WINTHER WINTHER A/S

1. Introduction

1.1 At Winther Winther A/S, we take the protection of your personal data seriously. We fully respect all requests for confidentiality of personal data. Furthermore, we are aware of the need for appropriate protection and proper processing of your personal data. Winther Winther registers and processes personal data in accordance with the relevant regulations in force at all times.

1.2 On this basis, we have drawn up this policy, which tells you something about how we handle your personal data.

1.3 Personal data means any type of information about an identified or identifiable natural person.

1.4 When you order a Christmas present from Winther Gifts, or when you otherwise communicate with us, we receive and collect a number of personal data about you. This makes us so-called data controllers. Formally speaking, the data controller is:

Winther Winther A/S
Parken, Øster Allé 48, 6. sal
2100 København Ø
CVR.nr. 13227047

1.5 You can always contact us regarding this policy and our collection and processing of personal data by writing to
gifts@winthergifts.com

2. Purpose of collecting and processing personal data and the type of personal data

2.1. When you order your Christmas present, we register the following information:

• Name
• Address
• Phone number
• Mail
This personal data is necessary to be able to deliver your Christmas gift to a parcel shop near you.

3. Processing of personal data

3.1 We will at all times ensure that your personal data is treated with respect and confidentiality and in accordance with the rules applicable at any time, and we do not collect or process information that is not relevant for the purpose.

3.1.1 We have implemented technical and organizational measures that protect your personal data against unauthorized or illegal processing, accidental loss, destruction or damage.

4. Legal basis

4.1 We are obliged at all times to ensure that we have a legal basis for processing your personal data.

4.2 Our processing of your personal data is based on a consent from you. You will be able to withdraw your consent at any time, without however affecting the legality of the processing of your personal data that took place prior to the withdrawal of consent.

5. Dissemination and transfer of personal data

5.1 Your personal data may be passed on to public authorities, to the extent that we are obliged to do so according to Danish law.

5.2 Your personal data may be left to our business partners, who in that case process your personal data on our behalf and according to our specific and purpose-limited instructions (a so-called data processor).

5.3 we do not transfer personal data for processing outside the EU/EEA or to an international organisation.

5.4 In addition, we do not sell, pass on or otherwise transfer your data to other third parties.

6. Deletion of your personal data

6.1 Your personal data is deleted when the purpose of storage has been exhausted, which means when the Christmas gifts have been invoiced to your employer

7. Your rights

7.1 The applicable personal data protection rules give you (under certain conditions) a number of rights in relation to your personal data. It is:

• the right to be informed of which personal data we have registered about you (the right to access)
• the right to have incorrect, incomplete or irrelevant personal data rectified (the right to rectification)
• the right to have the scope of processing of your personal data limited (the right to limitation)
• the right to object to specific processing of your personal data (the right to object)
• the right to have your personal data transferred to a third party (the right to data portability)
• the right to have all your personal data deleted (the right to be deleted)

7.2 Any question and any other request, request or inquiry regarding exercising your rights must be done in writing to gifts@winthergifts.com

8. Complaint to the Data Protection Authority

8.1 You have the opportunity to complain to the Norwegian Data Protection Authority about our processing of your personal data.

8.2 Complaints can be sent to:

Datatilsynet
Borgergade 28
1300 København K

8.3 You will find further information, including contact details, on the Danish Data Protection Authority's website https://www.datatilsynet.dk/

9. Revision of this policy

9.1 We reserve the right to continuously change and adapt this policy.

9.2 This may be for the purpose of ongoing adaptation to current regulations.

9.3 It may also be in connection with ongoing adaptation to our way of processing personal data, for example when implementing new IT solutions for better security and processing of information.