Privacy Policy / GDPR

Privacy Policy 
1.    INTRODUCTION

1.1    By using the website www.nomadcph.com and affiliated services, you consent to Nomad CPH IVS’ (hereafter ”Nomad CPH”, ”we”, ”us” or ”our”) processing of your personal data as described in this privacy and cookie policy (the “Policy”).

1.2    This Policy applies to all Nomad CPH’s users and customers from the 25 May 2018. Nomad CPH reserves the right to amend this Privacy Policy at any time with appropriate notice to the users and customers.

2.    DATA CONTROL

2.1    Data controller
Nomad CPH is the data controller and we ensure that personal data is processed in accordance with applicable laws.

2.2    We take the protection of your personal data seriously
We are collecting and processing personal data whilst operating the website www.nomadcph.com and have therefore adopted this Privacy Policy to inform you of how we process the personal data we collect about you and use when you use our services.  

2.3    We ensure fair and transparent data processing
When we ask to make your personal data available to us, we will inform you of the personal data we are processing and the purpose hereof. You will receive this information when your personal data is being collected. 

2.4    Contact information. If you would like to get in touch with us, our contact information is:

Nomad CPH
Lille Strandstræde 20, parterre th. 
1254 Copenhagen
Denmark 
CVR: 39649012
Email: hello@nomadcph.com

3.    PROCESSING OF PERSONAL DATA


3.1    Usage of without signing up for services
It is possible to use our website without our collection of your personal data as described in the following. By using the website, we might use cookies, and deactivating cookies can potentially reduce our website’s functionality. You can read more about cookies in section 6 below.



3.2    Processing of personal data when you sign-up for service, make a purchase or contact us. We are using your personal data when we are providing our services to you, improving and ensuring the quality of the Service and in our contact with you.

The personal data we use mainly includes
- Personal data in the form of contact and bank information
- Information from inquiries to us, complaints, feedback, etc. 
Nomad CPH does not collect personal data about our users or customers from any third party.

3.3    We collect and keep your personal data for specific purposes
We collect and keep your personal data in accordance with specific purposes or other legal commercial purposes. It occurs when we need to:
- Administer your relation to us, including in the sign-up process;
- Process your purchase and deliver our service, including executing your order
- Perform your request for special services
- Improve our services;
- Adjust our communication and marketing to you In the following, you can read more about the individual services. We always strive to comply with the general principle described for each individual service.

3.3.1 Orders

[SHORT DESCRIPTION OF THE SERVICE AND THE PURPOSE]
Nomad CPH processes the following information:
- First name
- Surname
- Address
- Email
- Telephone no.
- Country
- Reg and account no.
- Login & password
- IP address(es)

For the use of our service Nomad CPH is processing the following for the use of:
- Login and browser data, if approved by the user
- Administering payments as well as bookkeeping
- Order history
- Complaints
- Events
- Message at the website
- Data which is automatically collected given the user activity on the website (cf. the cookie policy below)
If you are ordering goods on our website we will transfer your data as follows:
- Name and address to Webshipper and GLS, to be able to send and deliver the goods.
- Email information to Trustpilot solely for the use of Trustpilot being able to contact you by email to let you assess the buying process.

We will process this information based on your consent, and comply with the other terms in this Policy.



3.3.2    Newsletters
On our website as well as during the placement of your order you can separately subscribe to our newsletter. You can always unsubscribe from these services in each inquiry. You will not receive other newsletters or other unsolicited commercial inquiries from our partners without your prior consent.

We use the service Klaviyo to send out our newsletter. If you subscribe to our newsletter your name and email will be transferred to Klaviyo.

We use technology from Klaviyo that enables us to see if you have clicked links in your campaign. We only use the information for statistical purposes. 

4.    PROCESSING OF PERSONAL DATA



4.1    Disclosure of personal data
In order to deliver our services to you, it is necessary to disclose relevant personal data on you to business partners acting as suppliers e.g. order and return management, payment solutions, etc.
 
We only use data processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the relevant data protection laws, including ensuring the protection of the rights of the data subject.

4.2    We only process relevant personal data
We only process personal data about you which is relevant and sufficient in accordance with the purposes defined above. The purpose is decisive for the types of personal data we process about you. The same applies to the scope of the personal data that we use, e.g. we do not use personal data more extensively than what is necessary, in accordance with the specific purpose.  

4.3    We only process relevant personal data
We only collect, process and store personal data which is essential in relation to fulfill our specific purpose. Additionally, it may be determined by the law which kind of personal data is essential in order to collect and store for our business operations, e.g. accounting legislation. The type and extent of the personal data we process may also be required to fulfill a contract or other legal obligation.

4.4    We check and update your personal data
We ensure that the personal data which we process about you is not incorrect or misleading. We also make sure to update your personal data continuously. 
As our service depends on your correct and updated personal data, we kindly ask you to inform us if there are any relevant changes regarding your personal data. You may log in on your profile via our website or use our contact information above to notify us of your amendments. 

4.5    We delete your personal data when it is no longer necessary to keep
We will delete your personal data when it is no longer required in relation to the purpose that was the reason for our collection, processing, and storage of your personal data. We will store personal data that we are obliged to keep in accordance with the law, if any, e.g. bookkeeping legislation. In addition, we delete inactive user profiles, called “members”, after one year’s inactivity. Before erasure, we will provide the user with a notice.

4.6    We obtain your consent before processing your personal data
We will obtain your consent before processing your personal data for the purposes described above unless there is another legal basis for the collection. We will notify you of such a legal basis and of our legitimate interests for processing your personal data, e.g. if the processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract.    
Your consent is voluntary and you can at any time withdraw it by contacting us. Use the above-stated contact information if you wish to withdraw your consent or want further information. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

4.7    We do not disclose your personal data without your consent.
We will collect your consent and give you information concerning what your personal data will be used for before we disclose your personal data to business partners and others, e.g. for marketing purposes. You can, at any time, object to this kind of disclosure. [For users with a Danish CPR-no., you can also opt-out of certain unsolicited marketing inquiries by contacting the CPR-register via borger.dk].  
We do not collect your consent if we are legally obliged to disclose your personal data, e.g. as part of a regulatory filing with an authority.  

5.    SECURITY

5.1    We protect your personal data
We protect your personal data to avoid unintended loss or amendment, against unauthorized publication and against unauthorized persons accessing your personal data.   
We use data processors in the EU who store and process personal data on behalf of Nomad CPH in accordance with this Privacy Policy and the current legislation. 
If you signed up for our newsletter your name and email may be transferred to Klaviyo’s servers in the USA. Klaviyo is Privacy Shield certified, cf. https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG, which meant that the EU Commission decided that Klaviyo ensures an adequate level of protection.
Should a breach of security occur, we will as soon as possible inform you if the breach may result in a high risk to your rights e.g. theft of ID, economic loss, discrimination of you, loss of reputation or other significant inconvenience.

6.    USE OF COOKIES 

6.1    Cookies, purpose and relevance
By using the website, you may provide us with your consent in order to use cookies to collect information about you to adapt and improve our content and to increase the value of the advertisement shown on the website. If you do not want your data to be collected, please delete your cookies (see instructions below) and refrain from any further use of the website. We have elaborated on what data is being collected, the purpose and third-parties’ access to these below.

6.2    What are cookies?
The website uses ”cookies”, which is a text file that is saved on your computer, mobile phone or similar devices with the purpose of recognizing the device, remembering settings, performing statistics and targeting advertising. Cookies cannot contain damaging code such as viruses.

It is possible to delete or block cookies.
See instructions at: http://www.youronlinechoices.com/uk/faqs
If you delete or block cookies, advertising can become less relevant for you and occur more frequently. Furthermore, you can risk that the website will not operate optimally, as well as content not being accessible.

6.3    Which cookies are used:

 
6.3.1    First-party cookies
Nomad CPH uses cookies on our website to optimize the website and the functionality. Our cookies help us making your experience as good as possible when you visit our website. Below you can read more about which cookies Nomad CPH uses as well as the purpose

6.3.2    Third-party cookies
We allow third parties’ to place their cookies on our website (so-called third party cookies). We use marketing and optimization cookies to optimize the services on our website. This includes Google Analytics, which we use to analyze how you use our website. The collected data will be sent and stored at Google’s servers.



7.    YOUR RIGHTS AS DATA SUBJECT



7.1    You have the right to access your personal data

You have the right, at any time, to receive information about the personal data we are processing about you, where the data is collected from, and what we are using it for. You also have the right to be informed about the period for which the personal data will be stored and who the recipients of your personal data are, if we transfer your personal data inside Denmark and/or abroad. If you request so, we can inform you of, and provide you with, a copy of the personal data we process concerning you. The access can, however, be limited to ensure other people’s privacy protection, trade secrets and intellectual property rights.You can use your rights by contacting us. You will find our contact information at the top.



7.2    You have the right to have inaccurate personal data corrected, restricted or deleted. If you think the personal data we are processing about you is inaccurate, you have the right to request correction or restriction. You must contact us and inform us about the inaccuracies and how to rectify the information or may be restricted. 
In some instances, we are obliged to delete your personal data. This might be the case if you withdraw your consent. If you are of the opinion that your personal data is no longer necessary in accordance to the purpose for which we collected them, you are entitled to request their deletion. You can also contact us if you are of the opinion that your personal data is being processed contrary to applicable law or other legal obligations.    
We will investigate if the conditions are fulfilled, when you make a request of having your personal data rectified, restricted or erased. If so, we will carry out the amendments or deletion as fast as possible. 



7.3    You have the right to object
You have the right to object, on grounds relating to your particular situation, to processing of personal data concerning you. You may also object to our transfer of your data for direct marketing purposes. You can use your rights by contacting us. You will find our contact information at the top. If your objection is justified we will cease to process your personal data.

7.4    You have the right to data portability
You may have the right to data portability to the extent that the processing is carried out by automated means. Data portability involve a right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller without hindrance.



7.5    Lodge a complaint if you wish to make a complaint about our processing of your personal data, you have the right to contact the Danish Data Protection Authority (“Datatilsynet”), Borgergade 28, 5th floor, 1300 Copenhagen K, +45 3319 3200, E-Mail: dt@datatilsynet.dk