With this Privacy Policy, we want to ensure that you receive adequate information about our collecting and processing of your personal data, including such information we are obliged to inform you about according to applicable personal data protection regulation incl. the EU Regulation No. 2016/679 the General Data Protection Regulation (“GDPR”).
In this privacy policy we use the term “Personal Data” synonymously with “personal information” or similar expressions as defined in applicable privacy regulation, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
We will update this Privacy Policy periodically and will post updates on the Website. Additionally, this Privacy Policy may be supplemented or amended from time to time by other “privacy notices” posted on the Website or specific pages within the Website or other channels, where we engage with you.
These privacy notices describe in more detail the information we collect on particular pages or areas of the Website, App or other channels, where we engage with you.
1. OUR CONTACT DETAILS
The controller of the processing of personal data explained herein is OmniGraph A/S with its registered address at Bryggernes Plads 17, 1799 København V, Copenhagen, Denmark, unless otherwise is mentioned herein. Please unfold below sections to read more about how to contact us.
- Identity of the Controller(s)
Unless otherwise specified elsewhere, the legal entity being responsible for the collection and processing of your personal data under this Privacy Policy (the “Controller”) is:
OmniGraph A/S,
Bryggernes Plads 17,
1799 København V, Copenhagen, Denmark
E-mail: privacy@omnigraph.com - Our Contact Details If you have any questions or need to get in contact with us we urge you to contact us through;
E-mail: privacy@omnigraph.io
Or through our contact page on: https://www.omnigraph.io/main/contact
2. HOW WE COLLECT AND USE YOUR PERSONAL DATA
When you interact with us, we will collect personal data about you, and use it for various purposes, such as operating this Website and App, enabling you to make use of our various services, including our dashboards, AI driven retail services and more.
If you are asked to provide information, then it is optional for you to disclose such information. The information might, however, be needed for statutory, contractual or practical reasons. We will always clearly indicate whether the information is mandatory. If you refrain from disclosing information which we deem as mandatory, it may be that we will not be able to provide you with the services you have requested (e.g., signing up for a Newsletter, creating a membership or making a purchase through our online shop).
To help personalise and continuously improve our services and communication with you, for instance through our Newsletters, we may upon occasion ask you for information on your personal interests, demographic data or your experience of our products and services. This supplementary information is always voluntary and is used solely to improve our products and services. Further, to improve our targeted advertisement we use information collected on how our customers respond to our advertisement, products and services.
How we collect and use your personal data depends on how you interact with us, and which services you make use of.
We strongly believe and are committed to the protection of the personal data in our custody and control, and we have therefore implemented what we believe are appropriate technical and organisational security measures to protect this personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage.
If you unfold below sections, you can read more about how we collect and process your personal data in different situations, including the general categories of personal data being processed; the source of the personal data that we do not directly obtain from you; the purposes for which personal data is being processed; and the legal basis for the processing.
2.1. How your personal data is collected by us
We may collect the personal data described herein directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:
- You: We collect information directly from you, whenever you: register, subscribe to our services,; contact us with questions or comments; upload content to our Website, Apps, or Social Media Pages; enter any of our promotions; respond to a survey; make a review; opt in to text messages; apply for a job; communicate with us through our Social Media Pages; or fill out any forms on our Website, Apps, or Social Media Pages.
- Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, use our Apps, interact with our Social Media Pages or online advertising, or open our emails.
- Third Parties: We work with third parties who provide services to us, like analytics or advertising companies, data brokers, etc. These third parties share information they have collected with us. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
- Social Media Platforms: Social media platforms share information, which is typically aggregated and doesn’t include personal information, with OMNIGRAPH. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings. If you contact us via our Social Media Pages to make a complaint or service request, then we will collect information related to such complaint of service request from the Social Media Page.
- Cookies: OMNIGRAPH uses cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), web beacons, and other similar technologies to automatically collect information when you visit our Website, use our Apps, or interact with our emails. Through the use of cookies, we may link information about your interactions with our Website, Apps, or emails over time, for example, which pages you visit, which links you use, and how long you stay on each page. We also contract with third party advertising or analytics companies to serve you online ads on other websites. These companies use cookies or similar technologies to collect information about your interactions with our Website and Apps and interactions with other websites. These advertising companies may use and share the information gathered to deliver ads more tailored to your interests. We receive aggregate information from these third parties to understand our advertising effectiveness. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you.
- Publicly Available Data: We may combine the information you provide to us with data that is publicly available and data that we collect on our Website, at our marketing events, or receive from other sources.
2.2. Cookie Information
This Website and our Apps uses 1st and 3rd party cookies and similar technologies to optimize your user experience, and for statistical and marketing purposes. Read more about the cookies and how you can administer and reject these in our Cookie Information on the Website and App.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data for when you have consented to our placement of cookies:
Optimizing your user experience on our Website or in the App:
- The personal data we process for this is:
- IP address
- Data on your behaviour on our website
- If you have made a purchase
- Compilation of visited pages
- The legal basis for this processing is GDPR art. 6(1) a), namely the consent you have granted, when accepting our placement of functional, statistical and/or marketing cookies.
Sharing of data with third party advertising and analytics companies to show you ads on other websites and to understand our advertising effectiveness
- We contract with third party advertising or analytics companies to serve you online ads on other websites. These companies use cookies or similar technologies to collect information about your interactions with our Website and Apps and interactions with other websites. These advertising companies may use and share the information gathered to deliver ads more tailored to your interests. We receive aggregate information from these third parties to understand our advertising effectiveness. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you. The personal data we process for this is:
- IP address
- Data on your behaviour on our website
- If you have made a purchase
- Compilation of visited pages
- The legal basis for this processing is GDPR art. 6(1) a), namely the consent you have granted, when accepting our placement of marketing cookies.
General marketing research, profiling and to tailor or improve our Websites, Apps and our service offerings
- For the purposes of performing general marketing research, we use all information collected about you, as described in this section. We may also use information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- For the purposes of being able to personalize your website and/or app experiences, adapt the content of future Newsletters and membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the personal data described above in this section and information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
2.3. When signed up for Newsletters.
You have the opportunity to sign up to receive information by e-mail about OMNIGRAPH’s products and services, contests and promotions from us (“Newsletters”).
We will only send you Newsletters and other marketing material if you have specifically consented to receive Newsletters from us.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data for when you are signed up for a Newsletter:
Registration, checking the validity of the e-mail and providing you with relevant Newsletter
- The personal data we process for this is mandatory information that you have provided to us when signing up for the Newsletter:
- The legal basis for this processing is GDPR art. 6(1) a), namely the consent you have granted, when signing up to receive Newsletters.
Tailoring our services and offerings to you (personalising the Newsletters send to you)
- The personal data we process for this is mandatory and non-mandatory information that you may have provided to us when signing up for the Newsletter:
- Name
- Company name
- E-mail address
- Date of birth
- Phone number
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in improving our services and providing you with content tailored for your segment.
- PLEASE BE INFORMED THAT YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO OUR PROCESSING OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES INCL. PROFILING RELATED HERETO. Please also refer to SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE)
Tracking of Newsletters to perform general marketing research and to optimize the distribution and use of Newsletters
- For the purpose of optimising the performance of our newsletters, including by identifying the ideal content and sending time to target customers most likely to be considering their next purchase and by optimising the number of emails that each segment should receive to create value via greater engagement and lower unsubscribe rate, we are processing your personal data, including:
- Tracking pixels* (included in the Newsletter), which are used to collect and process personal data such as information on when you open the e-mail and which links in the e-mail you have clicked on.
- The time emails are sent
- Whether or not the email was opened
*A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when an e-mail was opened by the recipient, and which links in the e-mail were called up by the recipient.
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
General marketing research, profiling and to tailor or improve our Websites, Apps and service offering
- For the purpose of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in (SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- For the purposes of being able to personalize your website and/or app experiences, adapt the content of future Newsletters and membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the personal data described above in this section and information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
- PLEASE BE INFORMED THAT YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO OUR PROCESSING OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES INCL. PROFILING RELATED HERETO. Please also refer to SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE)
2.4. When subscribing to our services
We offer you the opportunity to subscribe to our services via our website or through an App.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data if you make or take steps to make a purchase on this Website or any of our other Websites or Apps:
Signing up and registering an account on the app
- The mandatory personal data you provide to us when making a purchase is:
- Name
- E-mail address
- Company Name
- Company Billing Details
- Details of the subscription
- Other information necessary for the purpose of setting up your services such as integrations and account settings
- The Legal basis for this processing is GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
Managing payments on the app
- The personal data we process for this is:
- Name
- Company Name
- Company Billing Details
- Details of the subscription
- E-mail address
- IP address
- Phone number
- Other data necessary for payment processing
- This Privacy Policy describes how we collect information in connection with your interactions with us, e.g. when you use our websites and any other microsites or mobile websites (the “Website”), when you use our applications we make available for download on your device (our “Apps”), or when you use subscribe to and use our services. Additionally, this Privacy Policy describes how we use and share that information. Please take the time to read this Privacy Policy.
- For the purpose of managing payments on our App, we have integrated components of the following online payment service provider (Hereinafter referred to as the “Online Payment Service Providers”). When having selected the relevant payment method, we automatically transfer personal data to the Online Payment Service Providers, which is necessary for payment processing.
- You will provide your credit card details directly to the Online Payment Service Providers, who will then further transfer necessary data to the relevant credit card agencies for identity and creditworthiness checks and payment clearance.
- The Legal basis for this processing is GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
Managing vouchers, membership rewards and gift certificates
- If you have received a voucher, membership reward or a gift certificate, then we will for the purpose of managing such voucher, membership reward or a gift certificate and enabling you to benefit from it, process personal data about you. The personal data we process for this is:
- Name
- Company Name
- E-mail address
- Details of the subscription
- Transaction history
- The Legal basis for this processing is GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are party.
Prevention of fraud, misuse of services and money laundering
- If you sign up for our services, we perform automated fraud checks to minimize the risk of being exposed to fraudulent behaviour and the misuse of credit cards. The personal data we process for this is:
- Name
- Company Name
- Company Details
- Phone Number
- Details of the subscription
- E-mail address
- Credit card number
- Credit card expiry date
- Credit card Security code
- Purchase behaviour for automated decision-making without human intervention to determine whether there is a risk that we are exposed to fraudulent behaviour and misuse of credit cards.
- The Legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in the prevention and protection of us and third parties against fraud, misuse of services, and money laundering.
- If we suspect fraudulent behaviour, then the purchase will not be completed. In case you experience that the purchase is denied, and you want to object to this, please contact our Customer Care in accordance with SECTION 1 (OUR CONTACT DETAILS).
General marketing research and to tailor or improve our Websites, Apps and our service offerings
- For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- For the purposes of being able to personalize your website and/or app experiences, adapt the content of future Newsletters and membership account to better suit to your interests and to provide you with personalized offerings we may also build profiles and inferences based on the personal data described above in this section and information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
- PLEASE BE INFORMED THAT YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO OUR PROCESSING OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES INCL. PROFILING RELATED HERETO. Please also refer to SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE)
2.5. When contacting us
You may always contact us through one of our Customer Care representatives, or e-mail us with a claim, comment or questions.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data if you decide to contact us through one of our Customer Care representatives, or e-mail us:
Customer care – request handling
- When you contact us either through one of our Customer Care representatives, or e-mail us with a comment or question, we will retain and use the following information in order to respond to your request:
- Name
- Company Name
- E-mail address
- Phone number
- Company Subscription, billing, and account details
- Other information, which might be needed to reply to your request
It is always optional for you what information you choose to provide us with. However, please note that in case we do not have sufficient information to process your request, then we may not be able to fully support your request or inquiry. - The Legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interests in providing customer services, understanding customer behaviour and interests and establishing, exercising and/or defending legal claims.
General marketing research, profiling and to tailor or improve our Websites and our service offerings
- For the purposes of performing general marketing research, we use all information collected about you, as described in this section. We may also use information collected about you through other channels as described in (SECTION 1.9 (PROFILING FOR MARKETING PURPOSES)).
- For the purposes of being able to personalize your website and/or app experiences, adapt the content of future Newsletters and membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the personal data described above in this section and information collected about you through other channels as described in SECTION 1.9 (PROFILING FOR MARKETING PURPOSES).
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
- PLEASE BE INFORMED THAT YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO OUR PROCESSING OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES INCL. PROFILING RELATED HERETO. Please also refer to SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE)
2.6. When participating in competitions, product reviews and surveys etc.
Occasionally we may give you the opportunity to participate in competitions, make product reviews or surveys etc. If you choose to participate, then we will be asking you to provide us with certain data.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data if you decide to participate in a competition, product review or survey:
Running competitions and surveys
- The personal data we collect, and process depends on the specific competition or survey etc., but it might include:
- Name
- Company Name
- Company Details such as industry or size range
- E-mail address
- Platform Usage
- It is always optional for you if you want to participate in a competition or answering a survey and therefore it is always optional what information you chose to provide us with. However, providing specific data may be mandatory for entry into a competition or completion of a survey and not providing this information may preclude your involvement.
- The Legal basis for this is GDPR art. 6(1) a) namely the consent you have granted, when choosing to participate in the competition or survey and/or GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
Conducting product reviews
- We may from time to time ask you to provide your feedback about products you have acquired from us. If you participate in a product review, we collect and process the following personal data:
- Name
- Company Name
- Company Details such as industry or size range
- E-mail address
- Data collected through the use of our App
- Transactional data
- Image and video recording of you
- Your opinion about our services
- It is always optional for you if you want to participate in a product review and therefore it is always optional what information you chose to provide us with. But please be aware that providing specific data may be mandatory and to the extent you will not provide such data you cannot participate in the product review.
- The Legal basis for this is GDPR art. 6(1) a) namely the consent you have granted, when choosing to participate in the product review.
General marketing research and to tailor or improve our Websites, Apps and our service offerings
- We use information for running competitions or surveys, but we also use it for general market research purposes and to tailor or improve our Websites, Apps, membership programme and service offerings.
- For the purposes of performing general marketing research, we use all information collected about you, as described above in this section. We may also use information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- For the purposes of being able to personalize your website and/or app experiences, adapt the content of future Newsletters and membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the personal data described above in this section and information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
- PLEASE BE INFORMED THAT YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO OUR PROCESSING OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES INCL. PROFILING RELATED HERETO. Please also refer to SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE)
2.7. Profiling for marketing purposes
OMNIGRAPH wants to better understand our customers to ensure we provide an experience that is relevant and to ensure effective marketing and advertising of OMNIGRAPH products and services. To better understand our customers and to personalise the experience of our Newsletters, App and Websites, we use the personal data we are in possession of to analyse or predict aspects concerning our individual customers’, newsletter recipients’, members’, and website visitors’ personal preferences, interests and behaviour. And to perform general marketing research including customer analysis, customer segmentation and statistics.
If you have identified yourself to us, for example by making a purchase, creating an OMNIGRAPH membership or by giving us your name, e-mail address or phone number, then we may link the personal data we have collected about you as per above sections.
PLEASE BE INFORMED THAT YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO OUR PROCESSING OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES INCL. PROFILING RELATED HERETO. Please also refer to SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE)
If you disagree and want to object to this, please contact us in accordance with the SECTION 1 “OUR CONTACT DETAILS”, and we will then cease to use your personal data for profiling for direct marketing purposes.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data for when profiling our customers:
General marketing research incl. customer analysis and customer segmentation and statistics
- The personal data we process for this is:
- Name
- Company Name
- E-mail address
- Phone number
- Data collected through the use of our Websites and App
- Newsletter-tracking data
- Service Usage
- Online and Offline Transactional Data including abandoned signups, subscriptions, integrations etc.
- We use your data for different analytical purposes to better understand: a) how you browse and use our platforms; b) which products you are interested in; c) which features of our products and platforms you like; d) the quality of our services including customer service, marketing and advertising campaigns addressed to you, and your reaction to these services; e) our product and website design; f) whether overall user experience worked for you or not; and g) which rewards you most commonly redeem in your membership programme. We use this analysis to understand and improve and develop our products and services, our marketing communication to you and the quality of our personalisation experience across our channels and platforms.
- The legal basis for this is GDPR art. 6(1) f) our legitimate interests, namely in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
Personalize your shopping and website experiences and optimise the service you receive
Furthermore, we may use the information to evaluate and assess your individual interests and preferences in order to personalize your shopping and website experiences, membership experience and rewards, and optimise the service you receive from us.
- The legal basis for this is GDPR art. 6(1) f) our legitimate interests namely in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
Customizing Newsletter content and special offers
If you have signed up to receive Newsletters, then we will also use your personal data in order to adapt the content of Newsletters to better suit your interests and to provide you with personalized offerings.
- The Legal basis for this is GDPR art. 6(1) f) namely our legitimate interest in improving our services and providing you with personalized content and offerings.
Audience Management
- We create a profile about you by consolidating all the information you provided to us directly or indirectly. This allows us to personalise our interactions with you. We use audience management technologies to ensure the right messages and information reach you at the appropriate moment through the channels you have used previously or expressed a preference for. This includes sending you marketing messages of offers and product news or addressing you across digital media through ads on Social Media Pages and OMNIGRAPH brand platforms. The level of personalisation depends on the consents you have provided to us and the length and nature of our relationship with you.
- The Legal basis for this is GDPR art. 6(1) f) namely our legitimate interest in improving our services and providing you with personalized content and offerings.
Improve data models
- We use data science and your profile and personal data to create data models that can help us improve the logic in our analytics activities that give us more insight about your comments and feedback, your interactions, behaviour, preference and needs in our products and services. We will compare the data model we created using your profile with other similar consumer profiles and categories to further predict and analyse your preference.
- The legal basis for this is GDPR art. 6(1) f) our legitimate interests namely in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
2.8. Social Media
OMNIGRAPH is present on and operates various Social Media Pages on platforms such as Facebook, LinkedIn and Instagram. We use these to communicate with you and provide you with information related to OMNIGRAPH, our products and services and promotional updates. We may receive information from you through your comments, shared images, messages, and reactions, which we use to answer or communicate with you.
If you use a hashtag that includes OMNIGRAPH, our product names or other information that we search for, we may also use your information to reach out to you, communicate with you and, subject to your consent, use your user generated content on our Website and/or Social Media Pages.
Below you can read more about the types of personal data, the legal basis and the different purposes that we use for processing data on social media:
When visiting our Social Media Pages or when you are engaging with us via social media platforms
- We obtain information about you through different social media channels such as Facebook, Instagram, LinkedIn, Google, etc. when we use these channels for advertising, analytics purposes or to enrich your profile with OMNIGRAPH.
- The personal data we process for this about you include any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”, and comments or messages you shared with us publicly or privately on social media platforms.
- Also, we may be able to obtain information indirectly from social media companies (Facebook, Google, etc.) when we advertise on these platforms. The personal data we process for this include your participation and membership on particular topics and/or groups, your profile settings and preference and your behaviour on different platforms owned by the same company.
- The legal basis for this is GDPR art. 6(1) f) our legitimate interests, namely in understanding customer behaviour and interests, ensuring effective marketing and advertisement of OMNIGRAPH product and services and to provide a great service to our customers.
When we use your user generated content in marketing of our products
- From time to time we invite you to provide your images to us via social media platforms by following specific instructions on the use of hashtags. We will be using the images you provide for our campaign communications. We will obtain rights to your image through your consent provided via the social media platforms.
- By submitting your images via social media platforms to us, you will agree for us to use your images as described in the consent text we ask you to agree to. The personal data we process for this include information about your social media handle, images, videos, comments, sound recordings and other files provided through the social media platform promoting OMNIGRAPH and social media interaction and activity.
- The legal basis for this is GDPR art. 6(1) a) namely the consent you provide when you accept our use of your user generated content.
Advertisement via social media
- We use third-party advertising platforms, such as Facebook, TikTok, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behaviour and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns.
- In order to do this, we share your personal data with our advertising agency partners as well as social media platforms. We use third-party solutions such as Google Analytics and Facebook Business Manager tools to help us do a better job at targeting our campaigns and messages for our consumers.
- Social media platforms will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from OMNIGRAPH. We also need to analyse necessary information to understand the impact of our campaigns.
- If you don’t accept that we track you for this purpose, you will still see OMNIGRAPH advertisements on social media platforms and other third-party platforms at random. Please also read the privacy notice on the social media platforms to understand how your personal data is used by them for this purpose.
You can learn more about how our advertising partners and social media platforms help us achieve this purpose by visiting their sites:
Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en
Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956
Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531
Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience - The legal basis for this is GDPR art. 6(1) f) our legitimate interests, namely in understanding customer behaviour and interests and ensuring effective marketing and advertisement of OMNIGRAPH product and services.
Meta as a joint controller
Meta is a Joint Controller of the Joint Processing and information required by Article 13(1)(a) and (b) GDPR can be found in Meta’s Data Policy at https://www.facebook.com/about/privacy.
The information that you use Applicable Products as well as the purposes for which the collection and transmission of Personal Data that constitutes the Joint Processing takes place as set out in the Applicable Product Terms.
Further information on how Meta processes Personal Data, including the legal basis Facebook Ireland relies on and the ways to exercise Data Subject rights against Facebook Ireland, can be found in Meta’s Data Policy at https://www.facebook.com/about/privacy.
Meta and OMNIGRAPH has entered into a Controller Addendum to determine the respective responsibilities for compliance with the obligations under the GDPR with regard to the activities for which we are joint controllers.
Meta and OMNIGRAPH has agreed that OMNIGRAPH are responsible for providing Data Subjects as a minimum with the information required under the GDPR and which is set out in this Privacy Policy.
Meta and OMNIGRAPH has also agreed that between Meta and OMNIGRAPH, Meta is responsible for enabling Data Subjects’ rights under Articles 15-20 of the GDPR with regard to the Personal Data stored by Meta after the Joint Processing.
General marketing research, profiling and to tailor or improve our Websites, Apps and our service offerings
- For the purposes of performing general marketing research, we use all information collected about you, as described in this section. We may also use information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
- For the purposes of being able to personalize your website and/or app experiences, adapt the content of future Newsletters and membership account to better suit to your interests and to provide you with personalized offerings, we may also build profiles and inferences based on the personal data described above in this section and information collected about you through other channels as described in SECTION 2.9 (PROFILING FOR MARKETING PURPOSES).
2.9. Online Marketing and re-targeting
When entering the OMNIGRAPH Website and App and to the extent you have given us your consent to place cookies on your device, we will be using cookies and similar technologies to track your activities on our Website and use your information to target advertising to you across different channels and devices (also known as “cross-context behavioural advertising”).
Beside cookie technology and information processed by use hereof, we might also process other personal data we have about you for online marketing and re-targeting purposes.
If you have identified yourself to us, for example by making a purchase, creating an account or by giving us your name, e-mail address or phone number, then we may also use the personal data we have collected about you as per above sections.
If you disagree and want to object to this, please contact us in accordance with the SECTION 1 “OUR CONTACT DETAILS”, and we will then cease to use your personal data for profiling for marketing purposes.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use for online marketing and re-targeting:
Online marketing and re-targeting
- The personal data we process for this is:
- E-mail address
- Data collected through the use of our Websites and Apps
- Newsletter-tracking data
- Membership information, including tier, points and available rewards
- Interaction with our app
- Your profile inferred through this information cf. SECTION 2.9 (PROFILING FOR MARKETING PURPOSES)
- The legal basis for this is GDPR art. 6(1) a) namely the consent you provide when you accept our use of marketing cookies.
3. HOW WE SHARE YOUR PERSONAL DATA WITH OTHERS
In order to make our services available to you, provide you with requested services and support and in general to operate our business, we will have to disclose and transfer your personal data to third parties, such as IT suppliers, marketing agencies, logistics service providers, payment service providers etc.
When using service providers and contractors to process your personal data on our behalf (also referred to as “data processors”) we require, that they only process your personal data in accordance with our instructions. We also require that the data processors signs relevant contracts providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the data processing will meet the requirements of the applicable data protection regulation and ensures an appropriate protection of your rights.
In case we disclose your personal data to third parties, who will not be acting as a data processor under our instructions, but as independent data controllers, then we do our best to ensure that they are trustworthy and have implemented appropriate technical and organisational measure to protect your data.
Unfold below sections to read more about how we share your personal data.
3.1. Categories of Recipients
The main categories of potential recipients of your personal data are:
A. Service Providers acting as data processors
We may share your personal data with our trusted third party service providers, who, on our behalf, operate, maintain, and/or support our IT systems and IT infrastructure, our Websites, manage our payment solutions, perform statistical analysis, sending Newsletters, provide customer support and perform other important services for us.
B. Service Providers acting as independent controllers
We may also share your personal data with our trusted third party service providers, who will use your personal data for their own purpose and thus will act as independent data controllers. These third party service providers include logistic service providers, payment service providers and our external auditors.
C. Third party advertising partners like Facebook, Google and LinkedIn
We use third party advertising partners to collect information about your use of our Website in order to serve targeted advertising and to measure the performance of our advertising campaigns. The third party partners we use may collect this information using tracking technologies, such as pixels, cookies, APIs and SDKs.
Facebook (Meta): You can read more about how Facebook Ireland processes your personal data in their Data Policy at https://www.facebook.com/about/privacy.
Google: You can read more about how Google uses information shared with them here: https://policies.google.com/technologies/partner-sites
Instagram: You can read more about how Instagram uses information shared with them here: https://privacycenter.instagram.com/policy.
LinkedIn: You can read more about how LinkedIn uses information shared with them here: https://www.linkedin.com/legal/privacy-policy.
D. Legal Successors
A transfer of your personal data to another legal entity may occur as part of a transfer of our business or parts thereof in the form of a reorganization, sale of assets, consolidation, merger or similar.
E. Other disclosures
In addition to where you have consented to a disclosure of the personal data or where disclosure is necessary to achieve the purpose(s) for which it was collected, personal data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defence of legal claims.
3.2. Transfer of data to third countries
The use of service providers and disclosure of your personal data to other recipients might imply a transfer of your personal data to countries, which might not have data protection regulation as protective as in your jurisdiction and might not be considered ensuring an adequate level of protection of personal data by the EU Commission or a national data protection authority (so called “unsafe Third Countries”).
We require that all recipients of your personal data provide appropriate safeguards to protect your personal data, when it is transferred to “unsafe Third Countries”. This is among other lawful means ensured through the adherence to standard data protection clauses as applicable under the EU GDPR article 46(2) or the EU-U.S Data Protection Framework if data is transferred to the USA. Please refer to the following link to obtain more information about the standard data protection clauses we in general use visit http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
We may also share your personal data with other third parties in other countries if you have given your consent to do so, if we are required to do so by law, if it is necessary for an association dissolution or a merger with another association or another similar event, or if it is necessary in connection with legal proceedings or to assert or defend claims.
If you have any questions, please contact us in accordance with SECTION 1 (OUR CONTACT DETAILS).
4. HOW WE RETAIN AND DELETE YOUR DATA
Your personal data will be held by us and kept in a form, which permits identification of you for no longer than is necessary for the purposes for which the personal data is collected and legitimately processed.
This implies that we will keep and process your personal data as long as we are providing services to you and also keep it afterwards for as long as would be needed for:
- the establishment, exercise or defence of potential legal claims and disputes.
- compliance with tax, VAT, accounting and other mandatory regulation.
We will delete any information, which according to our reasonable assessment seems to be inaccurate or out of date by reason of the time elapsed since it was collected or by reason of any other information in our possession.
If you provide us with a written request, we will also erase or anonymize your personal data without undue delay, unless we have a valid legal ground to continue to keep your personal data. Please also refer to SECTION 5 (YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).
5. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE
You have certain rights according to the applicable data protection regulation. Some of the rights are rather complex and include exemptions, accordingly you are recommended to read relevant laws and guidance from the regulatory authorities for full explanation of these rights. However, you can find a summary of your rights, if you unfold below sections.
5.1. The right to access
You have a right to obtain the confirmation as to whether or not your personal data are being processed by us. In addition, you have a right to obtain more detailed information about the personal data kept and the processing undertaken by us and under certain circumstances the right to receive a copy of this personal data.
5.2. The right to rectification
You have the right to have inaccurate personal data about you rectified, and, taking into account the purpose of the processing, to have incomplete personal data completed.
5.3. The right to erasure
In some cases, you have the right to erasure of your personal data without undue delay. Those circumstances include but are not limited to; i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; ii) you withdraw consent to consent-based processing; iii) the processing is for direct marketing purposes and/or iv) the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary; i) for the exercising the right of freedom of expression and information; ii) for compliance with legal obligation; or iii) for the establishment, exercise or defence of legal claims.
5.4. The right to restriction of processing
In some cases, you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. However, we will only otherwise process it i) with your consent; ii) for the establishment, exercise or defence of legal claims; iii) for the protection of the rights of another natural or legal person; or iv) for reasons of important public interest.
5.5. The right to data portability
To the extent the legal basis for the processing is your consent, and such processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
5.6. The right to object
You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for i) the performance of a task carried out in the public interest or in the exercise of any official authority vested in OMNIGRAPH; or ii) the purpose of legitimate interests pursued by us or a third party. In such case we will cease processing the personal data, unless we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
You also have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
5.7. The right to withdraw consent
To the extent that the legal basis for the processing is your consent, you have the right to withdraw from that consent at any time.
In case you withdraw from a consent given, then we will cease to process your personal data, unless and to the extent the continued processing is permitted or required according to the applicable personal data regulation or other applicable laws and regulations. The withdrawal from your consent will in no event effect the lawfulness of processing based on consent before its withdrawal.
If you refrain from providing required consents, or later on withdraw from the consents, it might have as a consequence that you may not be able to benefit from some of the service offerings provided by us.
5.8. The right to complaint to data protection supervisory authority
You may always lodge a complaint with your local data protection supervisory authority. The data protection supervisory authority in Denmark is
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Tlf. 33 19 32 00
www.datatilsynet.dk
We do our best to ensure that we protect your personal data, keep you informed about how we process your personal data and comply with the applicable data protection regulation. In case you are not satisfied with the processing and protection of your personal data or the information you have received from us, then we urge you to inform us in order for us to improve. Please also do not hesitate to contact us if you want to make use of your rights.
Please contact us through the points of contact listed in SECTION 1 (OUR CONTACT DETAILS). Please also provide us with relevant information to take care of your request, including your full name and email address so that we can identify you. We will respond to your request without undue delay.
You can always withdraw from a consent to receive Newsletters etc. and unsubscribe from an e-mail list by following the instructions in any e-mail or other communication you receive from us.
If you have created an account with us, then you can also manage your account by logging into the account.
6. LINKS TO OTHER WEBSITES
We may provide links to third party websites. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our Websites. Before disclosing your personal data on any other website, we advise you to examine the terms and conditions of using that website and its privacy policies.
7. CHANGES TO THIS PRIVACY POLICY
We reserve the right, at our discretion, to add, modify or remove portions of this Privacy Policy in the future to ensure that the information herein provides relevant and adequate information about our collecting and processing of your personal data.
This Privacy Policy may be supplemented by other information received from us and other terms and conditions applicable to this Website or which you have agreed to as part of interacting with us.
You can always find the updated version of our Privacy Policy at https://omnigraph.io/legal/privacy-policy
If you have consented to receive Newsletters and other information from us, we will also inform you directly about any updates to this Privacy Policy through e-mail.
