Last updated 24. October 2019
1. VisitVejles ambition concerning your privacy
2. Application of data protection legislation
3. Scope and your acceptance
4. What personal data we process
5. VisitVejle as data controller
6. Why we process your personal data
7. How we collect your personal data
8. Automatic data collection tools
9. How we share your personal data
10. Your rights
11. Access and rectification
12. Data security and retention
13. VisitVejle as a data processor
13. A. Subcontractors and export of personal data
14. Changes to this Policy
15. How to contact us
“Users”: E.g. Marketing collaboration partners, customers, consumers, tourists visiting our platforms, contact persons and software users among our partners incl. persons representing new partners that approach us via VisitVejles platforms and third party social networks, jobseekers etc.
“Platforms”: Websites, Newsletter database system, Image and Video database system, Tourist attractions database system.
“Third party social networks”: Youtube, Instagram, Facebook, LinkedIN
“Marketing activities”: E.g. Newsletters, marketing campaigns, events, workshops, fairs etc.
“Personal data”: Personal data is information that can identify you as a person, e.g. an email address, street address or phone number.
“Data controller”: Legal entity determining the purpose and means of processing your data.
“Data processor”: Legal entity processing data on behalf of our partners based on their instructions.
VisitVejle is under the Vejle Municipality (Vejle Kommune) and a part of the public sector in Denmark.
VisitVejle promotes the Vejle region nationally as well as internationally including resources from local businesses, institutions and other parties with relations and an interest in tourism as much as possible.
VisitVejles office is located in Vejle. All VisitVejles entities, are located in the Vejle region, and are therefore subject to European data protection- and privacy regulations and directives. Our privacy policies and guidelines respect and comply with applicable privacy legislation in the countries in which we operate. We also work continuously on adapting to the new General Data Protection Regulation and EU/US Privacy Shield framework for data transfers to the US. All major decisions regarding privacy in VisitVejle are made at a corporate level.
This Statement is available on our visitvejle.com website.
The type of data that VisitVejle might process about you may be:
(a) Our users contact details such as: Name, address, telephone number and e-mail.
(b) IP address.
(c) Employment information about you and the company you are employed at, such as: Job title, position including preferences and interests – only in professional context.
(d) Personal data you provide us with due to our marketing collaboration and competitions.
(e) Personal data you provide us with due to seeking a job at VisitVejle.
(f) Feed-back, comments or questions provided by you while using VisitVejle platforms or third party social networks.
(g) Content you have uploaded on VisitVejle platforms or third party social networks.
(h) Unique user information such as: Login ID, username, password and security question.
(i) Financial information, e.g. credit card information, bank account number.
(j) Personal data you provide us with answering surveys.
(k) Tracking information as provided by your web browser such as browser type, language and the address of the website from which you arrived.
(l) Clickstream behavior such as which links you click on and when.
(m) Other personal data contained in your profile on third party social networks.
We may also in some cases compare a collected IP address with a geographic map service to derive your general location. If you make a post, comment or similar on any public forum or VisitVejle platforms or third party social networks, such information can be read and used by anyone with access to our platforms and third party social networks and used for purposes over which neither VisitVejle nor you have control. VisitVejle is not responsible for any information you submit to such forums.
We may also while planning specific events with collaboration partners ask for personal data such as: Passport number, expiry date, date of birth, sex, home address, diets, allergies, spouse etc.
VisitVejle will not post any photo, comment, testimonials or similar made by you without your prior consent.
VisitVejle control personal data that we collect in the context of you being:
(a) employed by a partner that has or may have a business relation to VisitVejle
(b) a user who declares that you want to receive information from VisitVejle based on your own or your employer’s interests.
(c) a jobseeker
When you represent a partner or user of VisitVejle, your rights are the same as if you were a private person only representing yourself.
To manage our user relations in general and to meet our user commitments, VisitVejle requires some information about you or you being a user of our platforms and third party social networks. Our aims with this are:
(a) Provide offers on marketing collaboration, marketing activities, digital marketing services such as marketing activities on third party social networks, and data reports on insight travel knowledge that users have requested.
(b) Inform about and present our marketing collaboration and digital/data services that are closely related to the services and marketing collaboration with you as a user.
(c) Perform deliveries in accordance with a partner/or customer agreement.
(d) Offer support to users of our platforms.
(e) Improve the quality of our marketing campaigns and platforms.
(f) Communicate and improve information that is relevant for our users in general.
(g) Process orders, invoicing, payments and other financial follow up.
(h) Payment of programs and services purchased through VisitVejles platforms.
(i) To manage access to our platforms.
(j) To manage information about you if you are a jobseeker.
If you are a jobseeker we gather information in order to:1) analyze your skills and background and 2) evaluate your potential as a future VisitVejle employee. The basis for VisitVejle processing your personal data when being a jobseeker is based on your voluntary consent.
Processing according to the above listed purposes (a to j) is necessary for us to manage our user relations. Therefore VisitVejle do not, as additional ground ask for your consent to process your personal data. We do not consider that the processing disadvantages you in any way.
In some cases, we may also collect information about you from other legitimate sources if you have given your consent that the party collecting the personal data may share this with others. These sources may be third party data aggregators, VisitVejle marketing partners, public sources or third party social networks.
VisitVejle uses a variety of technologies to collect information about your movements on the web as well as interest and preferences you freely have made available.
VisitVejle uses digital marketing software and digital re-marketing services that employs cookies or data in order to recognize a return visitor as a unique user. The cookies placed by this software are readable only by the vendor of the software, and cookies cannot access, read or modify any other data on your computer. We do link the information we store in cookies to any personally identifiable information you submit while on our platforms or third party social networks.
VisitVejle uses tracking tools which allows us to see information on user platforms activities including, but not limited to page views, source and time spent on our platforms. The information is depersonalized and is displayed as statistical overview, meaning it cannot be tracked back to individuals. This will help to protect your privacy.
As VisitVejle consists of different business entities, there is a great likelihood that a partner or customer will conduct business with more than one business unit. It is important for us that we provide the best possible partner/user experience when collaborating with VisitVejle. In order to maintain a complete overview and insight into which partners and users have relations with the various business entities, we will therefore share your data among our local business entities. The aim of this is to ensure that you can access the relevant information on time and that you are not contacted more often than is necessary for you or for VisitVejle.
VisitVejle does only share your personal data with third parties who intend to use the data for marketing purposes if you have given your consent.
However VisitVejle is part of the public sector in Denmark. Which means that anyone can ask for access to data handled by VisitVejle as a public authority according to Danish Law (Forvaltningsloven and Offentlighedsloven). Access to personal information will be handled by VisitVejle in compliance with Danish Law.
Right to opt-out of marketing communications
You have the right to opt-out of receiving marketing communications from VisitVejle and can do so by following the instructions for opt-out in the relevant marketing communication
Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from VisitVejle.
You have the right to request a copy of your personal data. You may send us a request for this on: firstname.lastname@example.org. You also have the right to request that VisitVejle correct any inaccuracies in your personal data.
How we keep your personal data secure
VisitVejle takes your personal data seriously. VisitVejle is committed to prevent unauthorized access, disclosure or other deviant processing of your data. Further, VisitVejle is committed to ensure proper use of the information, to maintain data integrity and to secure data availability. As part of our commitment, we utilize reasonable and appropriate physical, technical, and administrative procedures and measures to safeguard the information we collect and process. VisitVejle has implemented a number of security measures, which secure your personal data.
Please note that these protections do not apply to the personal data that you choose to share in public areas such as third party social networks.
How long we store your personal data
VisitVejle will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve problems and to comply with legal requirements under applicable laws.
This means that we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we collect is no longer required in this way, we destroy or delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
VisitVejle provides many different services to our partners. These services involves processing of the partners’ data and may include processing of personal data. The purposes of this processing is determined by our partners and not by VisitVejle. The partner is then the data controller for the data subject’s data. VisitVejle do in such cases act as data processor and process the data on behalf of and according to instructions given by the partner. When acting as data processor, VisitVejle is in accordance with the requirements applicable to data protection legislation always committed to enter into a data processing agreement (DPA) with the partner.
When acting as data processor, VisitVejle is responsible for providing technical and organizational security measures in order to safeguard your privacy on behalf of our partner - the data controller.
As data processor, VisitVejle will not process personal data in any other manner or for any other purpose than as authorized in the agreement with the data controller.
Data subjects having questions, comments, claims or any other issues regarding their personal data that VisitVejle is data processor for, must submit these to the data controller. As data processor, VisitVejle will not give any data subjects access to their personal data without instructions given by the data controller to do so. If governmental authorities or the police request disclosure of personal data, VisitVejle will promptly notify the data controller and we will disclose such data only to comply with applicable laws or a court order.
VisitVejle will provide non-public information about internal systems and routines for data processing to collaboration partners upon request. This may be contingent upon a non-disclosure agreement.
In some cases, VisitVejle will use subcontractors to process personal data, and we may export your or our partners data outside the EU. These subcontractors are typically vendors of cloud services or other IT hosting services. When using subcontractors, VisitVejle as data processor will always enter into a data processing agreement (DPA) in order to safeguard your privacy rights and/or to fulfil our obligations towards our partners.