1. Data controller

The legal entity responsible for the processing of personal data is:

Bonnier Publications A/S

Strandboulevarden 130

DK-2100 Copenhagen Ø

Org. no. 12376405

2. Description of the processing

Bonnier Publications processes personal data for a number of different purposes, which will be explained below. 

These include:

• Provision of services
• Trade and cooperation with third-party providers
• Marketing
• Product development and statistics
• Recruitment
• Business operations
• Compliance with legal obligations

This privacy policy does not apply to the processing of personal data about Bonnier Publications’ employees, including external consultants and similar external business matters, or data covered by the rules of the Danish Act on Information Databases.

Purpose – Delivery of services

Bonnier Publications uses personal data in order to supply our products to our customers and similar users of our services, as well as to conduct transactions as part of customer agreements. 

These can include:

Provision of our products and services 

Personal data is used to contact data subjects for the purpose of providing products and services they have purchased, signed up for and/or subscribed to.

Providing newsletters

Personal data is used to send out newsletters, which data subjects have signed up for.

Customer service

Support in connection with the data subject’s purchases and subscriptions, as well as other enquiries.

User profile

We may store personal preferences in profiles on our websites and in our apps in order to provide more tailored content.

Categories of personal data

We process the following categories of personal data:

General personal data

Such as:

• Name
• Address
• Email
• Telephone number
• IP address
• Payment details
• Purchase and payment history
• Use of digital services
• Interests and preferences
• Information regarding e.g. weight, height, diet and exercise habits when using selected apps
• Login credentials for customer support

Sensitive data

Health information e.g. allergies when booking travel activities.

Sources

We collect information from the following sources:

• Directly from the data subject
• From affiliated companies in the Bonnier Group
• From other sources that are publicly available, such as telephone directories and geodemographic classifications

Basis for processing

We process personal data based on the following processing basis:

• If necessary for the performance of a contract to which the data subject is a party by purchasing or signing up for our services, as well as support in the event of any enquiries.
• If explicit consent has been given for the processing of personal data by signing up for newsletters or creating a profile.

Recipients

We may disclose your personal data under the following circumstances:

1. To affiliated companies in the Bonnier Group and other partners, e.g. travel agencies.
2. To suppliers we work with to support our business e.g.:

• Service providers, technical support and customer service
• Delivery services
• Financial institutions and payment service providers

Storage

We will retain personal data for as long as necessary for the purposes mentioned above.

• As long as a contractual relationship has not been terminated, consent to receive newsletters has not been withdrawn and we are not obliged to store the personal data, e.g. in connection with a legal obligation.
• Upon conclusion of the customer relationship, we will store personal data for up to 6 years, unless there are special reasons for storing the information for a longer period of time. This period of time is determined on the basis of a fair assessment based on the deadlines in the Danish Bookkeeping Act.

Purpose – Trade and cooperation with third-party providers

Information about business customers belonging to external providers is used to contact companies, e.g. for the purpose of advertising sales or other forms of cooperation.

Categories of personal data

We process the following categories of personal data:

• Name
• Email
• Telephone number
• Job information

Sources

We collect information from the following sources:

• Directly from the data subject
• From affiliated companies in the Bonnier Group
• From other sources that are publicly available, such as telephone directories and websites

Basis for processing

We process personal data based on the following processing basis:

• Legitimate interest in being able to work effectively with our partners and suppliers, e.g. regarding advertising sales

Recipients

We may disclose personal data to the following categories of recipients

1. Affiliated companies in the Bonnier Group
2. Suppliers we work with to support our business e.g. service providers, technical support and customer service.

Storage

We will retain personal data for as long as necessary for the purposes mentioned above.

• As long as it is relevant for the fulfilment of commercial cooperation

Purpose – Marketing

Personal data is used for marketing purposes, including targeting communication at customers and end-users based on areas of interest, as well as digital behaviour on our websites, apps and newsletters and purchase history, in order to prepare and send relevant marketing.

Categories of personal data

We process the following categories of personal data:

General personal data

Such as:

• Name
• Address
• Email
• Telephone number
• IP address
• Purchase and payment history
• Use of digital services, including newsletters
• Interests and preferences
• Gender
• Age

Sources

We collect information from the following sources:

• Directly from the data subject
• From affiliated companies in the Bonnier Group
• From other sources that are publicly available, such as social media, telephone directories and geodemographic classifications

Basis for processing

We process personal data based on the following processing basis

• Necessary for the pursuit of Bonnier Publications’ legitimate interest in marketing products and services.
• Based on consent where direct digital marketing is used.

Recipients

We may disclose personal data to the following categories of recipients

1. To affiliated companies in the Bonnier Group
2. To suppliers we work with to support our business e.g.:
   • Service providers, technical support and customer service
   • Delivery services
3. With a view to marketing our products and services to:
   • Data and analysis agencies
   • Creative and digital agency partners
   • Consulting firms
   • Telemarketing agencies
   • Digital media partners
4. For the purpose of marketing their goods and services by partners, and in accordance with applicable law, we also share general customer data for the purpose of breaking it down into customer segments with partners within the following categories:
   • Publishing, including book clubs
   • Mail order companies
   • Lottery providers
   • Suppliers of health products
   • Digital advertisers

Storage

We will retain personal data for as long as necessary for the purposes mentioned above.

• As long as it is necessary to fulfill our marketing interests
• As long as consent to receive marketing content has not been withdrawn and we are not obliged to store the personal data, e.g. in connection with a legal obligation

Purpose – Recruitment

• Personal data is processed when assessing the potential of job applicants as employees of Bonnier Publications
• Upon employment, employees will be subject to an internal privacy policy

Categories of personal data

General personal data

Such as:

• Name
• Address
• Email
• Telephone number
• Education
• Nationality
• Interests and competencies
• Professional history

Criminal record

If the employment requires it, we may request that the applicant submits documentation of a relevant clean criminal record.

Sensitive personal data

In general, Bonnier Publications does not process sensitive data. If the data subject nevertheless wishes to share such information, e.g. if it is relevant for health reasons, Bonnier Publications will not process this information beyond what is strictly necessary for the employment relationship.

Sources

We collect information:

• Directly from the data subject
• From publicly available information, for example social media such as Facebook and LinkedIn
• From other sources expressly permitted by the data subject, e.g. references

Basis for processing

• Legitimate interest in recruiting talented and pleasant employees.
• Explicit consent, where processing relates to sensitive data that we have no basis for processing according to other applicable legislation

Recipients

• Our partners who provide secure systems for processing applications

Storage

• Personal data is stored for as long as applications are still being processed
• Subsequently, personal data is stored for legal reasons for a maximum of 6 months, after which the data is deleted if the applicant is not hired.

Purpose – Business operations

Personal data is processed in order to pursue Bonnier Publications’ legitimate interest in running a secure and efficient business. 

These can include:

Credit rating

Personal data can be used to perform credit assessments in connection with purchases.

Preventing fraud

Personal data can be used to prevent unreasonable and unlawful circumvention of the company’s purchasing terms and conditions of use.

Claims and similar legal demands

Personal data is used to assert legal claims e.g. in the collection of debts.

Categories of personal data

We process the following categories of personal data:

General personal data

Such as:

• Name
• Address
• Email
• Telephone number
• IP address
• Payment details
• Purchase and payment history
• Use of digital services
• Log-in details

Sources

We collect information from the following sources:

• Directly from the data subject
• From affiliated companies in the Bonnier Group
• From other sources that are publicly available, such as telephone directories and geodemographic classifications

Basis for processing

We process personal data based on the following processing basis:

• If necessary for the performance of a contract to which the data subject is a party
• If it is necessary for the pursuit of Bonnier Publications’ legitimate interest in running a secure and efficient business

Recipients

We may disclose personal data under the following circumstances:

1. To affiliated companies in the Bonnier Group and other partners, e.g. travel agencies.
2. To suppliers we work with to support our business e.g.:
   1. Service providers, technical support and customer service.
   2. Financial institutions and payment service providers.

Storage

We will retain personal data for as long as necessary for the purposes mentioned above.

• Upon conclusion of the customer relationship, we will store personal data for up to 6 years, unless there are special reasons for storing the information for a longer period of time. This period of time is determined on the basis of a fair assessment based on the deadlines in the Danish Bookkeeping Act.

Purpose – Compliance with legal obligations

We process personal data for the purpose of complying with and documenting our legal obligations under, for example, the Danish Bookkeeping Act, as well as where necessary for documentation in the event of any legal disputes.

Categories of personal data

We process the following categories of personal data:

General personal data

These can include: 

• Accounting material
• Customer information
• Any enquiries from customers, users and stakeholders

Sources

We collect information from:

• Directly from the data subject
• From affiliated companies in the Bonnier Group

Basis for processing

• When it is necessary for compliance with a legal obligation

Recipients

• Relevant public institutions
• Law firms and officially authorised stakeholders

Storage

• Personal data provided in connection with the purchase and delivery of services may be stored for up to six years after the end of the customer relationship, cf. the Danish Bookkeeping Act

3. Consequences of the processing

When we process personal data for marketing purposes, we will analyse and profile on the basis of the data subject’s interests and conduct, in order to make our marketing and other communication as relevant as possible.

4. Digital and programmatic marketing

In connection with online advertising, Bonnier Publications uses a standard TCF (Transparency and Consent Framework) for good online behaviour and disclosure of the user’s online consents and tracking preferences to third-party advertisers. This standard is managed through the websites’ cookie banners, where information can be found about each of the advertisers that use the standard. The standard has been developed and managed by the international interest association for advertisers, IAB Europe.

5. Transfers to countries outside the EU/EEA

We may transfer personal data to countries outside the EU/EEA, including the USA.

Transfers to third countries will only take place for the specific purposes mentioned under section 2, and we will always ensure that the appropriate safeguards are in place when there is a transfer to a country outside the EU/EEA as a consequence of the following:

1. The country/countries or company/companies has/have been assessed by the Commission as countries that generally ensure an adequate level of protection of personal data, either through legislation or other measures
2. If the country/countries or company/companies is/are not deemed by the Commission to be countries that ensure an adequate level of protection of personal data, we will ensure that there are adequate safeguards by using the Commission’s standard contracts, as published by the Commission. A copy of this contract/agreement can be obtained by contacting Bonnier Publications

6. Mandatory information

The following information is mandatory for doing business with Bonnier Publications:

• Name, email address and any payment information and preferences – if you would like a digital product
• Name, address, email address and payment information, if applicable – if you wish to have a physical product delivered.

7. Your rights

You have the following rights:

• You have the right to request access, rectification or erasure of your personal data.
• You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
• If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of processing performed before the withdrawal of your consent.
• You have an unconditional right to object to the processing of your personal data for direct marketing purposes, including targeted marketing. You can do this by writing to [email protected].
• You have the right to receive information about whether personal data about you is being used and, where this is the case, access to this data.
• You have the right to lodge a complaint with a data protection supervisory authority, for example the Danish Data Protection Agency.

You always have the option of unsubscribing from a newsletter or other communication received via email/text message by using the unsubscribe link directly in the mailing. You can also exercise your rights by sending an email to: [email protected].  Please indicate which email(s) and any telephone number you wish to unsubscribe.

Please note that consent to receive direct marketing via notifications on our websites can only be cancelled directly in your personal browser settings. You can unsubscribe from notifications in your browser settings under “Settings” – “Content settings” – “Notifications”. Similarly, you can unsubscribe from push notifications in our apps on your mobile device under “Settings” and “Notifications”.

There may be conditions or limitations to these rights. It is therefore not certain that you have the right to data portability in all cases, for example, or that you can object to profiling of content where it is a central part of our services – this depends on the specific processing activities.

In the event of significant changes, we will notify you via this website or by email if possible. The current version of this policy can be found on our website bonnierpublications.com/privacypolicy

2022-05-20