GDRP
Privacy Policy relating to the processing of your personal data as a buyer or tenant of our properties or as a business contact
NRE Denmark A/S (CVR no.: 30 48 85 12, Finsensvej 3, 7430 Ikast) and our affiliated real estate companies (collectively "we" or "us") process personal data on private buyers and tenants of our properties and on our business contacts. In some cases, we also process personal data about you as owner of a one-man business or a partnership company (“self-employed person”).
We will always process your personal data in a safe and confidential manner in accordance with applicable data protection legislation, and we have implemented appropriate measures to protect the data against the risks involved in the processing.
Who is data controller?
When bying or renting our properties
NRE Denmark A/S ("NRE") is the data controller in connection with the processing of your personal data received in general correspondence (by email or telephone), in discussions regarding vacancies or properties for sale, and in replies to general inquiries.
When you enter into a purchase or tenancy agreement, however, it is the real estate company in the NRE group that you contract with (the “Real Estate Company”) which is data controller in respect of your personal data, including in connection with subsequent correspondence, property management, remedy of defects, etc.
In business relationships
In business relationships, the data controlling entity will depend on your role in the business activity:
If you are a business customer (or an employee of a business customer) who engages NRE as a turnkey contractor, then NRE is the data controller.
If you are a supplier, sub-supplier, consultant, advisor etc. (or an employee of such party), then the real estate company that you contract with is the data controller.
Below are further details on how you contact the data controller in relation to the processing activities relevant for you.
Which data do we process and in what way?
Below, you will find an overview of how and when we collect and use your personal data. The overview is divided into three overall processing categories:
- NRE as the data controller: Correspondence and inquiries (private buyers or tenants)
The Real Estate Company as the data controller: Purchase or renting of NRE’s properties (private buyers or tenants)
- Business relationships (employees of business customers, suppliers, sub-suppliers, consultants and advisors etc. as well as self-employed persons)
NRE as the data controller: Correspondence and inquiries (private buyers or tenants)
When and purpose
NRE collects, records and processes personal data about you as former, existing or potential private customer for the purpose of:
- completing a sale or tenancy regarding NRE's properties, including for the purpose of entering into and performing a purchase or tenancy agreement with the Real Estate Company,
marketing of NRE, the Real Esate Company and our other real estate companies.
Types of personal data
NRE processes non-sensitive personal data such as contact details, housing preferences, etc.
The personal data will normally be provided by you, e.g. by telephone or electronically by email in connection with the correspondence between you and NRE.
Legal basis
The legal basis of the processing of your personal data is NRE's legitimate interests in pursuing the sale or tenancy of NRE's properties as well as general marketing of NRE, the Real Estate Company and other of our real estate companies (Article 6(1) f) of the General Data Protection Regulation).
Storage period
Personal data contained in correspondence and inquiries will be stored for up to 3 years after the last date of contact, unless a longer storage period is necessary, e.g. if any construction warranties are still in force, or due to any ongoing or potential complaints proceedings, disputes, or claims for defects pending between you and one or more of our real estate companies.
Recipients
NRE will not disclose your personal data to any third parties, unless it is necessary for entering into a contract requested by you, e.g. if you are interested in buying or renting one of the properties of NRE’s real estate companies. In that case, we will transmit your personal data to the real estate company(-ies) that own(s) the relevant property(-ies).
NRE has also engaged data processors to perform work on NRE’s behalf. These data processors get access to your personal data according to NRE’s specific instructions.
Among the data processors who may get access to your personal data are our IT suppliers.
The Real Estate Company as the data controller: Purchase or renting of NRE's properties (private buyers or tenants)
When and purpose
The Real Estate Company collects, records and processes personal data about you as buyer or tenant of the Real Estate Company's properties for the purpose of:
completing a sale or tenancy, including for the purpose of entering into performing a purchase or tenancy agreement
managing properties
responding to complaints and claims for defects and remedying defects
handling payment and bookkeeping tasks
applying for registration of documents with relevant authorities, including the Registration Court
submitting docimentation under the Danish Money Laundring Act
Types of personal data
The Real Estate Company processes non-sensitive personal data such as your contact and bank details.
The personal data will normally be provided by you, e.g. in the purchase or tenancy agreement, or collected when you are in contact with the Real Estate Company (by telephone or email).
In some cases, the Real Estate Company will also process your social security number if necessary e.g. for registration of documents of title and similar documents, and copies of your photo ID if required under the Danish Money Laundering Act.
Legal basis
The legal basis of the processing of your personal data is as follows:
Performance of a contract such as a purchase or tenancy agreement with you (Article 6(1) b) of the General Data Protection Regulation).
- The Real Estate Company’s legitimate interests in completing a sale or tenancy of a property as well as general property management, including replying to complaints and remedying of defects (Article 6(1) f) of the General Data Protection Regulation).
Compliance with legal obligations requiring the Real Estate Company to keep accounting records under the Danish Bookkeeping Act, to comply with the Danish Money Laundering Act (both Article 6(1) c) of the General Data Protection Regulation) and to register the documents necessary to enter into the contract of sale (section 11(2)(i) of the Danish Data Protection Act, see section 8(1) of the Danish Registration of Property Act).
Storage period
Personal data provided in connection with the purchase or tenancy of properties will be stored for 5 years after the date of completion of the purchase or the date of termination of the tenancy, unless a longer storage period is necessary, e.g. if any construction warranties are still in force, or due to any ongoing or potential complaints proceedings, disputes, claims for defects, etc.
Personal data which must be stored under the Danish Bookkeeping Act or other accounting rules will be deleted 5 years after the end of the relevant financial year.
Personal data received for property management purposes, including remedy of defects, will be stored for up to 3 years after the case has been closed, unless a longer storage period is necessary, e.g. due to ongoing or potential disputes, etc.
Copies of photo ID etc. will generally be stored for 5 years if required by the Danish Money Laundering Act.
Personal data contained in backup copies will be deleted by routine overwriting and cannot be accessed in the usual manner.
Recipients
The Real Estate Company will not disclose your personal data to any third parties, unless it is necessary for the performance of a purchase or tenancy agreement or for general property management purposes.
Your personal data may be shared with our external suppliers and cooperative partners for the above purposes, including in relation to the remedy of defects in tenancies or properties.
Your personal data may also be shared with NRE, since the Real Estate Company cooperates with NRE in connection with the purchase and sale of our properties.
The Real Estate Company has also engaged a number of data processors to perform work on its behalf. These data processors get access to your personal data according to the Real Estate Company’s specific instructions.
Among the data processors who may get access to your personal data are our IT suppliers.
Business relationships (employees of business customers, suppliers, sub-suppliers and advisors etc. as self-employed persons)
Below, the data controller is referred to as “we” or “us” as the question of who is data controller will depend on your role in the business activity. Read more above.
When and purpose
We collect, record and process personal data about you as a business contact or as self-employed person.
This is necessary in order to designate a contact person with our business relationships for the purpose of
establishing and maintaining a customer or supplier relationship, and
- entering into and performing a contract, including handling of payment and bookkeeping tasks, complaints and claims for defects, customer service, contract management, etc.
Types of personal data
We process non-sensitive personal data about you as a business contact such as your name, employer (business name), title, email address, telephone number (landline or mobile). In some cases, we receive a copy of your signature if a written contract is entered into between us and the business in which you are employed.
If you are a self-employed person, we may also process non-sensitive personal data such as the business name/company registration number, invoice information, finances, business activities, etc.
The personal data will normally be provided by you, e.g. during telephone conversations with us or by email.
Legal basis
The legal basis of the processing of your personal data is as follows
Our legitimate interests in establishing and maintaining customer or supplier relations with the business in which you are employed, including performance of contracts, handling of payment and bookkeeping tasks, complaints and claims for defects, customer service, etc. in the ordinary course of our business, where such legitimate interests are not overridden by your rights and interests (Article 6(1) f) of the General Data Protection Regulation).
Our legal obligations to keep accounting records under the Danish Bookkeeping Act (Article 6(1), c) of the General Data Protection Regulation).
Performance of a contract, e.g. contracts with self-employed persons (Article 6(1) b) of the General Data Protection Regulation).
Storage period
Your personal data will be stored as long as they are relevant for a former, existing or potential business relationship with the business in which you are an employee or owner.
Personal data which are relevant for contractual matters between us and the business in which you are employed will be stored as long as the business relationship exists and for a subsequent period of up to 3 years - and up to 5 years in case of construction matters. However, a longer storage period may be required, e.g. in case of any ongoing or potential disputes, complaints proceedings, claims for defects, warranties, etc.
Personal data which must be stored under the Danish Bookkeeping Act or other accounting rules will be deleted 5 years after the end of the relevant financial year.
Personal data contained in backup copies will be deleted by routine overwriting and cannot be accessed in the usual manner.
Recipients
We will not disclose your personal data to others, unless it is necessary in order to carry on our business activities, including logistic planning or coordination and performance of contracts.
Your personal data may be shared with our external suppliers, subcontractors, business customers etc. if necessary for the above purposes, e.g. through our project management platform.
We have also engaged a number of data processors to perform work on our behalf. These data processors get access to your personal data according to our specific instructions. Among the data processors who may get access to your personal data are our IT suppliers.
Contact deails
If you have any questions in relation to the processing of your personal data, if you want to exercise your rights as described below, or if you want to complain or object to our processing - whether the data controller is NRE, the Real Estate Company or any of our affiliated real estate companies - then please do not hesitate to contact us by sending an email to mail@nre.dk or by calling us at tel.: +45 87 12 49 50. Further contact details in relation to the Real Estate or other companies in the NRE group will always be available from NRE.
Updating of your personal data
We always seek to ensure that your personal data are accurate and updated. In case of changes to your personal data, we kindly ask you to let us know by using the above contact details. If you inform us of any inaccuracies in your personal data, or if we notice such inaccuracies, we will have them rectified or deleted as soon as possible.
Your rights under the data protection legislation
As a data subject you have a number of rights which you may exercise by contacting us, using the above contact details.
You have the right to request information about which personal data we process and to receive a copy of the data. You also have the right to object to our processing of your personal data and to request rectification or erasure of any data which you believe are incorrect, outdated, etc. Further, you may request a restriction of the processing of your personal data. For some of these rights, e.g. the right to erasure, exercising them requires satisfaction of certain concrete conditions set by data protection legislation.
Complaints
If you disagree with the way in which we process your personal data, you may file a complaint, using the above contact details. If you disagree with a decision made in any complaint proceedings (or do not wish to complain directly to us), you may also file a complaint with the Danish Data Protection Agency, which is the competent supervisor authority in Denmark. Contact details of the Agency are available at https://www.datatilsynet.dk/borger/klage-til-datatilsynet/.
Data: 22.10.2018