Privacy Policy

This privacy policy applies to KEHR+NIELSEN, a sub-brand owned by cphdialogue aps, CVR 34474745, with registered office address at Højeloft Vænge 79, 3500 Værløse, Denmark.

The controller on personal data is KEHR+NIELSEN. KEHR+NIELSEN is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative, and physical security measures.

You are in general under no obligation to provide KEHR+NIELSEN with any information, however, if you do not provide the required information regarding certain use cases set out in this privacy notice, KEHR+NIELSEN may not be able to offer our services, process your corresponding request or get in contact with you, etc.

The privacy notice below explains what information KEHR+NIELSEN gathers about you, what KEHR+NIELSEN uses it for and who KEHR+NIELSEN shares it with. It also sets out your rights and who you can contact for more information or queries.

KEHR+NIELSEN may also process information you provide to us in connection with an application for a job vacancy, for the assessment of your application and potential negotiation, preparation, conclusion and performance of an employment or service contract with you or management of your profile (Art. 6 para. 1 lit. b GDPR).

“Data Protection Legislation” means the EU General Data Protection Regulation 2016/679 ("GDPR"); together with all other applicable legislation relating to privacy or data protection and including any statute or statutory provision which amends, extends, consolidates, or replaces the same.

“Processing” means any operation performed on information about you, including to collect, disclose, record, organise, structure, store, alter, use, transfer, destroy or otherwise make available.

This privacy notice is updated August 2024.

What data does KEHR+NIELSEN process?

KEHR+NIELSEN may process information about you that: (i) you provide to KEHR+NIELSEN, (ii) that KEHR+NIELSEN obtains from third parties or (iii) that is publicly available. This information may include your name, age, gender, date of birth and contact details. It may also include ‘sensitive’ or ‘special categories’ of personal data, such as dietary requirements or mobility information.

How will KEHR+NIELSEN use your data?

KEHR+NIELSEN collects and process information about you and/or your business to enable KEHR+NIELSEN to:

provide KEHR+NIELSEN’s services to you or KEHR+NIELSEN’s clients;
to enable us to provide you with information that KEHR+NIELSEN thinks may be of interest to you; and
to meet KEHR+NIELSEN’s legal or regulatory obligations.

When KEHR+NIELSEN sends you information KEHR+NIELSEN thinks you might be interested in, you have the right to unsubscribe at any time by contacting KEHR+NIELSEN or by following the unsubscribe instructions in our communications.

KEHR+NIELSEN may share information about you with third parties. KEHR+NIELSEN may transfer some information about you to countries outside the European Union that have less stringent data protection laws. When KEHR+NIELSEN do this, KEHR+NIELSEN will make sure your information remains adequately protected.

What are your rights?

Your rights under Data Protection Legislation include the right to:

request copies of your data;
request correction of your data;
request erasure of your data;
object to KEHR+NIELSEN processing your data; and
ask KEHR+NIELSEN to restrict the processing.

If you have any questions or comments about privacy issues, or wish to exercise any of the rights set out above, please write to KEHR+NIELSEN’s Data Protection Officer, cphdialogue aps, Højeloft Vænge 79, 3500 Værløse, Denmark or email flemming@kehrognielsen.dk

Who does this privacy policy apply to and what does it cover?

This privacy policy applies to KEHR+NIELSEN. KEHR+NIELSEN is committed to protecting your privacy and handling your information openly and transparently. This privacy policy explains how KEHR+NIELSEN will collect, handle, store and protect information about you when:

providing services to you or KEHR+NIELSEN’s clients;
you use KEHR+NIELSEN’s website; or
performing any other activities that form part of the operation of KEHR+NIELSEN’s business.

This privacy policy also contains information about when KEHR+NIELSEN shares your personal data with other third parties – for example, our service providers.

In this privacy policy, your information is sometimes called “personal data”. KEHR+NIELSEN may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.

What personal data does KEHR+NIELSEN collect?

KEHR+NIELSEN may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this notice.

When KEHR+NIELSEN provides services to you or KEHR+NIELSEN’s clients and perform due diligence checks in connection with KEHR+NIELSEN’s services, or discuss possible services KEHR+NIELSEN might provide, KEHR+NIELSEN will process personal data about you. KEHR+NIELSEN may also collect personal data from you when you use this website.

KEHR+NIELSEN may process your data because:

you give it to KEHR+NIELSEN – for example, in a form on our website;
other people give it to KEHR+NIELSEN – for example, your employer or adviser, or third-party service providers that KEHR+NIELSEN uses to help operate KEHR+NIELSEN’s business; or
it is publicly available.

KEHR+NIELSEN may also collect personal information if you register for the website using a third-party social network account, e.g., LinkedIn, Facebook, and Twitter.

The information KEHR+NIELSEN collects may depend on the privacy settings you have with the social network site, so please review the privacy notice or policy of the applicable social network site. When you access the website through your social network account, you are authorising cphdialogue to collect and use your information in accordance with this privacy notice.

KEHR+NIELSEN may process personal data from you because KEHR+NIELSEN observe or infer that data about you from the way you interact with KEHR+NIELSEN or others. For example, to improve your experience of this website and to make sure that it is working effectively. For example, KEHR+NIELSEN, or KEHR+NIELSEN’s service providers, may use cookies on the KEHR+NIELSEN website to ensure a user-friendly website visitor experience, e.g. session cookies, based on KEHR+NIELSEN’s legitimate interest (Art. 6 para. 1 lit. f GDPR). Enhanced web analysis using cookies is, within the scope of applicability of the GDPR, based on your consent (Art. 6 para. 1 lit. a GDPR).

The personal data KEHR+NIELSEN processes may include your:

name, gender, age and date of birth;
contact information, such as address, email, and mobile phone number;
country of residence;
employment and education details, for example, the organisation you work for, your job title and your education details;
postings or messages on any blogs, forums, platforms, wikis or social media applications and services that KEHR+NIELSEN provides, including with third parties;
IP address, browser type and language, your access times;
information in any complaints you make;
details of how you use KEHR+NIELSEN’s products and services;
details of how you like to interact with KEHR+NIELSEN, and other similar information relevant to our relationship.

If you choose not to provide, or object to KEHR+NIELSEN processing, the information KEHR+NIELSEN collects, KEHR+NIELSEN may not be able to process your instructions or continue to provide some or all of KEHR+NIELSEN’s services to you or KEHR+NIELSEN’s client.

Personal data provided by or about third parties

If you share with KEHR+NIELSEN information regarding any other individual, e.g. your employees, colleagues, ultimate beneficial owners, relatives, etc., you warrant, and shall procure that any member of your group/affiliates warrants, that the personal data to be transferred has been collected and processed in accordance with the requirements of the Data Protection Legislation and that the further processing and transfer of personal data by KEHR+NIELSEN as set forth in this privacy notice is admissible by the Data Protection Legislation. Particularly you warrant that prior to any transfer of this personal data you have provided any necessary notice and collected any necessary permission from affected individuals, verified technical and organisational measures and do all such other things as are required under the Data Protection Legislation in order to disclose personal data to KEHR+NIELSEN, and let KEHR+NIELSEN process and transfer this personal data outside the European Union for the services.

How KEHR+NIELSEN uses your personal data

KEHR+NIELSEN processes information about you and/or your business to enable KEHR+NIELSEN to provide KEHR+NIELSEN’s services to you or KEHR+NIELSEN’s clients, and to meet KEHR+NIELSEN’s legal or regulatory obligations.

Some of your personal data may be used for other business purposes. Below are some examples.

How KEHR+NIELSEN uses personal data to provide services to KEHR+NIELSEN’s clients:

KEHR+NIELSEN will use your personal data to provide you or KEHR+NIELSEN’s clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:

you;
other third parties
cphdialogue’s service providers; or
competent authorities.

How KEHR+NIELSEN uses personal data for other activities that form part of the operation of KEHR+NIELSEN’s business:

KEHR+NIELSEN may also use your personal data in connection with:

legal or regulatory requirements;
requests and communications from competent authorities;
client account opening and other administrative tasks;
relationship management, which may involve:
- (a) sending you details of KEHR+NIELSEN’s products and services;
- (b) contacting you for feedback on services;
- (c) sending you event invitations; and
- (d) other marketing or research purposes;
recruitment and business development, which may involve:
- (a) the use of testimonials from a client’s employees as part of KEHR+NIELSEN’s recruitment and business development materials (with that employee’s permission); and
- (b) the use of third-party data sources to help KEHR+NIELSEN verify and improve the information KEHR+NIELSEN holds about key business relationships with individuals;
protecting KEHR+NIELSEN’s rights and those of KEHR+NIELSEN’s clients.

How KEHR+NIELSEN uses personal data collected via KEHR+NIELSEN’s website:

In addition to the above, KEHR+NIELSEN may also use your personal data collected via KEHR+NIELSEN’s website:

to manage and improve KEHR+NIELSEN’s website;
to tailor the content of KEHR+NIELSEN’s website to give you a more personalised experience;
to draw your attention to information about KEHR+NIELSEN’s products and services that may be of interest to you; or
to manage and respond to any request you submit through KEHR+NIELSEN’s website.

The processing regarding website use is based on KEHR+NIELSEN’s legitimate interest to operate and secure KEHR+NIELSEN’s website and KEHR+NIELSEN’s services, in particular for security reasons to ensure the stability and integrity of KEHR+NIELSEN’s systems (Art. 6 para. 1 lit. f GDPR). In addition, KEHR+NIELSEN may perform basic web analysis based on KEHR+NIELSEN’s legitimate interest (Art. 6 para. 1 lit. f GDPR) to optimize the website regarding usability and to gain insights about the use of KEHR+NIELSEN’s website and services. The collected data will not be merged with other personal data or disclosed to third parties. Enhanced web analysis using cookies is, within the scope of applicability of the GDPR, based on your consent (Art. 6 para. 1 lit. a GDPR).

Legal grounds for processing personal data

KEHR+NIELSEN is required by law to set out in this privacy notice the legal grounds on which we rely in order to process your personal data. KEHR+NIELSEN rely on one or more of the following lawful grounds:

you have explicitly agreed to KEHR+NIELSEN processing your information for a specific reason;
the processing is necessary to perform the agreement KEHR+NIELSEN has with you or to take steps to enter into an agreement with you;
the processing is necessary for compliance with a legal obligation KEHR+NIELSEN has such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
the processing is necessary for the purposes of a legitimate interest pursued by KEHR+NIELSEN or a third party, which might be:
(a) to provide KEHR+NIELSEN’s services to you or KEHR+NIELSEN’s clients and other third parties and ensure that KEHR+NIELSEN’s client engagements are well-managed;
(b) to prevent fraud;
(c) to protect KEHR+NIELSEN’s business interests;
(d) to ensure that complaints are investigated;
(e) to evaluate, develop or improve KEHR+NIELSEN’s services or products; or
(f) to keep you or KEHR+NIELSEN’s clients informed about relevant products and services and provide you with information unless you have indicated at any time that you do not wish KEHR+NIELSEN to do so.

To the extent that KEHR+NIELSEN processes any special categories of data relating to you for any of the purposes outlined above, KEHR+NIELSEN will do so because:

you have given KEHR+NIELSEN your explicit consent to process that data;
KEHR+NIELSEN is required by law to process that data in order to ensure KEHR+NIELSEN meet our ‘know your client’ and ‘anti-money laundering’ obligations , or other legal obligations imposed on KEHR+NIELSEN;
the processing is necessary to carry out KEHR+NIELSEN’s obligations under employment, social security or social protection law;
the processing is necessary for the establishment, exercise or defence of legal claims; or
you have made the data manifestly public.

Please note that in certain circumstances it may be still lawful for KEHR+NIELSEN to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

Sharing your personal data

In connection with any of the purposes outlined in the “How KEHR+NIELSEN uses your personal data” section above, KEHR+NIELSEN may disclose details about you to:

competent authorities if KEHR+NIELSEN is legally obliged or entitled to such disclosure or if it appears necessary to protect KEHR+NIELSEN’s interests;
anyone to whom KEHR+NIELSEN may transfer our rights and/or obligations under the Terms of Use;
credit reference agencies or other organisations that help KEHR+NIELSEN make credit decisions and reduce the incidence of fraud;
service providers, e.g. IT service providers, business information providers, newsletter service providers, marketing and event management service providers, etc.;
legal and professional advisors, including accountants and auditors;
other third parties that reasonably require access to personal data relating to you.

KEHR+NIELSEN’s website may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected, and used by other users of the application. KEHR+NIELSEN has little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy notice.

Transferring your personal data

Information KEHR+NIELSEN holds about you may be transferred outside Denmark, to the countries that offer adequate data protection pursuant to the Data Protection Legislation, e.g. to the EU, and under certain circumstances, KEHR+NIELSEN may also transfer data to the countries which do not offer adequate data protection if necessary for the respective processing purpose, e.g.:

where KEHR+NIELSEN do business;
which are linked to your engagement with KEHR+NIELSEN;
from where you regularly receive or transmit information; or
where KEHR+NIELSEN’s subprocessors or third parties conduct their activities.

These countries may have less stringent privacy laws than KEHR+NIELSEN does, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, and other purposes.

When KEHR+NIELSEN, or KEHR+NIELSEN’s permitted third parties, transfer your personal data, KEHR+NIELSEN will assure the transfer is secured by appropriate safeguards such as the EU Standard Contractual Clauses, or based on a statutory exemption, e.g. if you have given your consent to the transfer, and KEHR+NIELSEN will impose contractual obligations on the recipients of that data to protect your personal data to the standard required by the Data Protection Legislation.

If KEHR+NIELSEN transfers your personal data outside Denmark and the EU in other circumstances, for example, because KEHR+NIELSEN has to by law, KEHR+NIELSEN will make sure it remains adequately protected.

KEHR+NIELSEN may share non-personal, anonymised and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.

How KEHR+NIELSEN protects your personal data

KEHR+NIELSEN uses a range of measures to ensure KEHR+NIELSEN keeps your personal data secure, accurate and up to date. These include:

education and training to relevant employees to ensure they are aware of our privacy obligations when handling personal data;
administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
technological security measures, including fire walls, encryption and anti-virus software; and
physical security measures to access our premises.

The transmission of data over the internet (including by email) is never completely secure. So although KEHR+NIELSEN uses appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.

For how long will KEHR+NIELSEN keep your personal data?

KEHR+NIELSEN seeks to ensure that KEHR+NIELSEN only keeps your personal data for the longest of:

the period necessary for the relevant activity or services;
any retention period that is required by law; or
the period in which litigation or investigations might arise in respect of the services.

What are your rights?

You have various rights in relation to your personal data. In particular, you have a right to:

obtain confirmation that KEHR+NIELSEN are processing your personal data and request a copy of the personal data KEHR+NIELSEN holds about you;
be informed about the processing of your personal data, i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third-party sources from where it was obtained, confirmation of whether KEHR+NIELSEN undertakes automated decision-making, including profiling, and the logic, significance and envisaged consequences;
ask that KEHR+NIELSEN updates the personal data KEHR+NIELSEN holds about you, or correct such personal data that you think is incorrect or incomplete;
ask that KEHR+NIELSEN deletes personal data that KEHR+NIELSEN holds about you, or restrict the way in which KEHR+NIELSEN uses such personal data; withdraw consent to KEHR+NIELSEN’s processing of your personal data (to the extent such processing is based on previously obtained consent);
receive a copy of the personal data concerning you, which you have provided to KEHR+NIELSEN, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
ask KEHR+NIELSEN to stop or start sending you marketing messages at any time by using the contact details in the section “Contact” below; and
object to our processing of your personal data.

If you would like to access or see a copy of your personal data, you must ask KEHR+NIELSEN in writing. KEHR+NIELSEN will endeavour to respond within a reasonable period, and in any event within one month in line with the Data Protection Legislation. KEHR+NIELSEN will comply with KEHR+NIELSEN’s legal obligations as regards your rights as a data subject.

To help KEHR+NIELSEN ensure that your information is up to date, let us know if any of your personal details change using the contact details set out in the section “Contact” below.

You may also use the contact details in the section “Contact” below if you wish to make a complaint relating to your privacy.

Marketing

KEHR+NIELSEN may process marketing data for marketing purposes and relationship management, for example to send personalized advertising for KEHR+NIELSEN’s services and products, e.g. in the form of newsletters or other regular contacts either in person, via email or other electronic form, by phone or any other communication channel for which KEHR+NIELSEN have contact information from you and by any other marketing means, e.g. through events, fairs, etc. KEHR+NIELSEN does so based on KEHR+NIELSEN’s legitimate interest to keep you informed about KEHR+NIELSEN’s products and services (Art. 6 para. 1 lit. f GDPR), to the extent permitted by applicable marketing regulations, or, where required, based upon your consent in this regard (Art. 6 para. 1 lit. a GDPR).

You may, at any time, ask KEHR+NIELSEN not to send marketing information to you by following the unsubscribe instructions in communications from KEHR+NIELSEN, or contacting KEHR+NIELSEN in the way described in the “Contact” section below.

Contact

If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about privacy issues, or you wish to raise a complaint about how KEHR+NIELSEN is using your information, you can contact KEHR+NIELSEN in the following ways:

write to KEHR+NIELSEN’s Data Protection Officer, cphdialogue aps, Højeloft Vænge 79, 3500 Værløse, Denmark, or
send an email to flemming@kehrognielsen.dk

If you believe that KEHR+NIELSEN’s processing of your data contradicts the applicable data protection laws, you have the possibility to lodge a complaint with the appropriate data protection authority. The data protection authority in Denmark is Datatilsynet, Carl Jacobsens Vej 35, 2500 Valby, Denmark, www.datatilsynet.dk.

Changes to this privacy policy notice

This privacy policy notice does not form part of any contract with you and KEHR+NIELSEN may amend it at any time. The version published on KEHR+NIELSEN’s website is the version that currently applies. KEHR+NIELSEN encourages you to review this privacy policy notice periodically to remain informed about how KEHR+NIELSEN is protecting your information.