Privacy Policy
Last updated: 4 January 2021
Subaio Budget: For the privacy policy relating to our stand-alone Subaio Budget tool (Danish only), please see Privatlivspolitik – PSD2.
1. General
This B2B Privacy Policy applies when contacting Subaio ApS (CVR nr. 37766585, located at Gasværksvej 26B 1, 9000 Aalborg, Denmark) through website contact forms, social media accounts, or other third-party services. It covers situations where individuals have visited Subaio's website, reached out for business purposes, or where Subaio collected information via social media, public sources, or shared event/meeting attendance for B2B interactions.
2. Which Data Does Subaio Process?
Subaio may collect personal data submitted through Forms, including name, email address, and other voluntarily provided information. The company also gathers data through public searches, event attendance tracking, and cookies or similar tools (detailed in section 7).
Data retention periods depend on necessity. However, Subaio may retain information longer if required by law or to protect its legal interests, such as during ongoing legal proceedings.
3. Why Does Subaio Process Your Personal Data?
Primary purposes include:
- Providing requested information through Forms
- Fulfilling business tasks you request
- Sales and marketing activities (based on legitimate business interests)
- Customer analysis, market research, and statistics
- Business operations follow-up and development
Subaio may process data independently for legitimate promotional interests. Individuals can request exclusion from direct marketing by contacting Subaio in writing.
Processing Activities and Legal Bases
| Activity | Legal Basis | Retention Period |
|---|---|---|
| Communication, customer analysis, marketing | Article 6(1)(f) GDPR (legitimate interest) | 5 years post-inquiry or agreement end |
| Website usage (necessary cookies) | Article 6(1)(f) GDPR | Varies by cookie type |
| Other cookies (analytics) | Consent required; Article 6(1)(a) GDPR | Per cookie policy |
| Electronic marketing material | Danish Marketing Practices Act § 10 | 2 years after last distribution |
4. Third Parties
Subaio may share information with collaboration partners and data processors (IT suppliers, marketing vendors) but remains responsible for proper handling. Marketing network advertisers receive data solely for promotional purposes based on legitimate business interests.
Data may be disclosed when:
- Required by applicable law or competent authority decision
- Necessary to fulfill legal obligations
- Protecting Subaio's legal interests
- Detecting, preventing, or addressing fraudulent behavior or security issues
International Data Transfers
Data transfers to non-EU/EEA countries occur only with adequate protection levels or appropriate safeguards like "Standard Contractual Clauses" (per EU regulations).
Service providers outside EU/EEA:
- LinkedIn (USA) - Standard Contractual Clauses
5. Changes to the Privacy Policy
Subaio reserves the right to modify this policy anytime. Changes will be announced on its website with reasonable advance notice. Individuals may notify Subaio before updated policies take effect if they object to processing under new terms.
6. Data Security
Subaio implements necessary security measures to protect personal data from unauthorized access, modification, and deletion, maintaining user confidence.
7. Cookies
Subaio's websites use cookies and similar technologies for proper functioning, visit statistics, and user experience enhancement. Users may configure browsers to reject cookies, though this may impair website functionality. Additional details appear in the cookie policy.
8. Contact Details & Your Rights
Data Controller: Subaio ApS
Data Protection Officer: Luke Fier
Address: Gasværksvej 26B 1, 9000 Aalborg, Denmark
Email: privacy@subaio.com
Your Rights
Under applicable law, you may request:
- Access to personal data
- Correction or deletion
- Processing restrictions
- Objection to processing (including direct marketing)
- Data portability
Requests are typically answered within one month. Manifestly unfounded or excessive requests may incur administrative fees.
You may withdraw consent anytime (affecting only future processing, not past lawful processing).
Complaints
Contact Datatilsynet (Danish supervisory authority) at Carl Jacobsens Vej 35, 2500 Valby, www.datatilsynet.dk if dissatisfied after contacting Subaio.