Last updated 12 October 2023

Flux AD A/S, a company registered in Denmark under company registration number 41248831 (‘us’, ‘we’, ‘our’, ‘Flux AD’), and our affiliated group companies worldwide, recognises and respects the right to personal data protection.

This Privacy Notice applies to all Flux AD’s customers, business partners, customers’ end users, visitors to our offices and websites, job candidates and other parties who have a direct or indirect relationship with us.

For the purpose of this notice, the term ‘personal data’ means any information relating to natural persons who can be identified or who are identifiable, directly from the information in question, or who can be indirectly identified from that information in combination with other information.

This privacy notice tells you what kind of personal we process, the purposes of the processing, the legal base or basis we rely on to process this data, for how long we retain it and other privacy related details. The information we process about you will vary depending on your relationship with us and how you interact with us.

When appropriate, we will provide a ‘just in time’ notice to cover any additional processing activities not mentioned in this notice.

If you have any questions about how we process your personal data, please do not hesitate to contact dataprivacy@cowi.com (COWI A/S is our parent company).

 

Contact Information

Flux AD A/S
Valhøjs Allé 126
2610 Rødovre
Denmark

To contact our Group Privacy Office, please contact dataprivacy@cowi.com

 

Clients

As a client or as a potential client, we process your personal data to provide our services, and to conclude or fulfil an agreement we have entered into with you or the organisation that you represent.

The personal data we process:

• The personal data we process is limited to what is necessary for us to perform the contract to which you are a party or to take steps at your request prior to entering into a contract. This may include your name, title, contact information such as email address, telephone number, as well as professional information such as job title, company or organisation name, industry sector, and professional background. We may also collect financial information such as billing and payment information, information about the services requested or provided, including project details, timelines, and budgets, and any other information relevant to the provision of our services.

Our purposes for processing this personal data:

• We use your personal data for various purposes, such as providing our services to you or the organisation you represent, entering into and fulfilling contractual agreements, managing our relationship with you or the organisation you represent, communicating with you regarding our services or contractual obligations, and to comply with legal and regulatory obligations.

Where we source this personal data from:

• We may source this personal data directly from you, for example when you provide us with your contact details or when you enter into an agreement with us. We may also collect this personal data from the organisation you represent and or from any other party that may be associated with our services.
  
  

Our legal bases for processing this personal data:

• Contract: We process your personal data when necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract.
• Legal interest: We process your personal data when necessary to meet our legitimate purposes when permitted by law. For example, we rely on this legal basis to manage our contract with you or the organisation you represent.

 

Business Partners and Collaborators

We engage in partnerships and collaborations with numerous business partners and collaborators across various projects. As a result, we may need to process your personal data when we collaborate on a joint project or participate together in a joint venture or a bidding process. This processing of personal data enables us to effectively deliver services to our clients and optimise our collaborative efforts with our partners. We also process the data to facilitate collaboration and partnerships with the involved parties, or to assess the feasibility of establishing contractual relationships. For instance, we may engage in processing this data when participating in joint ventures or partnerships with other organisations or clients.

The personal data we process:

• The personal data we may process includes contact information such as your name, email address, phone number, and other relevant contact information. Additionally, we may process professional information such as your job title, company name, business address, and other related professional information, including your CV and details listed therein. Furthermore, we may also process any other personal data that you provide us with during our business interactions or that we consider legitimate to process in the course of our joint projects.
  
  

Our purposes for processing this personal data:

• Our processing of personal data of business partners and collaborators is necessary for effective collaboration and delivery of services with them and to our clients. The personal data collected, which may include contact and professional information, enables us to facilitate communication and collaboration, manage contractual and legal obligations, enhance project delivery, and maintain business relationships.
• Furthermore, depending on our relationship, our purpose of our processing is to share your personal data with relevant parties, for example when we submit your information to a client, or when we collaborate in a joint venture. We may also process this data for us to evaluate whether we can enter a contract with you or the organisation that you represent, based on the information submitted to us and depending on whether the information is deemed necessary of our client or other relevant third parties.
  
  

Where we source this personal data from:

• We may source this personal data directly from you or from the organisation you represent. This may occur when we collaborate on a project, participate in a joint venture, submit a bid for a project, or when we evaluate, together with our client, if we can enter into contract with you or the organisation you represent.
  
  

Our legal bases for processing this personal data:

• Contract: We process your personal data when necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
• Legal interest: We process your personal data when necessary to meet our legitimate purposes when permitted by law. For example, we rely on this legal basis to for the effective collaboration and delivery of services with business partners and collaborators. We also rely on this legal basis to evaluate and manage our relationship with you or the organisation you represent, including assessing and confirming suitability for entering a contract.

 

End Users

We provide a range of online platforms, including FLUX FAST and other IT solutions to our clients. As an end user of these platforms, we gather various data to provide you with access to the platforms, improve functionality, ensure optimal performance, and to gain insights into how our users engage with our platforms. This information helps us enhance the user experience, identify and troubleshoot any technical issues, and optimise the platforms to meet the needs of our clients and end users.

The personal data we process:

• The personal data we may process includes account details, logging information, product interactions, request data, performance data, diagnostic data, end user customer support data and user details such as names, initials, email, employer, title and similar.
  
  

Our purposes for processing this personal data:

• We utilise your personal data for a variety of reasons, including fulfilling our obligations to our clients, to personalise your experience and improve the relevance of our services, troubleshooting any errors that may arise, verifying appropriate user interactions with our platforms, detecting and preventing misuse, and for marketing purposes using anonymised data only.
  
  

Where we source this personal data from:

• We may source this personal data directly from you, for example when you log onto our platforms and when you interact with our customer support team. We may also source your personal data from the organisation which has granted you access to our platforms, or by completing data entry fields directly within the platform or in connection thereto.
  
  

Our legal bases for processing this personal data:

• Legal interest: We process your personal data when necessary to meet our legitimate purposes when permitted by law. For example, we rely on this legal basis to improve our platforms, to grant access, to help and support end users, to prevent misuse and to use anonymised data for legitimate marketing purposes.
  

 

Solicited and Unsolicited Job Applications

Our processing of your personal data in connection with our recruitment activities is to assess your qualifications and suitability for a solicited role you have applied for, or if you have submitted an unsolicited application. The personal data may also be used to contact you to progress your application with a view to offering you an employment contract and may further be used to screen if other open job vacancies might be of interest to you.

The personal data we process:

• We may process your name, email, phone number, resume, CV, cover letter, language, experience, education, qualifications, citizenship, and any other relevant information required for us to evaluate your application or information you have provided as part of your application.
• As part of our recruitment activities, we may create personal data about you through assessments and personality tests, which have independent privacy notices presented to you beforehand by our test providers. If you are called in for an interview, we may also process this data.
• In some circumstances, we may request a copy of your personal data relating to criminal convictions, offences, or related security measures depending on the role you have applied for. We will only collect this information with your prior explicit consent.
• If your application is successful and you accept our conditional offer of employment, we will process additional personal data about you. Please visit our Privacy Notice for Employees to familiarise yourself with the personal data we may process as part of your employment with us.
• Please do not include personal data such as national identification numbers, data relating to criminal convictions and offences, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning sex life or sexual orientation in your application, unless requested by us directly and unless you agree to disclose this information.

Our purposes for processing this personal data:

• Our processing of your personal data in connection with our recruitment activities is intended to evaluate your candidacy for a particular job, while also ensuring that we provide you with the best possible recruitment experience by keeping you informed of any suitable job vacancies. Our aim is to determine if you are the right fit for the position and to contact you to progress your application with the goal of offering you an employment contract.
• We may also process your personal data if you consent to be obtained in our resource database or talent pool prior to the erasure of your candidate profile. We may hereafter contact you to if suitable vacancies arise.
  
  

Where we source this personal data from:

• We may source this personal data directly from you when you apply for a job through our recruitment channels or when you send us an unsolicited application. We may also source your personal data from our test providers, referees, public authorities, and other third parties if permitted by law.
  
  

Our legal bases for processing this personal data:

• Contract: We process your personal data when necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into an employment contract.
• Legal interest: We process your personal data when necessary to meet our legitimate purposes as permitted by law. For example, we rely on this legal basis to evaluate and manage our recruitment process, including assessing and confirming suitability for employment. We may also rely on this legal basis if we offer another open vacancy that may be of interest to you.
• Consent: We process your personal data based on your explicit or implicit consent. For instance, if we ask you to provide contact details for referees of former employers to collect information about you, we rely on this legal basis. Similarly, if we request a copy of your personal data relating to criminal convictions and offences or related security measures depending on the role you have applied for, we may rely on this legal basis. However, we will always obtain your approval before contacting any referrer or obtaining your data relating to criminal convictions and offences. We may also rely on this legal basis if you consent to be obtained in our talent pool.
  
  

Website Visitors

We may place cookies on your devise when you visit our websites, for example to personalise content, to provide social media features and to analyse our traffic. We also share information about your use of our websites with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services.

Please note that we may use third-party cookie providers who may transfer your personal data to countries outside the EU/EEA, if you consent to our use of preference, statics and marketing cookies. These countries may not provide for an adequate level of data protection based on a European Commission decision, or other appropriate privacy safeguards. Furthermore, these countries may not have a local supervisory authority to safeguard personal data, and no or limited personal data protection or privacy rights. If you allow for our use of cookies, wholly or partly, you explicitly consent to our transfer of your personal data to these third-party cookie providers.

Joint data controllers: Please note that we are so-called ‘joint data controllers’ with our third-party cookie providers, meaning that we jointly determine the purposes and means of our processing of your personal data, and that we may process personal data for own separate purposes. A comprehensive list of all our third-party cookie providers is listed in our Cookie Notice, including their respective privacy notices and instructions on how to exercise your privacy rights.

The personal data we process:

• The personal data we may process is your IP address, device ID, browser information, location data, user preferences and settings, login and authentication information, session cookies, browsing activity and integration with website features.
  
  

Our purposes for processing this personal data:

• We use your personal data for various purposes, such as to improve website performance and functionality, to remember your preferences, settings and sessions, to provide personalised content and advertising, to track website analytics and user behaviour, and to enhance website security.
  
  

Where we source this personal data from:

• We may source this personal data directly from you when visiting our websites and from third-party sources such as other website you have visited.
  
  

Our legal bases for processing this personal data:

• Legal interest: We process your personal data when necessary to meet our legitimate purposes as permitted by law. For example, we rely on this legal basis to place necessary cookies for website functionality purposes, to ensure proper user authentication and website security and to remember your user preferences and settings.
• Consent: We process your personal data if you consent to our use of preferences, statics, marketing and unclassified cookies. You may withdraw your consent at any time by changing our cookie settings. Please be referred to our Cookie Notice.

 

Office Visitors

Our offices receive a diverse range of visitors, including clients, potential clients, suppliers, tradespeople, stakeholders, job candidates, and business partners and collaborators. Consequently, we may process your personal data for the purpose of managing your visit and providing you with access to our Wi-Fi network.

The personal data we process:

• The personal data we may process is your name, contact details, company name and job title, and other information of relevance to your visit.
• If you choose to sign onto our Wi-Fi network, we may process your device information, location data and network activity data.
  
  

Our purposes for processing this personal data:

• We use your personal data for various purposes, such as providing you with access to our office and ensuring the safety and security of all individuals on the premises, including our assets.
• If signing onto our on-site Wi-Fi, we process your personal data to grant you access to our network, to manage our network and for security and safety purposes.
  
  

Where we source this personal data from:

• We may source this personal data directly from you or from the organisation you represent.
  
  

Our legal bases for processing this personal data:

• Legal interest: We process your personal data when necessary to meet our legitimate purposes as permitted by law. For example, we rely on this legal basis to maintain the security of our premises and Wi-Fi network and to manage access control to our offices and networks.

 

General Enquiries

As an organisation, we receive several enquiries from different sources, including private individuals, the general public, and various entities. These enquiries cover a wide range of topics, including our organisation, the services we offer, and the projects we are involved in.

The personal data we process:

• Depending on the enquiry and what information and personal data you have made available to us, we may process that personal data for us to respond to your query. Generally, we may process your name, contact details, enquiry content and any additional information voluntarily provided in the enquiry.

Our purposes for processing this personal data:

• The purpose of our processing activities is to respond to your enquiry effectively, provide you with the requested information, address your concerns or issues, and offer customer support. In some cases, we may share your personal data with relevant business partners and collaborators if we believe they can address your enquiry and provide the necessary assistance.

Where we source this personal data from:

• We obtain this personal data directly from you when you submit an enquiry through our website, email, phone call, or any other communication channel.

Our legal bases for processing this personal data:

• Consent: We process your personal data based on your consent. By submitting your enquiry, you provide us with the consent to use your personal data for the purposes stated above.
• Legal interest: We process your personal data when necessary to meet our legitimate purposes as permitted by law. For example, we rely on this legal basis to respond to your enquiry effectively.

 

Recipients of Personal Data

Sometimes we may share your personal data with other organisations and authorities, but only when this is legitimate, necessary and/or when we have a legal basis or bases to do so. For example, we may share your personal data with:

• Other legal entities in the COWI Group under COWI Holding A/S.
• We may share your personal data with third parties where necessary for the provision of our services or the fulfilment of our contractual obligations. This may include sharing your personal data with our sub-contractors or partners who are involved in the provision of our services.
• We may also share your personal data with our professional advisers, regulators, or other third parties where required by law.
• As part of the operation of our business, your personal data may be disclosed to external suppliers, including independent data controllers and data processors such as system vendors, external legal councils etc.
• We may also transfer personal data about you to third parties in connection with third-party investments, acquisitions and/or the sale of COWI Group entities or parts thereof.

 

Transfer of Personal Data

If you are located in the European Economic Area (EEA), please be informed that we may transfer your personal data for the purposes set forth in this notice to countries outside of the EEA. For example, we may transfer your personal data to our COWI Group entities located in e.g., the United States, Canada and India for us to cooperate and function as a global business. We have established the necessary and appropriate guarantees to protect this transfer using the European Commission’s so-called Standard Contractual Clauses (SCCs). A copy of these clauses can be obtained by contacting dataprivacy@cowi.com

 

Retention Periods

• We retain your personal data for the duration necessary to fulfil the specific purposes outlined above. These purposes may encompass providing our services, offering customer support, meeting contractual obligations, and ensuring the security and integrity of your data. We only maintain data that is pertinent to these objectives.
• Our data retention practices adhere to applicable laws and regulations. We conform to the retention periods mandated by the legislation governing our operations. This includes laws related to data protection, taxation, employment, and industry-specific regulations. In instances where specific legal requirements do not specify a retention period, we keep data based on justified needs.
• Personal data may be retained for our legitimate interests if these interests clearly outweigh those of the data subject. For instance, we may keep personal data for the purpose of establishing, exercising, or defending legal claims, whether in court proceedings or in an administrative or out-of-court procedure. This ensures that we can safeguard our rights and interests in legal matters.
• Our commitment to data minimisation means that we endeavour to retain your personal data for the shortest possible duration. Once the data is no longer necessary for the purposes for which it was collected, or otherwise, we take measures to either delete it or anonymise it, making it no longer identifiable to any individual.
• If we process your personal data based on your consent, we will retain this data until the consent is withdrawn or until we decide to delete or anonymise it.

 

Your Privacy Rights

Under applicable law, you have several rights in relation to our processing of your personal data. If you wish to make use of your rights, please contact dataprivacy@cowi.com

• The right to access: You have the right to request access to the personal data that we process about you, as well as additional information.
• The right to rectification: You have the right to have inaccurate personal data rectified, or completed if it is incomplete.
• The right to erasure: In certain circumstances, you have the right to have personal data about you deleted before the time of our general deletion or anonymisation occurs.
  
• The right to restrict processing: In certain circumstances, you have the right to request the restriction of the processing of your personal data. If you are entitled to restrict the processing, we may only process your personal data with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest.
• The right to object: In certain circumstances, you have the right to object to your processing of your personal data.
• The right to data portability: In certain circumstances, you have the right to receive your personal data in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without hindrance.
• The right to withdraw consent: Where the processing is based on consent, you have the right to withdraw your consent at any time. To withdraw your consent, please contact dataprivacy@cowi.com. The withdrawn consent will not affect the lawfulness of the processing before its withdrawal. You will never be penalised for refusing to consent to any processing activities, nor will you be penalised for withdrawing your consent at a later point.
• The right to lodge a complaint: If you wish to complain about the processing of your personal data, please contact dataprivacy@cowi.com. You may also file a complaint to the national supervisory authority. The national supervisory authority responsible for Flux AD A/S is Datatilsynet, The Danish Data Protection Agency, Denmark.

If you need further guidance in relation to your rights, please contact your national supervisory authority.