1. Introduction

This privacy policy applies to Insero A/S' processing of personal information that we receive:

• Via CITYFACTS' website
• In connection with delivery of CITYFACTS subscriptions
• In connection with participation in R&D projects and activities

It is important to Insero A/S that your personal information is stored and processed safely and legally. For that purpose, we have developed this privacy policy ("Privacy Policy"), describing how we collect and process your personal information.

You are encouraged to read the Privacy Policy thoroughly.

2. Contact information for the data responsible

• Insero A/S
• VAT number 32 65 45 33
• Chr. M. Østergaards Vej 4A
• 8700 Horsens
• Mail: GDPR@insero.com

3. Description of Insero A/S processing of personal information

3.1 Delivery of CITYFACTS data collection

Purpose:

Delivery of CITYFACTS:

Personal information is used to contact you for delivery of CITYFACTS subscription which you have entered into with Insero A/S.

Support and customer service:

Support in connection with delivery of CITYFACTS subscription as well as other inquiries to our customer service.

Categories of personal information:

We process the following categories of personal information.

General personal information, e.g.:

• Name
• Address
• Email
• Phone number
• Name, position, phone number and e-mail of any customer contacts
• Payment information
• Information on annual energy and water consumption
• CITYFACTS subscribed addresses
• BBR information and other information in properties that have subscribed to CITYFACTS
• Heat consumption (kWh)
• Temperature forward
• Temperatur return
• Flow
• Thermal effect
• Volume (accumulated flow)
• Electricity consumption
• Electrical output
• Water consumption
• COP factor
• SCOP factor
• Presence
• CO2 concentration
• Temperature
• Humidity

Sources:

We collect information from the following sources:

• Information that we have received from you
• Data from CITYFACTS sensors
• Information from other publicly available sources, e.g. BBR and tingbogen.dk

Basis for processing:

We process your personal information on the following basis:

• If necessary for the fulfillment of an agreement to which you have entered.
• If it is necessary for us to comply with a legal obligation, e.g. the law of bookkeeping
• Necessary in view of Insero A/S' legitimate interest in sending you newsletters and otherwise offering you effective customer service
• Explicit consent

Recipients:

We may forward your personal information under the following circumstances

(i) To affiliated companies.

(ii) To suppliers that we collaborate with to support our company.
e.g.:

• Suppliers of services, technical support and customer service
• Delivery services.

(iii) If required by a court order or current legislation.

(iv) With a view to developing and improving our products and services to:

• Data and analysis agencies
• Creative and digital agency partners
• Consultancy
• Digital media partners

Storage:

We will store personal information as long as necessary for the purposes mentioned

• In connection with the delivery of the CITYFACTS subscription, we store your personal data for up to five years after the end of the customer relationship according to the law of bookkeeping unless there are special reasons to storage the information in a longer period.

Personal information regarding general inquiries from potential customers will be deleted when the information is no longer needed.

3.2 Forwarding of newsletter

Purpose:

Personal information is used to forward newsletters that you have signed up for.

Categories of personal information:

We process the following categories of personal information.

General personal information - e.g.:

• Name
• Address
• Email
• Phone number

Sources:

We collect information from the following sources

• Information that we have received from you.

Basis for processing:

We process your personal information on the following basis

• Explicit consent.

Recipients:

We may forward your personal information under the following circumstances

(i) To affiliated companies.

(ii) To suppliers that we collaborate with to support our company.
e.g.:

• Suppliers of services, technical support and customer service
• Delivery services.

(iii) If required by a court order or current legislation.

Storage:

We will store personal information as long as necessary for the purposes mentioned

• As long as a given consent to receive newsletters has not been withdrawn and we are not required to keep your personal data - e.g. in connection with a legal obligation.

3.3 Statistics and optimization

Purpose:

Statistics

• Personal information is used to develop statistics for yours and others use of our website

Optimizing the user experience on our website, including retargeting via Facebook, Linkedin and Google

• Personal information is collected using our website. We use this information to optimize the user experience on our website and the services we offer.

Categories of personal information:

We process the following categories of personal information

General personal information - e.g.:

• Name
• Address
• Email
• Phone number
• Use of digital services, including newsletters
• Interest and preferences including as collected by use of cookies.

Sources:

We collect information from the following sources

• Information that we have received from you.
• From affiliated companies.

Basis for processing:

We process your personal information on the following basis

• Necessary for the pursuit of Insero A/S' legitimate interest in compiling statistics, as well as optimizing the user experience on the website.

Recipients:

We may forward your personal information under the following circumstances

(i) To affiliated companies.

(ii) To suppliers that we collaborate with to support our company. e.g.:

• Suppliers of services, technical support and customer service
• Delivery services.

(iii) If required by a court order or current legislation.

(iv) In order to develop and improve our products and services for:

• Data and analysis agencies
• Creative og digital bureau partners
• Consultansies
• Digital media partners

Storage:

We will store personal information as long as necessary for the purposes mentioned

• If you have given consent to receive newsletters or marketing, we will store personal information until you withdraw this consent, unless we are obligated to store the personal information, e.g. in relation with a legal obligation.

3.4 Participation in R&D projects and activities

Purpose:

Personal information is used to collect and process data related to implementation of R&D projects and activities.

Categories of personal information:

We process the following categories of personal information.

General personal information, e.g.:

• Address
• Installation number
• Heat consumption (kWh)
• Temperature - heating
• Operating mode settings
• Thermal effect
• Electricity consumption
• Electricity flexibility
• Gas consumption and information about gas boilers
• Room temperature at installation address
• Electrical output
• Water consumption

Sources:

We collect information from the following sources.

• Information that we have received from you
• Data from CITYFACTS sensors and other measurement sources
• Information from other publicly available sources, e.g. BBR and tingbogen.dk

Basis for processing:

We process your personal information on the following basis.

• If necessary for the fulfillment of an agreement to which you have entered.
• If it is necessary for us to comply with a legal obligation, e.g. the law of bookkeeping
• Necessary in view of Insero A/S' legitimate interest in sending you newsletters and otherwise offering you effective customer service
• Explicit consent

Recipients:

We may forward your personal information under the following circumstances

(i) To affiliated companies, including Best Green A/S.

(ii) To suppliers that we collaborate with to support our company. e.g.:

• Suppliers of services, technical support and customer service
• Delivery services.

(iii) If required by a court order or current legislation.

(iv) In order to develop and improve our products and services for:

• Data and analysis agencies
• Creative og digital bureau partners
• Consultansies
• Digital media partners

(v) For partners in the implementation of R&D projects and activities.

Storage:

We will store personal information as long as necessary for the purposes mentioned

• In connection with implementation of R&D projects and activities, we store your personal data for up to five years after the project has been completed in accordance with the law of bookkeeping and rules of EUDF, unless there are social reasons for storing the information for a longer period.
• To the extent that personal data is included in R&D projects and activities supported by EU funding, personal data is stored for up to 10 years after the project has been completed.

4. Transfers to countries outside EU/EEA

We can transfer your personal information to countries outside EU/EEA including the United States. Transfers to third countries will only take place for specific purposes, as mentioned under point 3.

Transfer to a country outside EU/EEA will only take place if the EU Commission assess that the country/countries or the company/companies, either through legislation or through other measures, ensure a sufficient level of protection of personal data. For instance, this can happen to US companies that we are cooperating with and that are certified under the EU-US Privacy Shield (https://www.privacyshield.gov/list).

5. Mandatory information

The following information is necessary:

• If you wish to receive newsletters from Insero A/S: Name, email
• If you wish to be contacted by Insero A/S: Name, address, email, phone number

6. Your rights

In connection with Insero A/S' processing of your personal information, you have the following rights:

• The right to receive information about how Insero A/S processes your personal information (disclosure obligation)
• The right to gain access to your personal information
• The right to have incorrect personal information corrected
• The right to have your personal information deleted
• The right to object to your personal information being used for direct marketing
• The right to move your personal data (data portability).

All of the above rights are handled manually by contacting the person responsible for personal information at Insero A/S.

Insero A/S may refuse requests that are considered unserious or harassing and refuse requests if, for legal reasons, Insero A/S is entitled or obliged to do so.

You always have the option to unsubscribe from a newsletter or other communication received via email using the unsubscribe link directly in the email. In addition, you can make use of your rights by sending an email to: GDPR@insero.com.

 

7. Safety

Insero A/S has implemented security measures to ensure that our internal procedures have a high level of security focusing on data protection. Insero A/S ensures that necessary technical and organizational security measures are taken against accidental or illegal destruction, loss or deterioration of personal data and against personal data being misused or otherwise treated in violation of the laws of treatment of personal data. Finally, access to data is managed based on a necessity principle. This means that access to your data is only given to those employees who need access. This applies to Insero A/S as well as to partners and to Insero A/S' data processing staff.

8. Complaints

You have the opportunity to have a complaint processed regarding the collection and processing of personal data by contacting Insero A/S via email: GDPR@insero.com. You also have the opportunity to complain to the Danish Data Protection Agency, Borgergade 28, 5., 1300 København K.