February 19, 2021
Pensure develops user-oriented solutions in the field of pensions, with the aim of giving people a better overview of their pension situation. If you have any questions or feedback about this privacy policy or Pensure's processing of personal data in the course of operating our business, please contact us here:
Pensure ApS
CVR nr.: 38 91 82 73
Applebys Pl. 7
1411 København K
In connection with your use of the Pensure Services, Pensure collects and processes personal data for the purposes, including its own purposes, described in this Privacy Policy. Pensure is the data controller in relation to the processing of the personal data for these purposes.
In connection with the operation of Pensure's business, Pensure collects and processes personal data for the purposes described in this Privacy Policy. Pensure is the data controller in relation to the processing of the personal data for these purposes.
Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number or to one or more elements unique to the identity of a particular person.
The information we collect about you will be used to highlight what individuals with similar pension circumstances could achieve in savings potential by optimising their pension circumstances. The information collected will generally be information that we collect on your behalf and with your consent, or that you upload yourself in connection with your use of our services, information that is used to provide better services to our users, and information relating to Pensure's rights and obligations. Failure by you to provide personal information may mean that we will be unable to provide our services.
Pensure collects and processes general personal data and sensitive data about you. Pensure will typically collect the following information (the list is not exhaustive): Contact and identification information: information that you provide to us when you use our
services, including contact information (name, phone number and email address).
Information about your finances: in order for us to provide our service, you have consented to Pensure processing personal data about you from.
Other information for the administration of your user relationship, including marketing: information that you give us about your preferences in relation to marketing and communications, information you provide when using our pages on social media, and information you give us if you contact us with a question or when you otherwise contact us as part of your customer relationship with Pensure.
Information we collect and process when you visit our website: Information about the way you navigate within and between our websites and the resources you access, information about your computer, device and browser, including in some cases your IP address, browser type and other hardware and software information. If you access our website from a mobile device, we may also collect a unique identification number assigned to your device.
The information we collect about you will be used for various purposes in connection with the operation of Pensure's business. The information collected may vary depending on whether you are a supplier or a business partner, but generally it will be information relating to supplier administration and information relating to Pensure's rights and obligations. Failure by you to provide personal data may mean that Pensure will be unable to fulfil its obligations in relation to your supplier relationship. Pensure collects and processes only ordinary personal data.
Pensure will typically record the following information (the list is not exhaustive): contact and identification information:
Information that you provide to us, in connection with the conclusion of a supply or cooperation agreement, including contact information (work, job title, first name, middle name(s), last name, address, telephone number and e-mail address).
Other information for the administration of your supplier relationship, including marketing: information that you give us about your preferences in relation to marketing and communications, information that you give when using our pages on social media, as well as information that you give us if you contact us with a question or when you otherwise contact us as part of your supplier relationship with Pensure.
Information we collect and process when you visit our website: Information about the way you navigate within and between our websites and the resources you access, information about your computer, device and browser, including in some cases your IP address, browser type and other hardware and software information. If you access our website from a mobile device, we may also collect a unique identification number assigned to your device.
Pensure does not use your personal data to make decisions based solely on automated processing. Pensure strives to ensure that all personal data we process is accurate and up to date. If your information is incorrect or you wish to have your data deleted, you can write to us at any time at: kontakt@pensure.dk
Pensure processes your personal data for the purposes, including its own purposes, set out below. Please note that not all of the purposes, categories of data, recipients of data or types of data processing listed apply to you in all cases.
Provision of our services: as part of our provision of information about a potential savings opportunity, as well as general customer service. The delivery of our services is carried out in partnership with professional pensions advisers.
Statistics and analysis: all statistics and analysis used to ensure and improve the quality of Pensure's services are produced in an anonymised format and therefore do not contain information directly attributable to you as an individual.
Operation and maintenance of our websites: the provision of our online services on our websites, including to support the ongoing evaluation and improvement of our websites.
Compliance with applicable laws and regulations: Compliance with laws and regulations to which Pensure is subject in connection with the operation of the business or to comply with various reporting or disclosure obligations under applicable laws and regulations to which Pensure is subject.
Pensure processes your personal data for the purposes set out below. Please note that not all of the purposes, categories of data, recipients of data or types of data processing listed apply to you in all cases.
Administration of supplier and collaborative relationships: administration of supplier and/or collaborative relationships where you are
supplier or collaborative partner or are a contact person of a supplier or collaborative partner with whom Pensure works in the course of operating our business, including maintaining our CRM register with information about our contacts at our suppliers and collaborative partners.
Statistics and analysis: all statistics and analysis used to ensure and improve the quality of Pensure's services are produced in an anonymised format and therefore do not contain information that can be directly attributed to you as an individual.
Operation and maintenance of our websites: the provision of our online services on our websites, including to support the ongoing evaluation and improvement of our websites.
Compliance with applicable laws and regulations: Compliance with laws and regulations to which Pensure is subject in connection with the operation of the business or to comply with various reporting or disclosure obligations under applicable laws and regulations to which Pensure is subject.
Pensure only processes your personal data when we have a legal basis to do so. Where the circumstances so require, Pensure may process both general data, sensitive data and other special categories of data about you. Please note that not all of the legal bases listed apply to you in all cases. Processing of general data about you will generally be carried out on one of the following bases:
Consent: you have given your consent to the processing of your personal data for one or more specific purposes. Processing on the basis of consent is based on Article 6(1)(a) of the GDPR.
Contract: Conclusion or performance of your contract with Pensure. Processing on the basis of contract is based on Article 6(1)(b) of the GDPR.
Legal obligation: fulfilment of a legal obligation imposed on Pensure. Processing on the basis of a legal obligation is based on Article 6(1)(c) of the GDPR.
Our legitimate interests: The legitimate interests of Pensure, i.e. the purposes described above, in Part 4. Processing on the basis of our legitimate interests is based on Article 6(1)(f) of the GDPR.
Third party legitimate interests: There may also be situations where we process your personal data for the legitimate interests of third parties in relation to the purposes described above, unless the interests of you outweigh those interests. Processing on the basis of legitimate interests of third parties is based on Article 6(1)(f) of the GDPR.
Processing of sensitive data about you will normally be carried out on one of the following bases:
Consent: You have given your consent to the processing of your personal data for one or more specific purposes. Processing on the basis of consent is based on Article 9(2)(a) of the GDPR.
Publicly available data: Processing relates to personal data which have been manifestly made public by you. Processing on this basis is based on Article 9(2)(e) of the GDPR.
Legal claims: Processing is necessary for the establishment, exercise or defence of legal claims (Article 9(2)(f) of the GDPR).
Vital interests: processing is necessary to protect your vital interests or the vital interests of another natural person. Processing on the basis of vital interests is based on Article 9(2)(c) of the GDPR.
The processing of special categories of data relating to you will normally be carried out on one of the following bases
The processing of the CPR number is based on Article 11(2) of the Data Protection Act.
Pensure will disclose information to the extent necessary in connection with our provision of our services, including disclosing information to our business partners, where you have consented, for the purposes of providing advice.
Pensure may disclose and/or entrust your personal data to suppliers and/or service providers in the ordinary course of our business, for example in connection with external administration of our IT systems, analytical tasks, marketing tasks, auditing, legal assistance, etc.
Pensure strives to limit the disclosure of personal data in a personally identifiable format to the greatest extent possible, thereby limiting the instances in which personally identifiable information is disclosed.
Pensure does not transfer your personal data to countries outside the EU/EEA.
It is Pensure's policy to protect personal data by taking adequate technical and organisational security measures.
Personal data will not be retained longer than necessary to fulfil the purpose for which it was collected, unless retention is necessary to comply with national legal requirements, including mandatory retention periods. When your personal data is no longer needed, we will ensure that it is deleted in a secure manner.
This means that Pensure will generally keep your personal data for 12 months. When your user or supplier relationship or collaboration ends, your personal data will generally be deleted after the end, unless we are obliged to keep the data for a specific period of time. Pensure may in certain cases keep the data for a longer period if we have a legitimate interest in doing so, for example if legal proceedings are pending, or similar.
Under the GDPR, you have a number of rights that you can exercise against Pensure. Please note that we will not always be obliged to comply with these rights in whole or in part. For example, you do not have the right to have information about you that Pensure holds deleted if Pensure is required by law to hold that information.
Access: you can, among other things, request access to the personal data that we hold, as well as obtain information about, among other things, what personal data is used for and to whom it is disclosed.
Objection: you can object to the processing of the data, including objecting to automated decisions and profiling or to the use of your personal data for direct marketing.
Rectification: you can request rectification of any inaccurate information about yourself.
Restriction and erasure: You can request that information about you be restricted or erased if the conditions for this are met. Data portability: you can exercise your right to data portability for data you have provided to us yourself, provided that the processing is based on consent or contract and is otherwise technically feasible.
In addition, you have the right to withdraw your consent to the processing of your personal data where the processing is based on your consent. If you withdraw your consent or request restriction of our processing of personal data, this may mean that we can no longer provide our services to you.
If you wish to exercise one or more of your rights, please contact info@pensure.dk. Your request will be processed in accordance with the data protection legislation in force at the time. Complaints about Pensure's processing of your personal data may be addressed to:
Datatilsynet
Borgergade 28, 5th floor
1300 København K
Pensure regularly evaluates and updates this privacy policy. You should therefore regularly check this privacy policy for any changes that may affect the processing of your personal data.
