Data protection and confidentiality are important to Capital of Children (“we”, “us”, or “our”). This Privacy Policy sets out clear guidelines on Capital of Children’s processing of your personal data when you visit our website, Capital of Children, or in other ways interact with us.
1. Data controller and contact information
Capital of Children is data controller for the processing of your personal data:
CoC Office A/S
Kløvermarken 35
7190 Billund
CVR. 34087512
Tlf. +45 28 96 45 19
Email: info@capitalofchildren.com
2. Purpose, legal basis, and types of personal data
Below we have listed for which purposes we may process your personal data when you interact with Capital of Children.
a. To reply to your inquiries
If you contact us via our website, email or in other ways, we will use your personal data to be able to respond to your inquiries. We typically process the following personal data about you, including contact details such as name, address, email, phone number, title, and affiliation.
We use art. 6(1)(f) in the GDPR (the rule on balancing of legitimate interests) as our legal basis. Our legitimate interest is to be able to respond to your inquiries and communicate with you.
We obtain the personal data, that is collected, directly from you.
We will keep your personal data only for the period necessary to fulfil the purposes listed above.
b. Application for Children’s General Assembly
A link for applying to Children’s General Assembly will be published on Capital of Children’s website. If you apply, we will typically process contact details such as name, age, country, e-mail, phone number as well as information about your legal guardian to be able to respond to your application. The data is collected through the online survey tool Qualtrics.
We use art. 6(1)(b) in the GDPR as our legal basis, as we process your personal data to be able to fulfil our agreement regarding your participation or to be able to process and assess your application for participation.
We also use art. 6(1)(a) in the GDPR as our legal basis, to obtain parental consent for the processing of personal data in connection with the participation of a child.
We will keep your personal data only for the period necessary to fulfil the purposes listed above.
c. Use of pictures and videos
In connection with our projects, we will take pictures or make recordings and share them on our communication platforms to inform the public about our projects e.g., on our website or on social media channels.
The pictures or recordings are taken by us or one of our external partners. If you appear in our pictures or recordings, we will ask for your consent if the picture or recording is deemed to require your consent in accordance with Article 6(1)(a) of the GDPR. You can revoke your consent for such processing at any given time by contacting us using the contact details provided above.
However, we may also use Article 6(1)(f) (the rule on balancing of legitimate interest) of the GDPR as our legal basis for processing if we conclude that our legitimate interest of being able to share our work and activities to promote Billund as the Capital of Children legitimises our use of such pictures and recordings. You can always object to the use of pictures or recordings in which you appear by contacting us using the contact details provided above.
d. CCTV surveillance
CCTV surveillance is used to monitor access to the locations, for crime prevention as well as secure the safety of our employees and guests. The recordings may also be used to clarify and document a course of events.
The recordings will only be reviewed in case of suspicion of criminal acts or in case of internal/external audits.
We base the processing of your personal data on the Danish CCTV Act as well as the provision on legitimate interest stipulated in article 6(1)(f) of the GDPR as it is necessary to process the personal data to ensure a sufficient degree of safety for our employees and guests in relation to unauthorized access, suspicious behaviour, protection of assets and to prevent and pursue crime. We use articles 8(3) of the Danish data protection law as a legal basis if the surveillance reveals criminal acts.
We process the following categories of personal data about you:
CCTV recordings of traffic on Capital of Children’s locations.
We transfer the personal data to suppliers of different services (data processors) who process the personal data on behalf of Capital of Children and in accordance with our instructions. We use data processors for the supply of IT systems, software, support, or consultancy services.
Recordings from CCTV surveillance made for the purpose of preventing crime may be disclosed to the police in case of criminal acts, or if the disclosure is required by law. We may, furthermore, disclose the recordings to lawyers and other advisors as well as to public authorities in case it is required by law. If it is necessary to disclose the recordings for other purposes than the above-mentioned, we will ask for your consent to such a disclosure if you are in the recordings.
The CCTV recordings made for the purpose of preventing crime will be deleted or anonymized no later than 30 days after the recording, unless it is necessary to keep the recordings for the purpose of handling a specific case such as solving a criminal offence. If so, we will keep the recordings as long as it is necessary for the processing of the specific event.
Recordings from CCTV surveillance made for other purposes will be deleted when we no longer have a purpose for keeping the information.
e. Vendors
We may process personal data when we enter contracts, have contractual dialogues, ad-hoc supplies, or dialogues about ad-hoc supplies. We typically process name, title, email address, correspondence, phone number, information about powers to bind, and information listed in auto signatures.
We process the personal data to manage our supplier contracts, purchase goods, explore new supplier relationships, and keep track of potential and future business partners.
We use art. 6(1)(f) in the GDPR as our legal basis (the rule on balancing of legitimate interests) as it is necessary to record the personal data to be able to contact our current and future suppliers. We also use art. 6(1)(b) in the GDPR as our legal basis for processing your personal data in connection with the signing of new contracts or management of existing contracts.
We generally obtain your personal data directly from you or from your colleagues in the legal entity which you represent or are employed.
Your personal data will be deleted when it is no longer relevant for the purpose for which it was obtained. E.g., if the negotiations do not result in a contract, 72 months after the end of the contract, or at the end of the limitation period.
f. Use of our website
When you use our website, cookies are used to collect personal data about your behaviour if you give us your consent to do so via the cookie consent. Depending on which cookies you consent to, your cookie consent might enable us to send you marketing via social media platforms such as Facebook, LinkedIn, etc. You can read more about this in the cookie overview which can be accessed through our cookie policy https://capitalofchildren.com/cookiepolicy/
We process your personal data in connection with your use of our website as described above and as further described in our cookie overview. We use necessary cookies based on art. 6(1)(f) in the GDPR (the rule on balancing of legitimate interests). Our legitimate interest is to provide you with a well-functioning website.
If you consent to more categories of cookies, we will process such data on the basis of your consent art. 6(1)(a) of the GDPR.
You can read more about the use of cookies in our cookie policy https://capitalofchildren.com/cookiepolicy/
You can withdraw or change your consent by rejecting cookies in the cookie overview or by blocking cookies in your web browser.
g. Facebook
Capital of Children abide by the guidelines of the Danish Data Protection Agency regarding joint data controllers.
Facebook has published an appendix on the joint responsibility for “Facebook Insight” which you can find via the following link:
https://www.facebook.com/legal/terms/page_controller_addendum
What personal data does Facebook collect?
Depending on your behaviour on the Facebook page, Capital of Children and Facebook may collect the following personal data about you:
Furthermore, Facebook uses “Facebook Insight” on the Facebook page to collect anonymised statistical information about visitors’ behaviour on the page, including gender, relationship status, work, lifestyle, interests, information about purchases and geographical data. For this purpose, Facebook has placed cookies on your devices when you visit the Facebook page. Each cookie contains a unique identification code that will remain active for a period of two years, unless they are deleted before the expiration of this period. Facebook receives, stores and process your personal data through these cookies.
To read more about Facebook’s use of cookies on the Facebook page, please refer to Facebook’s general cookie policy.
Go to Facebook’s cookie policy via the following link:
https://www.facebook.com/policies/cookies/
What is the purpose with processing your personal data?
Capital of Children will also process your personal data to improve Capital of Children’s offerings, improve the Facebook page and conduct surveys, compile statistics, develop and protect Capital of Children’s offerings and products, based on, among other things, your feedback. Capital of Children will use aggregated data, which is made available by Facebook through cookies by “Facebook Insight”, e.g., information about age, gender, relationship status, work, lifestyle, interests, and geographical data.
Facebook processes your personal data to enable Facebook to improve its advertising system and to provide Capital of Children with statistics that Facebook produces based on your visit on the Facebook page, in order to advertise and customise the activities on the page. Through cookies, Facebook and Capital of Children will know if you like the Facebook page and use the page’s applications, and be able to customise the content on the Facebook page and develop functions that you might be interested in.
What is the legal basis for the processing?
Capital of Children processes your personal data based on Capital of Children’s legitimate Interest in improving Capital of Children’s offerings and services as well as in order to carry through competitions that you, a friend or family member attends (Article 6(1)(f) of the General Data Protection Regulation (GDPR)).
Facebook processes your personal data based on Facebook’s legitimate interests, including Facebook’s interest in providing an innovative, individually tailored, secure and profitable service (Article 6(1)(f) of the GDPR). Facebook will also process your personal data in accordance with your consent which you can withdraw at any time via the Facebook settings (Article 6(1)(a) of the GDPR).
For more information about Facebook’s legal basis for the processing of personal data, please refer to Facebook’s general privacy policy under the section “What is our legal basis for processing data?”.
Go to Facebook’s privacy policy via the following link:
https://www.facebook.com/about/privacy#
Who receives my personal data?
Capital of Children does not transfer your personal data to other companies.
Your personal data can be shared with the following categories of recipients:
For more information about who Facebook shares your personal data with, please refer to Facebook’s general privacy policy under the section “How is this information shared?”.
Facebook can transfer your personal data to Facebook in the United States and other third countries. Facebook uses standard contracts approved by the European Commission and apply European Commission decisions on an adequate level of protection as the basis of transfer to third countries. You can find more information under “How do we process and move data as part of our global services?” in Facebook’s general privacy policy. See the general privacy policy via the following link:
https://www.facebook.com/about/privacy#
What are my rights?
Under the data protection legislation, you have several rights:
If you are a Facebook user, you can change your privacy settings to affect how your personal data is collected and processed when you visit and use the Facebook page.
Use the following links to change your settings:
https://www.facebook.com/ads/preferences
https://www.facebook.com/settings
Who do I contact?
Facebook’s general set-up and the agreements Capital of Children has entered into with Facebook suggest, that you must contact Facebook if you wish to exercise your rights. This is due to the fact, that only Facebook are functionally able to take the necessary steps to meet most of your requests.
However, if you believe that Capital of Children can meet your request, you are of course very welcome to contact us. Please refer to Capital of Children’s general privacy policy on Capital of Children’s website for more information on how we process personal data.
You can visit Facebook’s general privacy policy for more information on how Facebook processes your personal data and for Facebook’s contact information at the following link:
https://www.facebook.com/about/privacy#
If you wish to make a complaint in connection to our processing of your personal data, please contact us.
3. Recipients
We may share your personal data with independent data controllers if we are legally required to do so. These recipient categories are:
Your personal data may also be disclosed to our data processors. Such disclosure is subject to data processing agreements, and the data processor may not use the data for other purposes than to perform the processing for us. These data processor categories are:
Furthermore, due to the collaborative nature of social medias, data that you post and other user content, may be accessible by other users of Capital of Children’s websites and social media channels from around the world.
4. Processing of personal data outside the EU/EEA
Capital of Children transfers, stores, and processes your information (including your personal data and content) both inside and outside of Denmark. We may transfer your personal data to third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal data is transferred, stored, or processed by us or by companies carrying out such services on our behalf, we will take reasonable steps to safeguard the privacy of your personal data.
In some cases, we will be transferring your personal data to countries outside the EU/EEA.
If your personal data is transferred to countries outside the EU/EEA, such transfer will take place on the following legal basis:
a. Binding Corporate Rules
b. The country has been approved by the European Commission as having an adequate level of security
c If the country has not been approved by the European Commission as having an adequate level of security, we will transfer the data by use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities.
We use Office 365 with data storage within the EU/EEA. However, data may be transferred or accessed from locations in third countries. Should this be the case, the transfer basis will be in the standard contracts of the European Commission.
5. Sources of personal data
We generally process personal data that is collected directly from you or from the device you are using.
6. Retention of personal data
We will retain your personal data for the period necessary to fulfil the purposes as listed above.
Data may be processed and stored for a longer period in anonymized form or may be retained for a longer period if we are legally required to do so.
7. Your right to withdraw your consent
You may at any time withdraw any consent that we have obtained from you. You can withdraw your consent by contacting us using the contact information stated above in Section 1. If you withdraw your consent, such withdrawal does not take effect until the date of withdrawal. It does, therefore, not affect the legality of our data processing up to the time when you withdraw your consent.
If you withdraw your consent, images depicting you will not be used in new material, and images depicting you in website material or similar will be deleted or made anonymous immediately.
8. Your rights
According to the General Data Protection Regulation and the Danish Data Protection Act, you have certain rights.
Please note that there may be conditions or limitations on these rights. It is therefore not certain that you e.g., have the right of data portability in the specific case - this depends on the specific circumstances of the processing activity.
You can exercise your rights by visiting the settings for your account or by contacting us at info@capitalofchildren.com. If you contact us at info@capitalofchildren.com we will have to verify your identity for security purposes.
9. Changes to this Privacy Policy
From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The updated and current Privacy Policy can be viewed here: (INDSÆT LINK)
10. Links to other websites etc.
Our website may contain links to other websites or to integrated sites. We are not responsible for the contents of the websites of other companies or for the practices of such companies regarding the collection of personal data. When you visit other websites, you should read the owners' policies on the protection of personal data and other relevant policies.
11. Questions and complaints
If you have any questions for this Privacy Policy, or if you wish to complain about our processing of your personal data, please contact us using the contact information provided in Clause 1.
You may also complain to:
The Danish Data Protection Agency
Carl Jacobsens Vej 35
DK-2500 Valby
Tel.: +45 33 19 32 00
Email: dt@datatilsynet.dk
Latest update: 2. February 2023