to execute the necessary intervention if an emergency arises or if your child needs help with taking the medication.
Our ability to deliver Summer School for your child relies on our having relevant information about your child’s health and other aspects. Such information enables our staff to accommodate your child and other children. We collect this information via a separate form that you complete during the registration process.
If you use our online webshop form to provide relevant details about your child (e.g. information about allergies in the “Comments” field), we regard such details as personal data and direct them to our Summer School staff. Summer School staff process your information only for the purposes indicated above. The Summer School manager ensures that only those teachers with a need to know have access to your information.
Personal health related information about your child is retained for the duration of the instructional event and for two additional years. However, you may request that we delete the information, and we will then do so immediately.
Basic data for students or their parents will be retained for the duration of the instructional event. The data will be deleted 5 years later unless we have received specific permission to retain contact details for a longer period for the purpose of directing marketing communications or issuing certificates of completion.
c) Donations to Danes Worldwide
- Processing of personal data of persons who donate to Danes Worldwide on the grounds of legitimate interest
We process personal data of a person donating to Danes Worldwide, such as name, e-mail address and phone number. The personal data is processed according to GDPR article 6(1), litra (f).
The processing of the data of a person who donates to Danes Worldwide serves the purpose of allowing Danes Worldwide to do direct marketing of similar services to the donor. Processing of the donor’s personal data is necessary according to this purpose which is a legitimate interest according to GDPR preamble 47.
- Processing of the donors’ CPR-number through explicit agreement
The donor has the option to inform Danes Worldwide of their CPR-number prior to donating. The CPR-number is processed by Danes Worldwide on the grounds of the donors’ explicit agreement in accordance with the Danish Law of data protection § 11, stk. 2, nr. 2 and GDPR article 7.
The purpose of the processing is, in accordance with the agreement of the donor, that Danes Worldwide can inform the Danish tax authorities of the identity of the donor.
d) E-mails to Danes Worldwide
We process the personal data of persons who write to any of our e-mail addresses. Such data is the name of the person, their e-mail address, along with any other personal data which might be contained in the e-mail.
- E-mails from members of Danes Worldwide
E-mails from our members are treated according to “a)” in this policy.
- E-mails from other persons
The processing of your personal data is done according to GDPR article 6(1), litra (f). The purpose of the processing is to be able to respond to your e-mail.
e) Other Products
Additional products sold by Danes Worldwide are typically special events. During the registration process for such events we collect data similar to the data collected with respect to our members (see item “a” above).
The nature of the product determines the requirement for data. Event related data is usually deleted upon completion of the event unless we have received specific permission to retain contact details for a longer period (up to 5 years) for the purpose of directing marketing communications or issuing certificates of completion.
3. Marketing Communications
We call attention to the fact that your purchase of a membership in Danes World and your consent to the applicable terms constitute an agreement that we may manage your personal data for the purposes of servicing your membership. As part of your membership, you will receive information about our offerings, products, events, and advocacy activities; we will in addition orient you with respect to relevant political developments. We provide such information via our regular newsletter and online promotions or Facebook ads.
By becoming a member, you have consented to the use of your personal data for targeting of marketing communications related to our products. You may at any time request not to receive such communications by unsubscribing from our newsletter. Unsubscribing will not affect your membership or your access to our services.
During the membership purchase process, you may indicate special interests. We use such information to direct special editions of our newsletter containing information about events or products. We do not share the information with external partners.
Similarly, we do not issue marketing communications from third parties based on your special interest information. The information assists us in tailoring our key areas of work and in orienting members, students, and their parents with respect to our initiatives, events, and products.
4. The Newsletter
When you enter your email address at danes.dk, you consent to being subscribed to our newsletter. As a registered newsletter subscriber, you will then receive our newsletters and related information including promotions for our instructional offerings.
You may unsubscribe from the newsletter at any time, and we will immediately delete your email address. Each newsletter contains a link for unsubscribing. In addition, you may at any time direct our data management coordinator to prevent further communications of any kind from being sent to you.
5. What is the process for collecting personal data?
We collect your personal data when you purchase one of our products, subscribe to our newsletter, or are granted a membership in Danes Worldwide from a third party.
If we receive data pertaining to you from a source other than yourself, we will specifically inform you as to:
- The data we have received
- Who provided the data
- The purpose of our maintaining the data
- Contact information for a deletion request
- Our policy on data protection (via a link)
We do not process your data without having express permission via your consent or via a purchase of membership, an instructional product, or a general product or service.
6. Sharing of personal data
Danes Worldwide shares personal data with collaboration partners for the purpose of meeting sales and delivery obligations related to the management of your membership and the services you choose to use through your membership of Danes Worldwide. We share your personal data with our IT suppliers in order to maintain a membership database and to provide online courses, accommodation bookings, language instruction, and other services.
Beyond that, Danes Worldwide shares personal data only if it is required by law, if we have obtained specific consent to the sharing, or if a legal judgment mandates it.
We never share sensitive personal data such as health related details.
Danes Worldwide shares your personal data and information about your membership in Danes Worldwide with the Danes Worldwide Summer School in the event you wish to purchase an instructional product. The Danes Worldwide Summer School is a separate legal entity. The two entities have a formal agreement respecting management of data.
Payment related information is shared with payment system suppliers such as QuickPay. We share only the data points necessary for completion of a payment transaction.
7. Cookies and Logs
In addition to the information you provide during the process of signing up for a membership or making a purchase of products or services on the Danes Worldwide website, we obtain information about your website activity through cookies. Cookies are digital data packets stored on your computer hard drive by the website. Cookies do not contain data that identify a person.
On the basis of information from our cookies we are in a position to streamline navigation and ensure the correct display of website content.
Data collected via cookies is always anonymized. Cookies provide only statistical information.
Users may visit our website without the storing of cookies. Internet browsers are set to accept cookies, but you can change the setting by adjusting the options in your browser. Please note that certain functions on our website may not work if you deactivate cookies in your browser.
- Technical functionality
- Measurements of site traffic
- Enhanced user friendliness
- Determination of the effectiveness of certain services
- Advertisement related data
- Individually tailored ads based on user activity
Find out how to delete or block cookies here: [insert link to English language instructions].
Each visit to danes.dk enables Danes Worldwide to build a statistical log. This log assembles information to provide a statistical picture of website activity – the number of visitors and their geographic location, the page from which visitors leave, etc. We use the log as a tool for optimizing the website and its functionality. Log statistics are anonymous.
Log statistics are used to …
- Enhance user friendliness
- Measure the effectiveness of services
- Document usage of the webshop
- Develop and target marketing initiatives
You may block cookies from Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We use Facebook Pixel on our website to track our ad activity on Facebook. The function ensures that our ads are targeted at relevant individuals and measures ad effectiveness. As a user of the danes.dk website, you may therefore see Facebook ads from Danes Worldwide. Facebook Pixel matches the data from your visit to danes.dk, including IP address and details about your device, with Facebook’s own data to identify your Facebook user name and thus target the ads.
Should you prefer not to receive ads from Danes Worldwide on Facebook, you may adjust your ad preference setting within the Facebook settings here: http://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen (you must be logged in).
Danes Worldwide has implemented several technical and organizational safety measures to protect your data against unauthorized use. Specifically, we have systems in place to prevent accidental or illegal destruction and to safeguard against loss or deterioration as well as to prevent transfer to unauthorized persons, misuse, and use in contravention of data protection legislation.
Danes Worldwide does not store and transfer personal data in encrypted form, however all the personal data we manage is protected by a firewall. When payments are made by credit or debit cards, card details are transmitted to our payment system provider in encrypted form. As a result, Danes Worldwide does not have access to account numbers or bank identifiers.
In addition, we have implemented access management in many of our internal systems to ensure that access to personal data is granted only to staff members with a need to know. We train our staff members on an ongoing basis, and we have developed and put in place a number of policies and procedures to ensure that management of personal data adheres to the principles of GDPR and data protection legislation.
Security measures are reviewed on a regular basis and are revised according to developments in technology.
9. Your Rights
When registered with Danes Worldwide, you enjoy several rights. We can help you exercise those rights, as follows:
- You may at any time get in touch with us to ask about the personal data we have collected about you, ask why we maintain the data, and ask whether we share the data with others.
- You may get in touch to make corrections to your personal data.
- You may request that we permanently delete your data.
- You may request limitations in our management of your data, for example to limit the length of time during which we may retain your data.
- You may request that your personal data be transferred to you and to another data management coordinator (data portability).
- You may object to the management of your personal data, including the use of the data for direct marketing
10. Changes in the Data Protection Policy
Danes Worldwide is committed to meeting the requirements for protection of personal data. Hence changes may be made from time to time in the data protection policy and in the necessary related technical functions to ensure the capacity to protect your privacy.