DATA PROTECTION AND PRIVACY POLICY FOR FLEXTRIBE APS

Date of last change in the privacy policy: February 9, 2021,

Flextribe ApS processes personal information and has therefore adopted this data protection and privacy policy, which briefly describes how we treat your personal information to ensure proper and transparent processing.

Throughout our data processing, we only treat personal data for specific purposes and based on legitimate interests. We process only personal information that is relevant and necessary for fulfilling the stated purposes and we will delete your information when they are no longer necessary.

1) The Data Controller

Flextribe ApS is the data controller and we ensure that your personal information is processed in accordance with the laws.
Contact info:
Flextribe ApS
Ragnagade 7 2100 København Ø
www.flextribe.io
e-mail: hello@flextribe.dk
CVR-nr.: 39724936

2) Processing of personal data

We treat the following personal information:
1) Information about employees, former employees and applicants:
› General Personal Information:
– Registration and contact information such as name, gender, address, phone number, e-mail address, bank account number
› Personal Information Added a Higher Protection:
– Social Security No.
– Optionally: Person and behavioural analysis

2) Information about customers, former customers and potential customers:
› General Personal Information:
– Contact information such as name, address, phone number e-mail address, professional interests and purchase history
› Personal Information Added a Higher Protection:
– None

3) Information about consultants, former consultants and potential consultants:
› General Personal Information:
– Contact details such as name, picture, address, telephone number e-mail address, bank account number, professional interests, competencies and CV
› Personal Information Added a Higher Protection:
– Optionally: Person and behavioural analysis

4) Information about shareholders:
› General Personal Information:
– Registration and contact information such as name, address, phone number, e-mail address, bank account number
› Personal Information Added to a Higher Protection:
– Social Security No.

3) Here we collect information from

Normally, the information is received directly from the registered person. In some instances, information from other sources is obtained/received:
› TAX – to collect tax information concerning personnel matters
› POLICE – for obtaining statutory certificates or the like.
› SOCIAL MEDIA eg. LinkedIn and Slack

4) Flextribe’s purpose in processing your personal information

We treat your personal information for specific purposes when we have a legitimate reason.
Legal reasons for treatment are special:
› Flextribe’s legitimate interests in processing your information (the interest rate rule)
› Required to fulfil a contract/agreement
› Treatment according to legal requirements
› Treatment with consent

The objectives:

a) Purpose of processing information on employees:
› Managing employment conditions
› Payment of salaries including pensions, allowances, refunds and similar
› Compliance with legal requirements

b) Purpose of processing information on customers:
› Flextribe’s customer administration, including hourly registration and billing for completed work
› As part of Flextribe’s activities, including planning, implementation and follow-up of projects, deliveries and administration of the relationship between the parties.
›Newsletters and invitations to events if consent has been given
› Compliance with legal requirements

c) Purpose of processing information on consultants:
› Flextribe’s consultancy administration including time registration and payment for work done
› As part of Flextribe’s activities, including planning, implementation and follow-up of new projects/tasks, ongoing projects, deliveries and management of the relationship between the parties.
› Newsletters and invitations to professional events if consent has been given › Compliance with legal requirements
d) Purpose of Processing Information on Shareholders:
› Handling of owner’s book and purchase/sale of shares
› Payment of any yield
› Compliance with legal requirements

5) Treatment Basis

Flextribe treats common personal data of the registrants as described above under item 2 based on the following treatment bases:

a) The balance of interests rule
To the extent that we process your personal information based on the Weighing Rules, this treatment will be motivated only by legitimate interests such as
› Handling of contracts and agreements entered into
› Fulfilment of payment and collection obligations
› Organisation of social and professional events and other activities
› Exchange of personal information between customers and consultants as part of the company’s primary purpose; to act as a sales company and network for independent consultants.

b) Treatment according to legal requirements
Flextribe is required by law to obtain and record a variety of information from and to public authorities such as Police and Tax

c) Consent
Have you consented to treatment, such as when receiving newsletters and invitations to events, Flextribe processes your information relevant to this? If we obtain your consent, you will voluntarily agree, and you may withdraw your consent at any time by notifying us.

6) Disclosure of your personal information

In connection with the operation and administration of Flextribe, the disclosure of relevant information is provided to business partners and suppliers that perform system operations/hosting, maintenance of the company’s business systems, auditing and accounting.
In addition, necessary information is provided to public authorities, including TAX and POLITI. If it follows from a court order or legal basis in other legislation.
Flextribe does not disclose any personal information to other persons or companies for marketing purposes.
Flextribe does not disclose personal information to persons or companies to third countries or outside the EU.

7) Data Processor Agreement

Paying customers of the Platform will receive a Data Processor Agreement to be read and signed. The agreement states the rights and obligations of both parties for when Flextribe is processing personal information on behalf of the Data Controller. This Agreement is based on the standard published by Danish Authorities (Datatilsynet) which has been designed to ensure the Parties’ compliance with Article 28, sub-section 3 of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), which sets out specific requirements for the content of data processing agreements. The Data Processing Agreement contains, but is not limited to, the following points:

  • that Flextribe shall solely be permitted to process personal data on documented instructions from the Data Controller unless processing is required under EU or Member State law to which Flextribe is subject.
  • that Flextribe shall ensure that persons authorized to process personal data on behalf of the Data Controller have undertaken to observe confidentiality, or is subject to a suitable statutory obligation of confidentiality.
  • that Flextribe shall take all the measures required pursuant to Article 32 of the General Data Protection Regulation
  • that Flextribe shall meet the requirements of the General Data Protection Regulation in order to engage another processor (subprocessor).
  • that Flextribe shall assist the Data Controller with appropriate technical and organisational measures, in the fulfilment of the Data Controller’s obligation
  • that Flextribe shall be under obligation, at the Data Controller’s discretion, to erase or return all the personal data to the Data Controller
  • that Flextribe is able to show documentation to the data controller.

8) Subprocessors

Flextribe collaborates with various subprocessors in order to provide the Platform. We utilize third parties to store the Platform, collect feedback, analyze user behavior, fix errors, process payments, send emails, create contracts and communicate with the users in order to provide customer support and information about the product and to meet the requirements stated by Danish Law. The subprocessors may get access to your information, bot solely with the purpose of facilitating the best possible contract management Platform as stated above. They are solely allowed to process data under the instruction you are giving us. Our subprocessors are required to have a privacy policy and security standards in place that is at least as protective of your information as is this Privacy Policy.

Flextribe has the Data Controller’s general consent for the engagement of sub-processors. Flextribe shall, however, inform the Data Controller of any planned changes with regard to additions to or replacement of other data processors and thereby give the Data Controller the opportunity to object to such changes. Such notification shall be submitted to the Data Controller a minimum of 14 days prior to the engagement of sub-processors or amendments coming into force. If the Data Controller should object to the changes, the Data Controller shall notify the Data Processor of this within 7 of receipt of the notification. The Data Controller shall only object if the Data Controller has reasonable and specific grounds for such refusal.

9) Storing and deleting your personal information

General personal data will be deleted as of a rule no later than three years after termination of use unless for accounting or legal reasons there is a need to extend the time period or the registrant requests this before that date.

10) Your rights

You have several special rights when we process personal information about you:
> The right to be informed about the processing of data
> The right to access personal data
> The right to rectification
> The right to delete
> The right to limit treatment
> The right to data portability (data delivery in a commonly used format)
> The right of objection

You may make use of your rights, including objections to our treatment, by contacting us. You can find our contact information at the top.
You can complain about the processing of information and data regarding you. Complaints submitted to Datatilsynet, Borgergade 28, 5, 1300 København K, Tlf. 33 19 32 00

11) Revision of privacy policy

We may make changes to this privacy policy on an ongoing basis. Changes will change the date at the top of the privacy policy. The current privacy policy will be available on our website www.flextribe.io