1.1 This personal data policy applies only to personal data that is collected from this Home Page, www.lubral.dk.
1.3 Personal data is everything that can be attributed directly or indirectly to a person - even if it is only possible to specifically know who the information relates to.
1.4 LUBRAL is the data controller for your personal data. All inquiries to LUBRAL can be made using the contact details listed under section 7.
2.1 LUBRAL collects personal information about you when you contact us. Personal information covers data like your:
This information is stored in our book keeping.
There are three ways to collect information. One is when you approach the company regarding a purchase or an information about a product. Such inquiries may be by telephone, using email, or when using the Home Page if you thereby need to provide personal information. Another way is through visits to the Home Page if you specifically create a personal profile, for example when purchasing a product or by signing up for a newsletter. The third way is that when visiting the Home Page we automatically collect information about you, see section 2.2.
2.2 While visiting LUBRAL's Home Page we automatically collect information about you, ie. about your use of it. This includes data like your IP address and hence your network location, and what type of computer you use (iPad, mobile or desktop), and what type of browser you use and which pages you seem to prefer, also how long time you may spend on each page. LUBRAL uses Google Analytics and thus has access to the tools offered there.
2.3 If you sign up for our newsletter, we keep your name and your email address.
3.1 All shipping information such as name, address, e-mail, telephone number and order number and specific delivery requests are passed on to a carrier or a freight carrier to handle and deliver goods to you. A freight carrier is a data controller. When purchasing non-stocked goods, the said personal data are not passed on to the manufacturer or producer, or any other company or person who could otherwise have been responsible for the delivery.
3.2 Information may be left to external partners who process the information on behalf of LUBRAL. We use external partners (data processors) for, among other things, technical operation and improvements to the Home Page. These companies, LUBRAL's external partners, are data processors and under our instructions and process data that LUBRAL is responsible for. Data processors may not use the information, such as name and e-mail etc. for purposes other than fulfillment of the agreement with us, and is subject to confidentiality. We have signed data processing agreements with all data processors who process personal data on our behalf. Broadcast of newsletters takes place as an integrated use of the Home Page. We do not currently use retargeting, nor do we use companies such as TrustPilot for assessments based on personal experiences, but we make statistics (cf. section 2.2) on the Home Page itself.
3.3 Our data processor, Google Analytics /by Google LLC is established in the United States. The necessary information for the transfer of information to the United States is ensured through the data processor's certification under the EU-U.S. PRIVACY SHIELD FRAMEWORK, cf. the nature of the EU GDPR Article 45.
In order to establish openness about the processing of your information we as the data controller must inform you of your rights.
4.1 The right of access
4.2 The right to correct data
4.3 The right of deletion
4.4 The right to object
4.5 The right to restrict treatment for storage
4.6 The right to data portability
4.8 The right to revoke consent
4.9 The right to appeal
5.2 Information collected during your use of the Home Page, cf. section 2, is handled according to the following rules:
6.1 Implementation of safeguards
We have implemented appropriate technical and organizational safeguards against the personal or accidental destruction, loss, alteration or degradation of personal data as well as against the knowledge or misuse of any unauthorized person.
6.2 Access limitations
Only employees who have a real need to access your personal data to do their work have access to them.
LUBRAL Specialsmøremidler is the data controller for the personal data collected from the Home Page.
If you have any questions or comments regarding this Data Policy or would like to exercise one or more of your rights described in section 4, please contact:
LUBRAL Special lubricants
c/o K. Torpenhow
Tel. 39 62 19 40
If we make any changes to the Data Policy, you may get informed by looking at the version number and the date at the end of this Data Policy.
If you have signed up for our customer club or a newsletter, you will also be informed that way.
Version 1, LUBRAL Specialsmøremidler's Data Policy (GDPR): May 24, 2018.
Version 2, LUBRAL Specialsmøremidler's Data Policy (GDPR): April 2, 2019. Source: FDIH
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