Privacy policy for customers and website visitors

RelyOn Nutec Holding A/S (including subsidiaries and affiliates) process your personal data when you are a customer, receive our newsletters and other electronic communication and/or use our website at www.relyonnutec.com and associated sub websites. In this privacy policy, we describe how we process your personal data.

We fully respect your right to privacy when using our services.

If you only visit the website, you should read sections 1 and 5 below.

If you only visit one of our training centers and register in the check-in system, you should read sections 4 and 5.

If you are a customer of RelyOn Nutec, create or cancel bookings on the booking portal website or cancel a purchase without becoming a customer, you should read sections 1, 2 and 5 below.

If you subscribe to a newsletter or other electronic mail or fill out a contact form on the website, you should read sections 1, 3 and 5 below.

1. Ordinary visitors on the website, relyonnutec.com

When you visit and navigate www.relyonnutec.com and associated sites, we process personal information about you.

Types of information and purpose

We collect and process the following types of personal information:

• IP address, operating system, language settings, browser type, type of equipment, MAC number (depending on equipment), etc.,
• Your navigation on the website and immediately before and after your visit on www.relyonnutec.com time and duration of visits to pages and sub-pages, etc.,
• Interests and preferences, and
• RelyOn Nutec collects this information by means of cookies on www.relyonnutec.com and associated sites. You can read about this in our Cookie Policy.

We collect and process the information for the following purposes:

• To retrieve the website from the server so that the website can be displayed in your browser,
• To optimise the website and your user experience,
• To prepare statistics on the use of the website by you and others,
• To prepare statistics and analyses with the objective of improving products, services and technologies,
• Marketing purposes, including profiling and behaviour-based marketing initiatives to make our product information and offers as relevant to you as possible.
• To comply with applicable legislation (e.g. the EU General Data Protection Regulation (the GDPR) and e-privacy rules), including documentation requirements:
  • Compliance with basic principles for processing of personal data and legal basis for processing (e.g. obtaining consent),
  • Implementation and maintenance of technical and organisational security measures,
  • Investigation of suspected or known security breaches and reporting to data subjects and authorities,
  • Processing of requests and complaints from data subjects and others, and
  • Handling of inspections and requests from supervisory authorities
• Management of disputes with data subjects and third parties.

Sources

We collect information about your behavior by means of cookies on the website. You can read more about this in our Cookie Policy. Information may also be collected from you directly, from our IT systems or from third parties.

Legal Basis for Collection and Processing of Personal Data

The legal basis for collection of your personal data by means of cookies, including for profiling purposes, is your consent, see relevant national legislation.

Your personal data may be processed for other purposes and based on another legal basis, including documentation of compliance with legislation, see article 6(1)(c) of the GDPR, and pursuing legal claims in accordance with RelyOn Nutec’s legitimate interests in safeguarding its legal position, see article 6(1)(f) of the GDPR.

You have the right to withdraw your consent; however, this will not affect any processing or disclosure prior to the withdrawal of your consent, i.e. withdrawal of your consent will only apply prospectively.

Disclosure of your personal data

Personal data will be disclosed and shared with digital media partners as described in the consent to cookies.

Collection on a voluntary or mandatory basis

The provision of personal data is voluntary. If you choose not to provide the information, you may not be able to access the website or use certain features on the website, etc.

2. Customers of RelyOn Nutec

When you make a purchase from us, e.g. on our booking portal, by telephone or another channel Relyon Nutec processes the following personal information (in addition to the information stated in section 1 above):

Types of information and purpose

We may collect and process the following types of personal information about you:

• Identification information: Name, invoice address, delivery address, date of birth, e-mail address, telephone number,
• Proof of identification information e.g. passport,
• Gender,
• Employment details including employing company, work location and your job title,
• Medical declaration and/ or medical information (where applicable),
• CCTV images,
• Payment details,
• Login information, such as user name and password,
• Purchase information, such as individual services/courses,
• Your use of RelyOn Nutec’s website, such as time of visits, sub-page visits and purchases made,
• Contact history between you and RelyOn Nutec,
• Recording of services and sales calls, and
• Customer satisfaction information,

We collect and process the information for the following purposes:

• To provide customer service and support regarding your purchases,
• To identify you in case of a dispute over a purchase,
• The collection of personal and medical (sensitive) data is required to ensure RelyOn Nutec have the necessary information to provide training courses and services,
• We record CCTV/video surveillance images to monitor the security of our premises and the safety of course participants during training,
• To make a self-service solution available to you that allows you to manage, change or terminate your agreements with RelyOn Nutec in accordance with the relevant terms and conditions,
• The information collected about you may be used for marketing purposes in accordance with applicable legislation,
• To comply with applicable legislation (e.g. the EU General Data Protection Regulation (the GDPR)), including documentation requirements:
  • Compliance with basic principles for processing of personal data and legal basis for processing,
  • Implementation and maintenance of technical and organisational security measures,
  • Investigation of suspected or known security breaches and reporting to individuals and authorities,
  • Processing of requests and complaints from data subjects and others,
  • Handling of inspections and requests from supervisory authorities,
  • Management of disputes with data subjects and third parties, and
  • Statistics concerning use of the website.

Your personal and sensitive information will not be shared, sold or disclosed other than as described in this privacy policy.

Sources

The personal information is collected from you when you make purchases or updates in RelyOn Nutec booking portal. Information about your use of our services is in some cases registered by RelyOn Nutec’s employees, e.g. in connection with general customer service. In addition, information may also be collected from other sources that are publicly available, e.g. social media, telephone registers and geodemographic classifications.

Legal basis for collection and processing of personal data

The legal basis for collection and processing of your identification information, is the following:

• Processing is necessary for the conclusion and performance of a subscription agreement, service agreement, purchase agreement or other agreements with you, see article 6(1)(b) of the GDPR,
• The legal basis for collection of information about your use of the website, enrichment of your data, collection and processing of customer satisfaction information and recording of sales calls is the following:

• Processing is necessary for pursuing a legitimate interest, see article 6(1)(f) of the GDPR
• The legitimate interests we pursue in enriching your personal data are to be able to identify you in relation to purchases, e.g. in case of a dispute over a purchase
• The legitimate interests we pursue in enriching your personal data are to target our marketing based on profiling (article 6(1)(f) of the GDPR)
• The legitimate interests we pursue in conducting customer satisfaction surveys are to improve our products and services, undertake follow-up and thereby ensure the overall satisfaction for you as customer
• The legitimate interests we pursue in recording service and sales calls are to improve our customer management and training of our employees and thereby the overall customer experience
• The legitimate interests in pursuing legal claims is RelyOn Nutec’s legitimate interests in safeguarding its legal position, see article 6(1)(f) of the GDPR.

The legal basis for collection and processing of personal data is:

The personal data may be processed for documentation of compliance with legislation, see article 6(1)(c) of the GDPR.

You have the right to withdraw your consent; however, this will not affect any processing or disclosure prior to the withdrawal of your consent, i.e. withdrawal of your consent will only apply prospectively.

Voluntary basis

We collect necessary and relevant data to deliver training courses and services. You are not obligated to provide the personal and sensitive information to us, however the consequences of not providing the information described above is that you may be unable to fully participate on training courses.

Disclosure of your personal data

Based on the legal basis mentioned above, personal data may be disclosed to the following recipients:

• Course awarding bodies such as OPITO, STCW, HSE, GWO, RTITB, ECITB etc.,
• DaWinchi and similar applications storing the certifications and ensuring that relevant parties are able to access and confirm due certifications as per mandatory legislation,
• Your employing company or company who made your booking,
• The RelyOn Nutec Group’s parent company,
• RelyOn Nutec internal and external audit processes,
• Insurance companies, and
• Government bodies such as Health and Safety Executive.

We will not share your medical (sensitive) data with anyone unless we receive your written consent. The requirement to share this information may be as follows:

• We may need to discuss your medical circumstances with a medical professional in support of your fitness to participate on a training course.
• We may need to inform your employer about your medical circumstances/ outcome in relation to your fitness to participate on a training course.

3. Email subscribers, filled out forms, etc.

When you register to receive e-mail from RelyOn Nutec or fill out a form, e.g. a contact form, RelyOn Nutec processes the following personal information (in addition to the information stated in section 1 above):

Types of information and purpose

We collect and process the following types of personal information about you:

• Identification information: Name, company name and occupation, if relevant, e-mail address, telephone number, IP address, and
• E-mail logging: number of clicks, number of openings, reading time, returning of newsletters (bounces), withdrawal of consent.

We collect and process the information for the following purposes:

• Marketing purposes, including to target our communication with you based on your interests and behaviour (digital behaviour on our websites and newsletters as well as any purchase history) in order to send you relevant marketing.
• To comply with applicable legislation (e.g. the EU General Data Protection Regulation (the GDPR), marketing legislation, e-privacy legislation), including documentation requirements:
  • Compliance with basic principles for processing of personal data and legal basis for processing,
  • Implementation and maintenance of technical and organisational security measures,
  • Investigation of suspected or known security breaches and reporting to individuals and authorities,
  • Processing of requests and complaints from data subjects and others, and
  • Handling of inspections and requests from supervisory authorities.
• Management of disputes with data subjects and third parties.

Sources

The personal information is collected from you when you make updates in RelyOn Nutec booking portal or through tracking in e-mails.

From other sources that are publicly available, e.g. telephone registers and geodemographic classifications.

Legal basis for collection and processing of personal data

The legal basis for collection and processing of personal data is:

When you have given your consent to receive direct marketing under the applicable national legislation, RelyOn Nutec’s legal basis is its legitimate interests in being able to send you the direct marketing to which you have provided your consent, see article (6)(1)(f) of the GDPR.

The legitimate interests we pursue in enriching your personal data are to target our marketing based on profiling, see article 6(1)(f) of the GDPR.

The legitimate interests in pursuing legal claims is RelyOn Nutec’s legitimate interests in safeguarding its legal position, see article 6(1)(f) of the GDPR.

The legal basis for collection of your personal data by means of cookies is your consent, see relevant national legislation.

The personal data may be processed for documentation of compliance with legislation, see article 6(1)(c) of the GDPR.

You have the right to withdraw your consent; however, this will not affect any processing or disclosure prior to the withdrawal of your consent, i.e. withdrawal of your consent will only apply prospectively.

Voluntary basis

When we collect personal data directly from you for the purpose of sending you newsletters, providing us with the information is voluntary. If you choose not to provide the information, we cannot send you newsletters.

4. Check-in

When you register and check-in electronically on arrival to one of our locations, RelyOn Nutec processes the following personal information (in addition to the information stated in the other sections if applicable):

Types of information and purpose

We collect and process the following types of personal information about you:

• Identification information: Name, company name and occupation, if relevant, and e-mail address, and

We collect and process the information for the following purposes:

• For administration purposes in order to ensure a due registration of visitors to our training centers and offices.
• To comply with applicable legislation (e.g. the EU General Data Protection Regulation (the GDPR), marketing legislation, e-privacy legislation), including documentation requirements:
  • Compliance with basic principles for processing of personal data and legal basis for processing,
  • Implementation and maintenance of technical and organisational security measures,
  • Investigation of suspected or known security breaches and reporting to individuals and authorities,
  • Processing of requests and complaints from data subjects and others, and
  • Handling of inspections and requests from supervisory authorities.
• Management of disputes with data subjects and third parties.

Sources

The personal information is collected from you when you check-in.

Legal basis for collection and processing of personal data

The legal basis for collection and processing of personal data is:

The legitimate interests we pursue in ensuring appropriate administration of visitors to our facilities, see article 6(1)(f) of the GDPR.

The legitimate interests in pursuing legal claims is RelyOn Nutec’s legitimate interests in safeguarding its legal position, see article 6(1)(f) of the GDPR.

The personal data may be processed for documentation of compliance with legislation, see article 6(1)(c) of the GDPR.

Voluntary basis

When we collect personal data directly from you for the purpose of you entering our facilities, providing us with the information is voluntary. If you choose not to provide the information, you cannot enter our facilities.

5. Common to all sections

Transfer of Personal Information to Data Processors

We transfer your personal data to certain suppliers, e.g. IT suppliers and other third party contractors working on our behalf, who process the information on behalf of RelyOn Nutec. 

Transfer of personal data to recipients in countries outside EU/EEA

The basis for the international transfer is EU’s “Standard Contractual Clauses” for transfers from data controllers to data processors in countries without an adequate level of protection outside EU/EEA. The standard agreement is available in different languages via this link.

Storage period

We keep your personal data for as long as necessary to meet the above-mentioned purposes and any subsequent, lawful purposes. Furthermore, we keep your personal data for as long as necessary for our documentation of compliance with applicable legislation based on the rules on time limitation. We also keep the information for as long as necessary for defending against or pursuing civil law claims, including on the basis of the rules on time limitation. If a claim is raised, however, we will keep the information for a longer period in order to handle the claim. For other purposes, including statutory documentation and implementation of security measures, we keep the personal data for as long as necessary based on the statutory rules on time limitation for incurring criminal liability.

Your rights

Subject to the limitations that follow from legislation, your rights include the following: right of access to your personal data, right to rectification of incorrect information, right to erasure of information, right to restriction of processing, right to data portability and right to object to the processing of personal data, including automated individual decision-making.

You also have the right to lodge a complaint with the national Data Protection Agency.

Security and Contact

RelyOn Nutec, as a data controller, has a duty to protect the personal and sensitive data we process about our delegates / data subject.

The information we collect about you and your organisation is stored on an electronic database on a secure server.

If you have any questions or comments with respect to the processing of your personal data or you wish to exercise your rights under applicable legislation, please contact us by emailing data.protection@relyonnutec.com.

RelyOn Nutec Holding A/S
Kalvebod Brygge 45, 3.
1560 Copenhagen V
Denmark
Company registration no. 19 95 13 83

20 April 2020v4