HH Mentality - Personal data policy
1. Establishment of appropriate security measures
The data processor must take the necessary technical and organizational security measures against information being accidentally or illegally destroyed, lost or degraded, and against it being disclosed to unauthorized persons, misused or otherwise processed in breach of the Personal Data Regulation and other legislation.
The data processor may only use persons who are subject to a confidentiality obligation to carry out their tasks in accordance with this agreement.
The data processor must generally assist the data controller in fulfilling his obligations towards the data subject. This entails, among other things, that the data processor, at the data controller's request, must provide the data controller with sufficient information so that the latter can ensure that the mentioned technical and organizational security measures have been taken and ensure that a timely notification of security breaches can be made to the Data Protection Authority.
The data controller has the right to demand access to the physical premises of the data processor and can also demand an annual audit statement.
2. What personal information do we collect, and with purpose and legal basis
2.1.1. Use of HHmentality.com
When you use the website, we automatically collect information about the type of browser you use, which search terms you use on the website, your IP address, including your approximate network location, and information about your computer. Read more about our use of cookies in ourcookie policy.
2.1.2.
The purpose is to generate statistics on use of the website, to optimize the user experience and the function of the website, as well as to carry out targeted marketing via Facebook and Google.
2.1.3.
The legal basis for the processing is the EU Personal Data Regulation, art. 6, subsection 1, letter f.
2.2. Information about persons who are not clients
When you download e-books, guides or other material available to non-clients, we collect the information you provide yourself, eg your name, email, phone number. When you communicate with us in writing or by telephone, we process the personal data you give us.
2.2.1.
The purpose is to be able to deliver the service to you, to comply with legal requirements, including for bookkeeping and accounting, as well as to offer a product or other services that are relevant to you.
2.2.2.
The legal basis for the processing is the EU Personal Data Regulation, art. 6, subsection 1, letter bc and f.
3.3. Newsletter
When you give consent to receive news and offers, etc. from us, we collect information about your name, e-mail address and possibly mobile number, and when you receive the newsletter, we register whether you open the newsletter and which articles you click on, etc.
3.3.1.
The purpose is to be able to deliver the newsletter and bring news that is relevant to the readers of HH Mentality's other products.
3.3.2.The legal basis for the processing is the EU Personal Data Regulation, art. 6, subsection 1, letter f.
4. Recipients of personal data
4.1.
Google Analytics v/Google LLC. And Facebook Inc. is established in the United States. The necessary guarantees for the transfer of information to the USA are secured through the data processor's certification under the EU-US Privacy Shield, cf. EU Personal Data Regulation art. 45.
4.2.
Copy of Google LLC's certification can be found here:https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI
4.3.2.
A copy of Facebook Inc.'s certification can be found here:https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
5. Your rights
5.1.
In order to create transparency around the processing of your information, we, as the data controller, must inform you of your rights.
5.2. The right of access
5.2.1.
You are entitled at any time to request information from us about, among other things, what information we have registered about you, what purpose the registration serves, which categories of personal data and recipients of information may be may be, as well as information about where the information originates.
5.2.2.
You have the right to receive a copy of the personal data that we process about you. If you would like a copy of your personal data, you must send a written request tohh@mentality.com. You may be asked to document that you are who you say you are.
5.3. The right to rectification
5.3.1.
You have the right to have incorrect personal data about yourself corrected by us. If you become aware that there are errors in the information we have registered about you, you are encouraged to contact us in writing so that the information can be corrected.
5.3.2.
Information that we have collected in connection with your creation of a user profile, you have the opportunity to correct yourself via log-in to your user profile.
6. The right to erasure
6.1.
In certain cases, you have the right to have all or some of your personal data deleted by us, e.g. if you revoke your consent and we have no other legal basis for continuing the processing. To the extent that continued processing of your information is necessary, e.g. for us to comply with our legal obligations, or for legal claims to be established, asserted or defended, we are not obliged to delete your personal data.
6.2. The right to restrict processing to storage
6.2.1.
In certain cases, you have the right to have the processing of your personal data limited to storage only, for example if you believe that the information we process about you is incorrect.
6.3. The right to data portability
In certain cases, you have the right to have personal data that you yourself have given us delivered in a structured, commonly used and machine-readable format and you have the right to transfer this data to another data controller.
6.4. The right to object
6.4.1.
You have the right at any time to object to our processing of your personal data for the purpose of direct marketing, including the profiling carried out in order to be able to target our direct marketing.
6.4.2.
You also have the right at any time, for reasons relating to your personal situation, to object to the processing of your personal data that we carry out on the basis of our legitimate interests, cf. 2.1 to 2.6.
6.5. The right to withdraw consent
6.5.1.
You have the right at any time to revoke a consent you have given us for a given processing of personal data. If you wish to withdraw your consent, please contact us athh@hhmentality.com.
6.6. The right to complain
You have the right to lodge a complaint at any time with the Norwegian Data Protection Authority, Borgergade 28, 5, 1300 København K about our processing of your personal data. Complaints can be lodged, among other things, by email dt@datatilsynet.dk or telephone +45 33 19 32 00.
7. Deletion of personal data
7.1.
Information collected about use of the website cf. pt. 2.1. deleted when the purpose of the processing is no longer present.
7.2.
When your consent to the newsletter is withdrawn, information collected in connection with your registration for our newsletter is deleted. However, documentation for your subscription to the newsletter will not be deleted until 2 years have passed since the last newsletter was sent to you.
8. Security
8.1.
We have implemented appropriate technical and organizational security measures against personal data being accidentally or illegally destroyed, lost, changed or degraded, as well as against unauthorized access or misuse.
9. Contact information
9.1.
HH Mentality is the data controller for the personal data collected via the website.
9.1.2.
If you have questions or comments about this personal data policy or wish to make use of one or more of your rights, you can contact:
HH Mentality
Langebrogade 5,
1411 Copenhagen K
Tel. no.: +45 22 35 21 70
Email: hh@mentality.com
10. Changes in the personal data policy
10.1.
If we make changes to the personal data policy, you will be informed about this on your next visit to the website.
10.2.
You will be notified of changes to the policy by sending information to your registered email address.
11. Versions
11.1.
This is version 1 of HH Mentality's personal data policy dated 05 March 2019.