External Privacy and Cookie Policy

 

Introduction

 

At Alumeco (which includes Alumeco A/S, Aluwind A/S, Alumeco Sverige AB, Alumeco Norge AS, Metallcenter West GmbH, Alumeco Service GmbH, Alcobra GmbH, Metalcenter Group GmbH, Alumeco Austria GmbH, Alumeco Finland OY AB, Metalcenter Finland OY AB, UAB Alumeco Baltic, Aluteam-Alumeco Sp. z o.o., Alumeco Service Sp. z o.o., Aluwind Sp. z o.o., Alumeco CZ s.r.o., and Alumeco NL) ("Alumeco") we understand the importance of treating the personal data of our customers, business partners, visitors to our website and other persons we interact with in a confidential and private manner.

 

Alumeco A/S, Næsbyvej 26, 5000 Odense C, Denmark, business registration number: DK19851974 is a company  registered and incorporated under the laws of Denmark. In addition, the mentioned group companies belonging to Alumeco A/S are made up of numerous legal entities with offices located across the globe.

 

Due to the Alumeco Group structure – including in particular the extent of shared services and the consequent joint data responsibility, this external privacy and cookie policy ("Privacy Policy") applies across the group. Each entity of Alumeco to which this Privacy Policy is relevant is, along with Alumeco A/S, the data controller for the processing of personal data in the respective entity.

 

Alumeco is committed to following the requirements and obligations in relation to data privacy in accordance with applicable law, including the EU General Data Protection Regulation ("GDPR"). Therefore, we have secure and adequate data processing procedures in place.

 

In Alumeco’s interaction with customers, suppliers, website visitors and others, Alumeco is granted access to personal data concerning natural persons ("Data Subjects"). The subject for this Privacy Policy is this processing of data. Below, Alumeco has provided an overview of the processing activities in which personal data are processed, including among others the purpose thereof and the legal bases. If at any time you wish to contact us, if you have any question to this Privacy Policy or if you wish to exercise your data subject rights, you may reach out to our GDPR team at GDPR@alumeco.dk.

 

Customers, suppliers, trading partners, or other business partners

 

Categories of Data Subjects:

Alumeco processes data about contact persons employed with or otherwise representing former, current and potential customers, suppliers, trading partners and other business partners. As a contact person at a customer, supplier, trading partner, or another business partner, Alumeco processes your personal data as a Data Subject when you communicate with Alumeco, e.g., via emails in connection with Alumeco's existing contractual relation with the company you are employed with or in connection with the conclusion or termination of a contract.

 

Purposes:

The purpose with the processing of personal data is to be able to offer a professional service towards our customers, suppliers, trading partners, etc. The registered personal data is therefore used for providing services to marketing, sales, purchase, manufacturing, delivery, market research, product development, business development and statistics.

 

Types of data:

Alumeco processes ordinary data including contact information in the form of names of the Data Subjects, e-mail addresses, telephone numbers, job positions, place of work, etc.

 

Legal basis:

The legal basis for such processing of your personal data is that the processing is necessary for the purposes of legitimate interests pursued by Alumeco and it is Alumeco's assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. Art. 6(1)(f) of the GDPR. Alumeco's legitimate interests are to be able to offer a professional service towards our customers, suppliers and trading partners and fulfilment of our contractual obligations, maintaining and enhancing customer relationships and other partnerships, invoicing for the services your company provides to Alumeco and/or vice versa, communicating with you if you have any questions related to our services or vice versa, and for documentation purposes.

 

It is estimated that Alumeco’s interest in being able to process personal data for the listed purposes including our legitimate interest in providing you with our goods and services and securing prompt payment of any fees, costs and debts in respect of our services, surpasses the Data Subject’s interest in the personal data not being processed by Alumeco. In particular, the personal data is a very limited dataset and primarily related to business related contact details.

 

In rare cases, the legal basis for the processing of your personal data is Art. 6(1)(b) of the GDPR. This is either because the processing is necessary for the performance of a contract to which you are a direct party or because it is necessary in order to take steps at the request of you prior to entering into a contract.

 

In some cases, processing of personal data is necessary in order to comply with a legal obligation to which Alumeco is subject, for instance in relation to the obligation on the preservation of accounting records pursuant to the Danish Bookkeeping Act. In such case, the legal basis for the processing is Art. 6(1)(c) of the GDPR.

 

Storage period:

If you are a contact person at a customer supplier, trading partner, or another business partner, Alumeco will store personal data about you as long as Alumeco communicates with you because you are Alumeco's point of contact. As a main rule, Alumeco deletes personal data either 3 years after termination of the contractual relationship with the company you are representing, or 3 years after the last interaction with you or the company you are representing, unless a further retention is deemed necessary for the establishment, exercise, or defense of a legal claim. Hereafter, your personal data will be deleted.

 

Alumeco will store your personal data to the extent it is necessary for bookkeeping purposes such as personal data related to invoicing. This period may vary depending on local legislation in the countries where Alumeco operates. In Denmark, such personal data will be stored for a period of 5 years from the end of the financial year to which the accounting records relate, cf. the Danish Bookkeeping Act.

 

Categories of recipients:

  • Business partners of Alumeco on an as-needed basis.
  • Alumeco group companies on an as-needed basis.
  • Data processors that process personal data on behalf of Alumeco, according to data processing agreements and under obligation to sustain sufficient technical and organisational measures and Alumeco is obliged to control that the applied data processors are acting in accordance with Alumeco’s instructions.
  • In accordance with requests from public authorities and in case of court orders.
  • Advisors of Alumeco, e.g. if the disclosure of your personal data is necessary for the establishment, exercise or defense of Alumeco's legal claims.

 

In certain cases, your personal data may be transferred to countries outside of the EU/EEA. Alumeco ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the EU standard contractual clauses ("SCCs") with Alumeco. Alumeco will ensure the implementation of supplementary safeguards if deemed necessary in the specific case. You may receive a copy of the legal basis for transfers upon request. Please contact GDPR@alumeco.dk.

 

Website

 

Purpose:

The purpose with Alumeco's website www.alumeco.com ("Website") is to sell and market our aluminium, copper, brass, stainless steel etc. products and services towards professional metal customers. Our Website also contains information and technical data to help customers in connection with the use of aluminium and other metals in general.

 

The Website uses cookies. The purpose of using these cookies is, i.a., to improve your user experience on our Website, to provide functionality, to generate statistics, to target the marketing of our products to your needs, and to remember your preferences.

 

Types of data:

When you visit Alumeco's Website, Alumeco will process ordinary personal data about you as a Data Subject via Cookies, for instance, browser type and version, IP-address, and length of visit. We also aggregate anonymized statistical information about our website visitors' activities, for example which pages are visited and from which sources, how much time is spent on each website and which pages are most popular. If you give us your consent to marketing purposes, we use the information that you have visited our site to present you with advertisements about the Alumeco group products and services on social media platforms.

 

Especially about “cookies”:

 

A cookie is a text file that is sent to your browser from our Website and saved on your computer, phone or whichever device you use to access the internet. Cookies make it possible to recognize the applied unit and to gather information about the data subject’s behaviour on the Internet as well as to secure that the technology of the unit works. When a user visits our Website, a number of modules are installed with the purpose of collecting and organizing data. The meaning of the word “cookies” in this Privacy Policy and in the consent popup also includes other kinds of automated data collection, e.g. Flash-cookies (Local Shared Objects), Web Storage (HTML5), JavaScript’s or cookies placed by the use of other kinds of software. The word “cookies” also refers to information about MAC-addresses and other information about your device.

 

There are basically two types of cookies - so-called session cookies and persistent cookies. Session cookies are information units that are deleted when you close your web browser. Persistent cookies are information units that are stored on your computer until they are deleted. Persistent cookies delete themselves after a certain period but are renewed each time you visit the Website. Alumeco uses both session and persistent cookies. An overview of the specific cookies we use are available in the cookie declaration in the consent popup shown to you when you visit the Website.

 

Cookies may be used for a number of purposes, but in essence they are used to save information about your activity on the internet. Cookies contain information that later in time can be read by a web server on the domain that issued the cookie in question. This means that the relevant website remembers you the next time you visit it. We collect information via cookies in order to improve your user experience on our Website and products, to provide and improve usability and functionality, to generate statistics, analysis and website performance reviews, to remember your preferences, marketing purposes, tracking of your location and to customize our advertising on social media platforms. The benefit for you is that you will save time next time you visit the Website, as you do not have to enter the same information again and that the content will be adjusted to your preferences.

 

When you visit www.alumeco.com for the first time, you will be asked to give your explicit consent to the use of cookies on the Website or decline the use of all or some of the cookies. We encourage you to accept the cookies used by the Website, because it will help us improve you and other people's experience when visiting the Website. If you decline the use of cookies, there may be a variety of functionalities on the Website, which you cannot utilize. Please note that the use of functionality cookies does not require your consent, as such cookies are necessary for the function of the Website.

 

When you use our Website, we do not register any information that can identify you directly, such as name and address. However, we register how you navigate around the site, so we can learn more about how our site is used, and we register your IP-address, which can identify indirectly.

 

Removal of cookies:

You can always reject or deselect the location of cookies on your computer by changing the settings in your browser or by visiting the permanent representation of the cookie banner.

 

Please note that if you opt out, there are many features and services on our Website that you cannot use because they require the Website to remember the choices you make.

 

Cookies that you have previously accepted can easily be deleted subsequently. If you use a computer with a newer browser, you can delete your cookies using the shortcut keys: CTRL + SHIFT + Delete. If the shortcut keys do not work and/or if you use a MAC, you must start by finding out which browser you are using, and then click on the relevant link with guidelines on how to opt out of cookies:

 

 

Note that if you use multiple internet browsers, you must delete cookies in all your browsers.

 

Legal basis:

The legal basis for our processing of your personal data when visiting the Website is Alumeco's legitimate interests and it is Alumeco's assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. Art. 6(1)(f) of the GDPR. The legitimate interests pursued are to provide you with a website that works optimally, a good website experience and marketing activities.

 

In certain cases, the legal basis for the processing of your personal data in this regard is consent which you will be asked to give when you visit the Website, cf. Art. 6(1)(a) of the GDPR. We use a special popup for this purpose designed by Cookieinformation, which helps group cookies and similar technologies into categories such as necessary, functional, statistical, and marketing.

 

Storage period:

There are different expiry dates for each cookie depending on the type and purpose of the cookie in question and they are updated automatically when you visit the Website again. The cookies are all listed in the consent popup along with the description of the data recipient, etc.

 

Categories of recipients:

In order to further develop and improve the Website, we use cookies from certain third parties. The purposes are preparation of statistics and analyses of online behaviour. The third parties place the cookies on your computer on our behalf and prepare the statistics, etc. Third parties used are listed in the cookie declaration available in the consent popup shown to you when you visit the Website.

 

If you only give consent to “necessary” we only receive your opt-out and process this using Google Tag Manager to respect your decision.

 

If you give consent to one or multiple other categories, we transfer your personal data as described in the cookieinformation popup to the relevant recipients listed in the cookieinformation popup. Certain of these third-party recipients are data controllers using the personal data to pursue own purposes whilst certain others are data processors only processing the personal data on behalf of and as instructed by Alumeco.

 

In certain cases, your personal data may be transferred to countries outside of the EU/EEA. Alumeco ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the SCCs. Alumeco will ensure the implementation of supplementary safeguards if deemed necessary in the specific case. You may receive a copy of the legal basis for transfers upon request. Please contact GDPR@alumeco.dk.

 

Chat function

 

Purpose:

The purpose with the chat function is to provide users of the Website access to advice and guidance in a fast and flexible way. At the same time, Alumeco utilizes the opportunity to generate statistics.

 

Types of data:

If you submit an inquiry relating to Alumeco's services via Alumeco's chat function, Alumeco will process ordinary personal data about you as a Data Subject, e.g., your IP-address, geographic location, possible reactions to our ads, cf. the use of cookies above, and the personal data you may include in your inquiry, e.g., name, telephone number and e-mail address.

 

Alumeco will not process special categories of personal data (sensitive personal data) about you, e.g., health in-formation, unless you have provided us with such information, e.g., through the chat function. Alumeco kindly encourages you not to send such sensitive personal data.

 

Legal basis:

The legal basis for registering personal data through the Alumeco chat function is balance of interest, cf. Art. 6(1)(f) of the GDPR. The legitimate interests pursued are to provide support by answering the inquiries and business development. It is estimated that Alumeco’s interest in being able to process personal data for the listed purposes including our legitimate interest in the effective delivery of information and services to you, surpasses the Data Subject’s interest in the personal data not being processed by Alumeco. In particular is mentioned that the personal data is only stored to the extent that it is assessed necessary, and that the personal data is not of a private nature.

 

Storage period:

The inquiries from potential customers will be deleted 12 months from the inquiry is resolved, unless it is deemed necessary to store such inquiries for documentation purposes e.g., due to a dispute, including for the establishment, exercise or defence of legal claims.

 

The inquiries from existing customers will be deleted 3 years from the termination of the contractual relationship, unless it is deemed necessary to store such inquiries for documentation purposes e.g., due to a dispute, including for the establishment, exercise, or defence of a legal claim.

 

Alumeco will store your personal data to the extent it is necessary for bookkeeping purposes such as personal data related to invoicing. This period may vary depending on local legislation in the countries where Alumeco operates. In Denmark, such personal data will be stored for a period of 5 years from the end of the financial year to which the accounting records relate, cf. the Danish Bookkeeping Act.

 

Categories of recipients:

  • Business partners of Alumeco on an as-needed basis.
  • Alumeco group companies on an as-needed basis.
  • TICWARE (FocalScope) ApS is used as data processor and service provider and processes personal data on behalf of Alumeco according to a concluded data processing agreement obligating it to sustain sufficient technical and organisational measures, and Alumeco is obliged to control that TICWARE (FocalScope) ApS is acting in accordance with Alumeco’s instructions. It is estimated that TICWARE (FocalScope) ApS has an adequate security level and has made the sufficient technical and organisational precautionary measures against that information about the Data Subject by accident or illegally is forfeited or brought to the attention of unauthorized persons or abused by other means.
  • In accordance with requests from public authorities and in case of court orders.
  • Advisors of Alumeco, e.g. if the disclosure of your personal data is necessary for the establishment, exercise or defence of Alumeco's legal claims.

 

In certain cases, your personal data may be transferred to countries outside of the EU/EEA. Alumeco ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the SCCs. Alumeco will ensure the implementation of supplementary safeguards if deemed necessary in the specific case. You may receive a copy of the legal basis for transfers upon request. Please contact GDPR@alumeco.dk.

 

Webshop

 

Purpose:

The purpose with Alumeco’s webshop is to sell our products to our customers.

 

Types of data:

Alumeco registers ordinary personal data about the Data Subjects in the form of information about contact persons, such as name and e-mail address and details about your inquiry and/or order.

 

Legal basis:

The legal basis for such processing of your personal data is that the processing is necessary for the purposes of legitimate interests pursued by Alumeco and it is Alumeco's assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. Art. 6(1)(f) of the GDPR. Alumeco's legitimate interests are to be able to offer a professional service towards our customers, suppliers and trading partners and fulfilment of our contractual obligations, maintaining and enhancing customer relationships and other partnerships, invoicing for the services your company provides to Alumeco and/or vice versa, communicating with you if you have any questions related to our services or vice versa, and for documentation purposes.

 

It is estimated that Alumeco’s interest in being able to process personal data for the listed purposes including our legitimate interest in providing you with our goods and services and securing prompt payment of any fees, costs and debts in respect of our services, surpasses the Data Subject’s interest in the personal data not being processed by Alumeco. In particular, the personal data is a very limited dataset and primarily related to business related contact details.

 

In rare cases, the legal basis for the processing of your personal data is Art. 6(1)(b) of the GDPR. This is either because the processing is necessary for the performance of a contract to which you are a direct party or because it is necessary in order to take steps at the request of you prior to entering into a contract.

 

In some cases, processing of personal data is necessary in order to comply with a legal obligation to which Alumeco is subject, for instance in relation to the obligation on the preservation of accounting records pursuant to the Danish Bookkeeping Act. In such case, the legal basis for the processing is Art. 6(1)(c) of the GDPR.

 

Storage period:

The webshop is integrated with the ERP system of Alumeco.

 

If you are a contact person at a customer, supplier, trading partner, or another business partner, Alumeco will store personal data about you as long as Alumeco communicates with you because you are Alumeco's point of contact. As a main rule, Alumeco deletes personal data either 3 years after termination of the contractual relationship with the company you are representing, or 3 years after the last interaction with you or the company you are representing, unless a further retention is deemed necessary for the establishment, exercise, or defence of a legal claim. Hereafter, your personal data will be deleted.

 

Alumeco will store your personal data to the extent it is necessary for bookkeeping purposes such as personal data related to invoicing. This period may vary depending on local legislation in the countries where Alumeco operates. In Denmark, such personal data will be stored for a period of 5 years from the end of the financial year to which the accounting records relate, cf. the Danish Bookkeeping Act.

 

Categories of recipients:

  • Business partners of Alumeco on an as-needed basis.
  • Alumeco group companies on an as-needed basis.
  • Data processors that process personal data on behalf of Alumeco, according to data processing agreements and under obligation to sustain sufficient technical and organisational measures and Alumeco is obliged to control that the applied data processors are acting in accordance with Alumeco’s instructions.
  • In accordance with requests from public authorities and in case of court orders.
  • Advisors of Alumeco, e.g., if the disclosure of your personal data is necessary for the establishment, exercise or defence of Alumeco's legal claims.

 

In certain cases, your personal data may be transferred to countries outside of the EU/EEA. Alumeco ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the SCCs with Alumeco. Alumeco will ensure the implementation of supplementary safeguards if deemed necessary in the specific case. You may receive a copy of the legal basis for transfers upon request. Please contact GDPR@alumeco.dk  

 

Social media marketing

 

Purpose:

Our Website uses so-called social media plug-ins ("Plug-ins") from the social networking sites YouTube, LinkedIn, Facebook and Instagram.

 

The purpose with the social media platforms is generally to market Alumeco and our aluminium products as well as interact with customers and stakeholders.

 

Alumeco uses the following social media platforms:

  • YouTube: Alumeco has a channel with videos about Alumeco, aluminium products and cases. Alumeco has access to a statistics module where Alumeco can analyze the user data and behaviour.
  • LinkedIn: Alumeco has a corporate page where relevant information about Alumeco and the products as well as job ads are posted. Alumeco has access to a statistics module where Alumeco can analyze the user data and behaviour.
  • Facebook/Instagram: Alumeco has a Facebook and Instagram profile where relevant information about Alumeco and our products as well as job adverts are posted. Via Facebook Business Manager, Alumeco has access to a statistics module where Alumeco can analyze the user data and behaviour.

 

Our use of these Plugins on our Website provides us with information about the number of visitors on the website in response to social media advertisements.

 

If you access our Website using such a Plug-in, your browser will contact the server of the underlying social networking site, load the visual presentation of the Plug-in, and present it to you. While this is happening, the social networking site receives information concerning your visit to our Website, as well as further data such as your IP address. Alumeco receives anonymous demographic and geographic statistics from the social media on the visitors on our Website and our social media sites.

 

Alumeco is joint data controller with our social media providers for personal data collected and processed in connection with your visit to our social media sites and our Website. It means, among other things, that you may contact both Alumeco and the social media providers to exercise your rights under the GDPR. Facebook, Insta-gram and LinkedIn have primary responsibility for ensuring compliance with the GDPR and responding to requests from visitors on Facebook, Instagram, and LinkedIn. If you are registered as user of Facebook, Instagram and/or LinkedIn, you may exercise your rights via your account settings on Facebook, Instagram and/or LinkedIn.

 

We have no influence on the amount of data that social networking sites collect via an active Plug-in. For more information, please consult the relevant data privacy notice of the respective platform:

 

 

Types of data:

Alumeco processes personal data about you as a Data Subject including your name and contact information as well as the content of the message you may choose to share with us.

 

Legal basis:

The legal basis for the processing will be balance of interest, cf. Art. 6(1)(f) of the GDPR. It is estimated that Alumeco’s interest in being able to process personal data for the listed purposes including our legitimate interests in making content available on social media to users who follow Alumeco Group companies, in branding and marketing Alumeco Group surpasses the Data Subject’s interest in the personal data not being processed by Alumeco.

 

Personal data collected in relation to the use of social media will be erased when the content is deleted or when you withdraw your response to our content (likes, sharing, etc.).

 

Alumeco has no influence on the retention social media's retentions periods, please see the privacy policy for each platform.

 

Categories of recipients:

  • Alumeco group companies on an as-needed basis.
  • Data processors that process personal data on behalf of Alumeco, according to data processing agreements and under obligation to sustain sufficient technical and organisational measures and Alumeco is obliged to control that the applied data processors are acting in accordance with Alumeco’s instructions.
  • Recipients in unique cases according to consent from the data subject, for example passing of contact details between our customers or suppliers in order to facilitate dialogue.
  • In accordance with requests from public authorities and in case of court orders.
  • When you visit our social media sites on e.g. Facebook, Instagram and LinkedIn or our Website where social media Plugins have been installed, our social media service providers collect and process your personal data using cookies, subject to your consent to the service provider, as applicable. Such collection and processing take place even if you have no account on the social media.

 

In certain cases, your personal data may be transferred to countries outside of the EU/EEA. Alumeco ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the SCCs with Alumeco. Alumeco will ensure the implementation of supplementary safeguards if deemed necessary in the specific case. You may receive a copy of the legal basis for transfers upon request. Please contact GDPR@alumeco.dk.

 

Rights of the data subject

 

Alumeco has implemented a number of measures to protect your personal data and ensure your rights. As a Data Subject you have certain rights which Alumeco is obliged to fulfill unless otherwise exceptionally provided by the data protection legislation. These rights include the right to be informed, the right of access, the right to rectification, the right to erasure ("the right to be forgotten"), the right to restriction of processing, the right to data portability, the right to object, the right not to be subject to a decision based solely on automated processing, including profiling. Please note that certain limitations may apply to your ability to exercise these rights, for example, when your right to obtain the information is found to be overwritten by essential considerations of private interests.

 

The Danish Data Protection Agency has prepared guidelines regarding the Data Subjects’ rights. The guidelines can be accessed here. However, please note that the guidelines are only available in Danish.

 

If Alumeco is processing personal data based on your consent, you also have the right to withdraw this consent at any time. Please note that your withdrawal does not affect the lawfulness of the previous processing of your personal da-ta which until your withdrawal has been based on your consent.

 

To exercise any of your rights, you can contact Alumeco GDPR team by e-mail at GDPR@alumeco.dk.

 

If you disagree with the way in which Alumeco processes your personal data, you may file a complaint with the relevant data protection supervisory in your country which is an independent organisation overseeing and enforcing the application of the GDPR and local data protection rules. In Denmark, this is the Danish Data Protection Agency whose contact details are available here. However, we hope that you will contact us first, using the below contact details, so that we may reach agreement.

 

Various

 

Apart from this Privacy Policy, Alumeco has an IT security policy with the purpose of ensuring that processing of personal data is carried out on the basis of an adequate security level. Alumeco’s IT security policy is revised in connection with the annual IT revision.

 

Alumeco reserves the right at any time to one-sidedly change the Privacy Policy. The Privacy Policy is available at Alumeco’s Website at all times.

 

Enquiries concerning this Privacy Policy can be directed to Alumeco GDPR team at GDPR@alumeco.dk.

 

Last revision: 18.08.2022