1. Data Controller
The data controller for the processing of personal data described in this section is:
Qarma ApS
Hermodsvej 5B, 3.
CVR 37912786
Email:
info@qarmainspect.com
2. Purpose of ProcessingWhen you subscribe to our newsletter, we process your personal data for the following purposes:
a) to send you our newsletter, including marketing communications, product updates, industry insights, and event invitations relating to Qarma and its services;
b) to administer your subscription, including registration, segmentation, and processing of unsubscribe requests; and
c) to follow up commercially through our sales team where you have indicated an interest in our products or services.
3. Categories of Personal DataWe process the following categories of personal data in connection with your newsletter subscription:
a) identification data: first name and last name;
b) contact data: email address;
c) professional data: company name and job title; and
d) engagement data: information about your interaction with our newsletters, including whether you have opened a given email and which links you have clicked.
4. Legal BasisThe legal basis for our processing of your personal data is your prior consent, cf. Article 6(1)(a) of the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR") and section 10 of the Danish Marketing Practices Act (markedsføringsloven).
You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to such withdrawal. You may withdraw your consent by clicking the "unsubscribe" link contained in every newsletter or by contacting us using the details set out in section 1.
5. Sources of DataThe personal data we process is collected directly from you at the time of subscription via our website or other Qarma-controlled channels.
6. Recipients and Data ProcessorsYour personal data is shared with the following categories of recipients:
a) HubSpot, Inc., which acts as our data processor and provides the customer relationship management (CRM) and email marketing platform used to administer subscriptions and dispatch newsletters; and
b) Internal recipients within Qarma ApS, including our sales personnel, who may access your data through our CRM system in order to follow up commercially in accordance with the purposes set out in section 2.
We have entered into a data processing agreement with HubSpot, Inc. that complies with the requirements of Article 28 GDPR.
7. Transfers to Third CountriesHubSpot, Inc. is established in the United States and may process your personal data outside the European Economic Area ("EEA"). Such transfers take place on the basis of the European Commission's Standard Contractual Clauses adopted pursuant to Article 46(2)(c) GDPR and, where applicable, the EU-U.S. Data Privacy Framework, which together provide an adequate level of protection for your personal data.
8. Tracking in NewslettersOur newsletters contain tracking technologies (including tracking pixels and tagged hyperlinks) that allow us to register whether and when you open an email and which links you click. This information is used to measure the effectiveness of our communications and to tailor future content. The tracking is performed on the basis of your consent, cf. section 4.
9. RetentionWe retain your personal data for as long as your subscription remains active. If you unsubscribe from our newsletter, your personal data relating to the subscription will be deleted without undue delay, unless we are required by applicable law to retain certain data for a longer period (for example, to document compliance with marketing or accounting legislation).
10. Your RightsSubject to the conditions set out in the GDPR, you have the following rights in relation to our processing of your personal data:
a) the right of access (Article 15 GDPR);
b) the right to rectification (Article 16 GDPR);
c) the right to erasure ("right to be forgotten") (Article 17 GDPR);
d) the right to restriction of processing (Article 18 GDPR);
e) the right to data portability (Article 20 GDPR);
f) the right to object to processing (Article 21 GDPR); and
g) the right to withdraw your consent at any time (Article 7(3) GDPR).
You may exercise your rights by contacting us using the details set out in section 1.
11. ComplaintsYou have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet) if you consider that our processing of your personal data does not comply with applicable data protection law. Contact details are available at
www.datatilsynet.dk.