XO CARE may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. In the event of significant changes, you will be notified via email.
This policy is intended to provide adequate and consistent safeguards for the handling of personal data in accordance with the General Data Protection Regulation (GDPR) Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the Danish Data Protection Act.
2 PURPOSES, LEGAL BASIS AND DELETION
- Our legitimate interest in providing, maintaining and improving our current products and services in accordance with GDPR art. 6(1)(f);
- Our legitimate interest in developing new products and services in accordance with GDPR art. 6(1)(f);
- Provide and deliver the products and services you request and send you related information in accordance with GDPR art. 6(1)(b);
- Our legitimate interest in facilitating communications between users in accordance with GDPR art. 6(1)(f);
- Our legitimate interest in responding to your comments, questions and requests and provide customer service and support in accordance with GDPR art. 6(1)(f);
- Our legitimate interest in sending you technical notices, updates, security alerts and support and administrative messages in accordance with GDPR art. 6(1)(f);
- Communicate with you about products, services, offers, promotions and events offered by XO CARE and others, and provide news and information we think will be of interest to you. Our legal basis is our legitimate interest in processing your personal data in order to provide the news and brochures in accordance with the GDPR art. 6(1)(f) and you marketing consent when forwarding the news and brochures in accordance with section 10(1) of the Danish Marketing Practices Act.
- Our legitimate interest in personalizing and improving our products and services and provide tailored advertisements, content or features in accordance with GDPR art. 6(1)(f);
- Our legitimate interest in monitoring and analyzing trends, usage and activities in connection with our products and services in accordance with GDPR art. 6(1)(f);
- Our legitimate interest in linking and combining information we get from others to help understand your needs and provide you with better service in accordance with GDPR art. 6(1)(f);
- Completion of orders in our online web shop. Our legal basis is the contract you enter into in accordance with the GDPR art. 6(1)(b); and
- Legitimate interest in being able to establish, exercise or defend legal claims in accordance with art. 6(1)(f) and art. 9(2)(f) of the GDPR.
We will delete your personal data when we no longer need to process them in relation to one or more of the purposes set out above. However, the data may be processed and stored for a longer period in anonymised form. As a starting point your personal data will be deleted.
Some of the processing activities above are further described in section 3 below e.g. in relation to special retention periods.
3 VISITORS TO XO-CARE.COM
3.1 DATA COLLECTED WHEN YOU SUBSCRIBE TO XO NEWS
You may at any time unsubscribe directly in the mail containing XO News. Your personal data are stored as long as you receive the news and up to 2 years after withdrawal of consent or from the time the marketing consent is no longer valid.
3.2 DATA COLLECTED FROM YOU WHEN ORDERING A BROCHURE
- Language preference
After we have sent the requested brochure, your data will be deleted.
4 EXISTING OR POTENTIAL XO CARE END-CUSTOMERS
- Phone number
- Professional information, hereunder the company you represent, your title, etc.
Our legal basis for the processing of your personal data is either (i) the performance of the contract to which you or the company you represent is party in accordance with the GDPR art. 6(1)(b) or (ii) our legitimate in being able to keep your as a business contact in accordance with the GDPR art. 6(1)(f).
Data will be deleted 3 years after collection or if requested by the potential customer.
5 PARTNER EMPLOYEES WHO REGISTER AT XO-CARE.COM
XO CARE collects and maintains data concerning partner employees as required by MDD 93/42/EEC concerning medical devices, by EN ISO 13485 and by XO CARE’s quality management system.
Our legal basis for the processing of your personal data is our legal obligation in accordance with the GDPR art. 6(1)(c) as well as our legitimate in managing the business relation with the company you represent in accordance with the GDPR art. 6(1)(f).
The data are stored while the partner employee is working at the XO CARE Partner and 5 years thereafter.
6 JOB APPLICANTS
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Cookies are passive files that cannot collect information stored on your device nor carry computer viruses or install malware.
- Traffic log information: to identify which pages are being used, including including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our services registering when you visit the website. This helps us analyze data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
- Device information: we collect information about the device you use to access our services, including information about the device’s software and hardware, Media Access Control (“MAC”) address and other unique device identifiers, device token, mobile network information and time zone identifying your http requests when using the website.
- Usage information: we collect information relating to your use of our services, including which applications you use and your game progress, scores, achievements and interactions with other players.
Consumption information: we collect information about your consumption habits relating to your use of our services, including which purchases you make with both virtual and real currencies.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
XO CARE collaborates with advertisers, media agencies, and networks. The purpose of such cookies is generally to ensure the delivery of targeted online ads on behalf of our collaborative partners. Therefore, the following companies also place session or persistent cookies on our website: Google and Facebook.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
The procedure for deleting or disabling cookies on your device depends on the browser you are using.
If you are using a PC, you may delete cookies by using the keyboard shortcut [CTRL]+[SHIFT]+[Delete]
- Internet Explorer
- Mozilla Firefox
- Google Chrome
- Flash cookies
8 DISCLOSURE OF YOUR PERSONAL DATA
To fulfil the above purposes we may provide access to your personal data for third parties who, on the basis of a contractual relationship with XO CARE provide relevant services, e.g. IT-providers, invoicing providers and email providers. Such service providers will only process personal data in accordance with our instructions pursuant to the data processor agreements entered into.
In connection with XO CARE’s development, the company structure may change, e.g. through a full or partial sale of XO CARE. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, as a general rule, art. 6(1)(f) of the GDPR, as XO CARE has a legitimate interest in handing over part of its assets as well as making commercial changes.
- Public authorities
- Utility companies
- Prospective buyers
Under certain circumstances the data may be shared with relevant XO CARE Partners for professional purposes, if your request relates to their area of responsibility. Our existing XO CARE Partners can be found here: https://www.xo-care.com/xo-partners/.
Your personal data is not transferred to data controllers or data processors located outside the EU/EEA.
9 LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
11 CONTROLLING YOUR PERSONAL INFORMATION
- Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
- If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing the data controller – see below
- We will not sell, distribute or lease your personal information to third parties
- You may request details of personal information which we hold about you
- If you would like a copy of the information held on you please write to the data controller – see below
- If you believe that any information, we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect
12 DATA CONTROLLER
XO CARE A/S is data controller and shall ensure that all personal data are handled according to the applicable data protection rules.
Responsible manager: Thomas Brogaard
Address: Håndværkersvinget 6, DK-2970 Hørsholm, Denmark
CVR: 46 93 67 28
Phone No.: +45 26 16 76 16
13 YOUR RIGHTS
You are at any time entitled to be informed of the personal data about you that we process, but with certain legislative exceptions. You also have the right to object to the collection and further processing of your personal data including profiling/automated decision-making. Furthermore, you have the right to have your personal data rectified, erased or blocked. Moreover, you have the right to receive information about you that you have provided to us, and the right to have this information transmitted to another data controller (data portability).
You may, at any time, withdraw any consent you have given and we will no longer process your personal data, unless we can continue the processing based on another purpose. If you wish to withdraw your consent, please contact us at firstname.lastname@example.org.
If you wish to appeal against the processing of your personal data, please contact us as indicated above. You may also contact the Data Protection Agency, Carl Jacobsens Vej 35, Copenhagen 2500 Valby.
This policy is effective from 2019-02-26