- Purpose of the policy
- Description of the processes
Mac Baren Tobacco Company A/S, Ministry of Snus processes your data for one or more specific purposes and in accordance with data protection rules. We process your data, for example, if you are a customer of ours through our webshop, business partner, supplier, visit our website or our social media and apply for a job with us. The information will predominantly come directly from you, and we will only process your information for as long as it is necessary for the purpose for which it was collected.
You can read more about the types of processing we do below.
2.1.1. Customer relations
Mac Baren Tobacco Company A/S, Ministry of Snus processes personal data of private customers in connection with the sale of our products and merchandise via our web shop in order to conclude and perform a contract (GDPR Art. 6(1)(b)). This information includes contact details such as name, email, address, country, and telephone number as well as purchase history and payment details. In connection with purchases via our web shop, we also process personal data in the form of photo ID, as we must require the presentation of valid photo identification (GDPR art. 6(1)(c)) and § 2a of the Decree on the Act prohibiting the sale of tobacco and alcohol to persons under the age of 18 (Statutory Order no. 964 of 26/08/2019).
We delete the data on an ongoing basis, but no later than 5 years after the end of the customer relationship.
2.1.2. Website and cookies
2.1.3. Social media
We use the social media LinkedIn, Facebook and Instagram to get in touch with our customers and potential customers, as well as to promote our marketing efforts. If you have “liked” our fan page on the social media or have been in contact with us through this, we avoidably process your personal data. For this purpose, we only process information about your name and email, and possibly information about your purchase, if this is apparent from the context.
If you contact us through social media, we process your personal data on the basis of our interest in being able to contact you and respond to your enquiries, as set out in GDPR Article 6(1)(f). The data will originate from you and the social media through which you contact us.
We have a joint data responsibility with the social media we use, as we both process your personal data for our own purposes. You can read more about the social media’s processing of your personal data below:
Data processed in the context of social media that relates to direct communication via social media is deleted immediately. Posts on, for example, Facebook pages or in public groups are not deleted, as a post or comment on Facebook pages or in public groups is considered to be in the public domain. You can read more about public areas here
2.1.4. Job applicants
If you apply for a job with us, we process your personal data for the purpose of assessing whether you are qualified for an existing or future position with us in accordance with GDPR Art. 6(1)(b). We process the information you provide to us, including your name, contact details, work and education history, education level, CV, application, availability date, video presentation and references. References are obtained only if deemed relevant and with your consent.
We also process information about you based on our legitimate interest as set out in GDPR Art. 6(1)(f). This includes, for example, information collected from social media published by you. In this case, we consider that our interests in processing your personal data outweigh your interests in not having the data processed.
In a possible recruitment process, logic and personality analysis may be used In this context, ordinary personal data will be processed, where the basis for processing is following a legitimate interest pursuant to GDPR Art. 6(1)(f). If the need for processing sensitive personal data arises, you will be asked to give your consent pursuant to GDPR art. 9(2)(a). When you apply for a job with us, HR, management and any trusted employees will have access to your data.
If you have applied for a job advertised with us, your data will be automatically deleted after six months. If you wish to delete your data before the six months, please send an email to HR@halberg-as.dk with the information.
Unsolicited applications are kept for six months. 14 days before the six months have elapsed, you will receive an email with the option to consent to a further six months of retention. If you do not accept this consent or do not respond to the e-mail, your consent and thus your data will be deleted. If you wish to delete your data within the next six months, please send an email to HR@halberg-as.dk with the information.
If you choose to subscribe to the Job Agent, your data will be kept until you stop subscribing to the Job Agent.
2.1.5. Suppliers and business partners
When we enter into agreements with suppliers and business partners, we process their contact information. This includes information on name, job title, telephone number, e-mail and, if necessary, payment or bank details.
The data is processed either because it is necessary for the performance of the contract with the supplier or business partner concerned (GDPR Art. 6(1)(b)) or because we have a legitimate interest in processing the contact details of the person concerned as part of the contract (GDPR Art. 6(1)(f)).
We keep relevant contact information throughout our cooperation. Written correspondence is deleted on an ongoing basis, and information necessary to fulfil our obligations under the Accounting Act is kept for 5 years plus the current financial year.
- Recipients of personal data
We process your personal data with confidentiality and as a rule we do not disclose the information to third parties. However, we may disclose your personal data if you have given your consent or we have a legitimate interest in disclosure.
We may transfer personal data to our system providers who process personal data on our behalf and under our specific instructions pursuant to the data processing agreement.
Some of our data processors, and the social media platforms we share data responsibility with, are located outside the EU, resulting in a transfer to a third country. In this case, we have ensured a lawful basis for the transfer, including by applying the EU Commission’s standard rules.
- Your rights
You have several basic rights under the data protection rules that you can exercise when we collect information about you. Your rights include the right to request access to and rectification or erasure of your personal data, restriction of and objection to our processing, and the right to receive your data in a structured, commonly used, and machine-readable format (data portability)
The above rights may be subject to conditions and limitations. Whether you as a data subject can request, for example, the erasure of your personal data, will in all cases depend on a specific assessment.
If you have given your consent to our processing of your data, you have the right to withdraw this consent at any time.
If you are dissatisfied with our processing of your personal data, you can lodge a complaint with the Danish Data Protection Authority via their website www.datatilsynet.dk or by calling 33 19 32 00.
- Our contact details
The company responsible for processing your personal data is: :
Mac Baren Tobacco Company A/S, Ministry of Snus
CVR.nr: 88 21 22 15
Grønnemosevej 6, 5700 Svendborg
Tlf.: +45 63 22 53 50
If you have any questions regarding our processing of your personal data, please contact us at email@example.com or by phone +45 63 22 53 50
We reserve the right to update and amend these guidelines for the processing of personal data. In the event of material changes, we will notify you by e-mail or by a visible notice on our website.