PRIVACY POLICY

Introduction

iNudgeyou wants all of its online visitors to be confident that we process information about you in accordance with applicable privacy legislation. Our Privacy Policy describes how iNudgeyou handles and protects your personal data in our capacity as a data controller. It also describes your rights and how to proceed in case you wish to exercise them. Customers who subscribe to iNudgeyou services, such as participants to our courses, are contractually obligated to comply with the agreement, terms and conditions.

iNudgeyou is committed to respecting your privacy and protecting your personal data – any information that may identify you as an individual person (such as name, address, pictures, IP-number) and which is collected via our digital channels, such as our website, social media platforms and/or other future digital contact interfaces which links to this Privacy Policy.

It is important to us at iNudgeyou that you feel safe in our processing of your personal data. iNudgeyou would never knowingly sell or release your personal data to another party in other ways than as follows from this Privacy Policy and you are always welcome to contact iNudgeyou if you have any questions.

You will find information about how to contact iNudgeyou below.

We welcome you to visit all digital channels managed by iNudgeyou and you do not need to provide any personal data to visit them. However, please be aware that if you do not provide some requested information, access to certain services or parts of our digital channels and certain social media channels may be restricted.

Sensitive Personal Data and Personal Identification Numbers

Sensitive personal data includes any information that reveals your race or ethnicity, political views, religious or philosophical beliefs, membership in a trade union, as well as personal data regarding your health or private life.

Sensitive personal data may be collected from you if you purchase our services or choose to attend our courses, programs and/or events (or other sessions or events organized by iNudgeyou or on our behalf). You may in such case choose to submit your sensitive personal data to iNudgeyou about, for example, your special learning needs or dietary requirements.

Personal identification numbers are only processed when needed to ensure your identification or if strictly needed. iNudgeyou limits the use of personal identification numbers.

iNudgeyou has additional measures in place to protect sensitive personal data, personal identification numbers, and confidentiality. iNudgeyou will use your sensitive personal data to deliver our services to you, meet your requirements, or deal with any requests made by you. Personal data and other sensitive information, such as credit card numbers and/or location data, collected on our website and/or transmitted to other websites is protected through the use of encryption such as the Secure Socket Layer (SSL) protocol.

iNudgeyou will only disclose your sensitive personal data to the third parties as referred to in this Privacy Policy or where iNudgeyou considers it absolutely necessary – such as to establish appropriate security or confidentiality obligations.

Sources of Information

Generally speaking, iNudgeyou only processes data you have provided or that iNudgeyou registers based on your purchases and the use of our services. In certain cases, iNudgeyou may supplement this data with information from third parties for the purpose of evaluating and improving our digital channels and services.

Information to Other Parties

DATA PROCESSORS

Other than as provided in this Privacy Policy, iNudgeyou will not knowingly share personal data you provide to any third party. In cases where it is necessary for iNudgeyou to carry out our services, we may retain external suppliers (processors) for services in connection with our digital channels or the services. These suppliers may process personal data and sometimes iNudgeyou uses the following types of suppliers:

• Payment solutions (banks, other payment service providers);
• Marketing (social media, media agencies, advertising services, CRM providers);
• IT (companies that handle necessary operations, technical support and maintenance of our IT solutions such as Google);
• Events, statistics and surveys (companies that handle evaluations, statistics and surveys of our services).

iNudgeyou endeavours to limit third-party access and only share information that is necessary to enable suppliers to carry out their work. iNudgeyou always checks that our suppliers can meet our high standards and provide sufficient safeguards and require them to protect your personal data in accordance with this Privacy Policy and refrain from using or disclosing your personal data for any purpose other than providing iNudgeyou with the agreed product or services.

OTHER DATA CONTROLLERS

iNudgeyou may also share your personal data with companies that are independent data controllers. This may include:

• Government agencies (e.g. the Danish tax authorities) if iNudgeyou is required to do so by law;
• Companies offering payment solutions (banks and other payment service providers).

When personal data is shared with an independent data controller, this Privacy Policy is no longer applicable.

Transfers to Third Countries

iNudgeyou strives at all times to keep personal data within the European Economic Area (EEA) but engages suppliers located outside of the EEA such as Google.

During support and maintenance, iNudgeyou may have to transfer the information outside of EEA, also when iNudgeyou shares data with our group companies in order to carry out our services.

Any such data will always be kept to a minimum relevant for the purpose. No matter where your personal data is transferred iNudgeyou always take appropriate technical and organizational measures to ensure that the security level is the same as in the EEA and at an adequate security level, for example by using the EU Commission’s Standard Clauses or ensure that the supplier is Privacy-Shield registered.

Amendments to the Privacy Policy

iNudgeyou reserves the right to change this Privacy Policy. Changes to the terms of the policy will be notified on inudgeyou.com, one month before the change of terms enters into force.

You should not supply iNudgeyou with any personal data if you do not accept changes which are made to this Privacy Policy.

Deletion of Data

Personal data will not be stored for longer than is necessary in light of the purposes of the processing and, in general, iNudgeyou will delete personal data in the manner which follows from applicable legislation. Where information is known to be unreliable, irrelevant or excessive, it will be securely deleted or access will be removed, as soon as is reasonably possible.

Your Rights

You are entitled once each year and free of charge to request information regarding the personal data, if any, about you which iNudgeyou processes and to have any erroneous information corrected. Please note that iNudgeyou may request additional details about you in order to ensure secure and effective handling of your request and to ensure that the information is provided to the correct person.

Should you have reason to believe that any personal data that iNudgeyou holds about you is inaccurate, please let us know and we will update the information.

You may request us to delete personal data we hold about you. For example, if the information is no longer necessary to fulfil the purpose they were collected for, they are processed in an illegal way, or you opt out from direct marketing. Please note that, when legally required, iNudgeyou could decline your request, for example, if the data is needed for tax or bookkeeping purposes, or are necessary to defend legal claims.

You also have the right to request limitations of the processing of your personal data. In such cases, iNudgeyou may need to investigate the situation further prior to reaching a decision. Please be aware that you always have a right to opt out of direct marketing activities and request limitation of processing based on legitimate interest – including potential profiling for direct marketing purposes.

When you provide iNudgeyou either with your consent or the processing is based on fulfilment of an agreement with you, you have, under certain circumstances a right to have your data transferred to another data controller. This requires that the transfer is technically possible and may be carried out automatically.

If you would like to know how iNudgeyou processes personal data, send a written and signed request to iNudgeyou. You will find our contact information below.

Links

Our digital channels may include links to websites which are provided by other group companies or companies which do not belong to iNudgeyou. This Privacy Policy shall not apply to such websites. You should, therefore, review the privacy policy of any such website before you provide personal data.

Security

iNudgeyou takes all appropriate technical and organizational security measures which are necessary to the safeguard personal data against unauthorized access, modification, or destruction. However, providing personal data over digital channels always entails a risk since it is not possible to completely protect technical systems from unauthorized access.

Information About Children

The iNudgeyou website is not intended for or targeted at, children under the age of 13 years old and iNudgeyou never knowingly or intentionally collect information about children under this age. If you believe that iNudgeyou has collected information about a child, please contact us at info@inudgeyou.com to request deletion of the information.

Social Media and External Websites

The iNudgeyou website includes social media features, such as a Facebook ‘Like’ button and also widgets, such as the ‘Share this’ button, or interactive mini-programs that run on our website. These features may collect your IP address, which pages you visit on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by third parties or directly on our website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by their privacy policies and other routines of the companies providing them.

Our website may provide hyperlinks to other websites. iNudgeyou does not control and is not responsible for, the content or practices of other websites.

Cookies & Technologies

Cookies are a small text file consisting of letters and numbers sent from our web server and stored on your browser or device.

They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The cookies iNudgeyou uses usually improve the services iNudgeyou offers you. Some of the iNudgeyou services need cookies to work properly, while others improve the services for you. iNudgeyou uses cookies for overall analytical information regarding your use of iNudgeyou services. iNudgeyou uses cookies to save functional settings such as language and other tasks. iNudgeyou also uses cookies that allow iNudgeyou to target relevant marketing to you. Cookies allow iNudgeyou to understand who has seen which pages, and to determine the most popular areas of our website.

iNudgeyou uses cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

iNudgeyou uses different cookies: Session cookies are a temporary cookie that ends when you close your browser or device. Permanent cookies are cookies that remain on your computer until you delete them or expire. Prebook cookies are set by the site you visit. Third-party cookies are cookies set by a third-party site. At iNudgeyou, these are primarily used for analysis (such as Google Analytics). Similar techniques are techniques that store information in your browser or device in a manner similar to cookies.

Use of Google Analytics

As part of iNudgeyou’s marketing, iNudgeyou analyzes information about the use of inudgeyou.com and activity on iNudgeyou’s pages on social media. For example, using Google Analytics, we will analyze behaviour for creating more relevant ads and offers, as well as for developing iNudgeyou’s products and services. In addition, Google Analytics helps to evaluate the use of inudgeyou.com for services related to website activities and internet usage.

How to Control Cookies

You have the ability 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. If you choose to decline cookies, you may not be able to fully experience the interactive features of the iNudgeyou subscription service or websites you visit.

Your browser or device enables you to change the settings for usage and extent of cookies. Go to the settings of your browser or device to learn more how to adjust cookies settings. For example, you may block all cookies, only accept first-party cookies or delete cookies when you close your browser. Please note that some of our services may not be working if blocking or reading cookies.

Clear Gifs (Web Beacons / Web Bugs)

iNudgeyou uses software called clear gifs (also known as web beacons or web bugs), that helps us better manage the website and subscription service by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, used to track the online movements of online users. Unlike cookies which are stored on users’ computer hard drives, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. iNudgeyou uses clear gifs in our emails to let iNudgeyou know which emails have been opened by recipients. This allows iNudgeyou to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. iNudgeyou ties the information gathered by clear gifs in emails to our customers’ personal data.

Advertising

iNudgeyou partners with third-party advertising networks to either display advertising on our website or to manage our advertising on other websites. Our advertising network partner uses cookies and clear gifs to collect non-personal information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/or, if located in the European Union, by clicking here: http://www.youronlinechoices.eu/. Please note this act does not opt you out of being served advertising. You will continue to receive generic ads.

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy. iNudgeyou does not have access to or control over these third-party tracking technologies.

Contact Information

If you have any questions regarding our Privacy Policy or any other question regarding our processing, please contact us:

iNudgeyou – Den Danske Nudge Enhed
Kompagnistræde 7A, st. tv.
1208 København K
info@inudgeyou.com

In case your personal data is not being processed in accordance with this Privacy Policy or with the General Data Protection Regulation (EU) 2016/679, you have the right to file a complaint with Datatilsynet in Denmark or any other European Supervisory Authority.

PRIVACY NOTICE

Data Controller

iNudgeyou acts as a data controller in cases where iNudgeyou alone or jointly with others determines the purposes and means of the processing of your personal data.

If you have any questions about how we process your personal data, please contact iNudgeyou at info@inudgeyou.com.

Purpose of the Processing

We use the personal data we collect to send you newsletters, invitations to our courses, events and lectures, and to maintain our list of contacts.

We do not sell, share, distribute or otherwise make your personal data available to any third party.

Data Categories

iNudgeyou collects certain personal data about you but only at a minimum level to be able to fulfil the purpose of the processing. “Personal data” can be used to identify you or that we may directly or indirectly connect to you. We collect personal data that you have voluntarily provided to us, for example when you sign up for one of our courses, events, newsletters or other materials or when you communicate with us via email or other channels. The data we collect includes your name, e-mail address, job title, company information, address and/or language preferences.

In some cases, your personal data may have been supplemented by information retrieved from other sources, including searches via publicly available search engines, sector-specific newsletters, social media, and/or your employer’s website.

We do not process your data by automated decision making or profiling.

Legal Grounds

When processing personal data for the purposes explained in this email, we rely on our legitimate interests in maintaining a legitimate business relationship and communicating with you as a business contact about our operations and our events. We consider that our interests abide by the law and the legal rights and freedoms of our business contacts.

Transfer of Data

Only the people who need to process personal data for the purposes mentioned above have access to your personal data. iNudgeyou will only transfer your personal data if needed to fulfil a contract with you, if required by law or if needed to fulfil a legal obligation.

We may need to allow our suppliers and sub-suppliers to access your personal data when they perform services on our behalf to maintain and support our IT systems.

Any transfer of data outside the EU/EEA is made in line with applicable data protection laws. Unless there is another legitimate basis, our international transfers of personal data are based on the EU Commission’s standard contractual clauses.

Retention

Your personal data will be stored in our registers for the specified purposes mentioned above for as long as you are considered a business contact. The data will be deleted when no longer needed to fulfil its purpose.

We will provide you with opportunities to unsubscribe from our newsletters. If you choose to unsubscribe, we will cease data processing for the purposes mentioned above and remove your personal data from our contact systems.

Security

iNudgeyou uses technical and organizational security measures to help protect your personal data against loss and to guard it against access by unauthorized persons. This includes, for example, limited access rights. We regularly review our IT and privacy security policies to ensure our systems are secure and protected.

Your Rights

You have the right to know what personal data we process about you and may request a copy free of charge. You are also entitled to have incorrect data about you corrected and you may in some cases ask us to delete your personal data, for example, if iNudgeyou would process your personal data without legal ground. You may also object to certain personal data about you being processed and request that processing of your personal data is limited. Please note that limitation and/or deletion of personal data may result in that you do not receive our newsletters. You also have the right to receive your personal data in a machine-readable format and have the data transferred to another party responsible for data processing.

Complaints

In case of any questions or comments, please contact us at info@inudgeyou.com. You have the right to make a complaint at any time to your local supervisory authority for data protection issues. In Denmark, you can direct such complaint to Datatilsynet.