§ 1 General

1.1: This Privacy Policy regarding the processing of personal data (“Privacy Policy”) describes how Subscribed ApS (“Elome”, “we”, “us”, “our”) collects and processes information about you.

Elome ApS (hereinafter referred to as “Elome”) is part of Subscribed ApS, CVR no.: 37496804.

Elome ApS
Hammerholmen 11K
2650 Hvidovre
Denmark

Email: [email protected]
Website: elome.com

1.2: This Privacy Policy applies to personal data that you provide to us or that we collect via Elome’s website, elome.com (the “Website”).

1.3: Elome is the data controller of your personal data. All inquiries to Elome may be made via the contact details set out in § 7.

§ 2 Personal Data We Collect, Purpose, and Legal Basis

2.1: Visits to the Website
When you visit the Website, we automatically collect information about you and your use of the Website, for example the type of browser you use, the search terms you use on the Website, your IP address, including your network location, and information about your device.

2.1.1: The purpose is to optimize the user experience and the functionality of the Website, as well as to carry out targeted marketing, including retargeting via Facebook and Google. This processing of information is necessary in order for us to pursue our legitimate interests in improving the Website and presenting you with relevant offers.

2.1.2: The legal basis for the processing is Article 6(1)(f) of the EU General Data Protection Regulation.

2.2: Purchases and Communication
When you purchase a product or communicate with us via the Website, we collect the information you provide, such as your name, address, email address, telephone number, payment method, information about which products you purchase and may have returned, delivery preferences, and information about the IP address from which the order was placed.

2.2.1: The purpose is to enable us to deliver the products you have ordered and otherwise fulfill our agreement with you, including administering your rights to return and make complaints. We may also process information about your purchases in order to comply with legal requirements, including bookkeeping and accounting obligations. In connection with purchases, the IP address is collected for the purpose of safeguarding our interest in preventing fraud.

2.2.2: The legal basis for the processing is Article 6(1)(b), (c), and (f) of the EU General Data Protection Regulation.

2.3: Newsletter
When you subscribe to our newsletter, we collect your name, email address, and, where applicable, your mobile number.

2.3.1: The purpose is to pursue our legitimate interest in being able to provide you with newsletters.

2.3.2: The legal basis for the processing is Article 6(1)(f) of the EU General Data Protection Regulation.

2.4: Subscription and Customer Account
When you subscribe to our subscription service, you will be asked to provide information such as your name, address, date of birth, email address, telephone number, your preferences and interests, etc. In addition to your name, address, and email address, you decide which information you wish to provide to us.

In addition, we collect information during your membership regarding your use of subscription benefits, competitions you participate in, etc. We combine this information with other information we have about you, including information about what you have purchased and potentially returned.

2.4.1: The purpose is to manage your membership and provide you with the services and benefits associated with the subscription, as well as to pursue our legitimate interest in sending service emails and marketing communications via newsletters and conducting targeted marketing.

2.4.2: The legal basis for the processing is Article 6(1)(b) and (f) of the EU General Data Protection Regulation. Upon registration, you will be asked to provide separate consent for electronic marketing.

2.5 Cookies:
We use cookies and similar technologies. Detailed information about the use of cookies, their purpose, and your choices can be found in our separate cookie policy on the Website.

Cookie policy

§ 3 Recipients of personal data

We may disclose or transfer personal data to external partners who process such data on our behalf and in accordance with our instructions. These partners act as data processors or, in certain cases, as independent data controllers, depending on the purpose of the processing. Disclosure shall only take place to the extent necessary to fulfill our obligations towards you or in accordance with applicable law.

Personal data may be disclosed to the following specifically defined categories of recipients:

3.1 Distributors and Carriers
Information regarding your name, delivery address, email address, telephone number, order number, and any specific delivery instructions may be disclosed to distributors and carriers responsible for handling, distribution, and delivery of the goods you have ordered.

The disclosure of such information is necessary in order to perform the contract with you and to complete delivery of your goods, cf. Article 6(1)(b) of the GDPR. Distributors and carriers process personal data either as data processors on our behalf or as independent data controllers in connection with their delivery services. Where they act as independent data controllers, processing is carried out in accordance with their own privacy policies.

3.2 Providers of Technical Infrastructure
We use providers of technical infrastructure for the operation, hosting, maintenance, security, and monitoring of our website and associated systems. These providers supply the technical platform that enables us to deliver our services in a stable and secure manner. These providers process personal data as data processors and solely in accordance with our instructions.

It is important to emphasize that your personal data is not shared with these providers for their independent use. These technical infrastructure providers act exclusively as our data processors, subject to our instructions and contractual agreements. Some of these providers may be located outside the EU/EEA, which entails a transfer of your personal data to third countries. For further information on such transfers, please refer to §4 on transfers to third countries.

3.3 Providers of Customer Service Infrastructure
In order to provide customer service and support, we use systems for managing customer communications, including email, chat, telephone, and automated support solutions. In this context, personal data such as your name, contact details, and the content of your inquiry may be processed.

3.4 Providers of Payment Services
In connection with purchases and payments, personal data may be disclosed to payment service providers for the purpose of completing transactions, administering payments, and preventing fraud. The data processed typically includes contact details and transaction-related information. This processing is necessary for the performance of a contract with you, cf. Article 6(1)(b) of the GDPR.

3.5 Providers of Marketing and Communication Services
We may use external providers to distribute marketing communications, including emails, messages, and other forms of direct communication. In this context, contact details and information regarding your preferences may be processed. Processing for marketing purposes will only take place on the basis of your consent and provided that you have not objected to such processing.

Some of these partners may be located outside the EU/EEA, which entails a transfer of your personal data to third countries. For further information on such transfers, please refer to §4 on transfers to third countries.

3.6 Providers of Advertising and Analytics Services
We use analytics and advertising tools to measure the use of our website and to target our marketing, including platforms such as Meta (Facebook and Instagram), Google (Google Ads, Google Analytics, YouTube), TikTok, Snapchat, and similar services. This may involve the use of cookies and similar technologies as well as the sharing of pseudonymized or encrypted identifiers.

Processing only takes place where you have given your consent, where such consent is required. Several of these providers act as independent data controllers with respect to their own processing of personal data.

The manner in which your data is collected by advertising partners also determines their role in the processing of your data. However, most of our advertising partners act as independent data controllers. Some of these advertising partners are located outside the EU/EEA, which entails a transfer of your personal data to third countries. For further information on such transfers, please refer to §4 on transfers to third countries.

3.7 Public Authorities
We may disclose personal data to public authorities where required by law or where necessary to establish, exercise, or defend legal claims. In such cases, processing is carried out on the basis of Article 6(1)(c) or (f) of the GDPR.

§ 4 Transfers to Third Countries

Certain of the partners and service providers who process personal data on our behalf are established outside the EU/EEA. In such cases, personal data may be transferred to third countries. Transfers of personal data to third countries may in particular take place to the United States, including where certain of our partners and service providers are established.

Transfers of personal data to third countries shall only take place where such transfers are permitted under applicable data protection legislation and provided that an adequate level of protection for the data subjects’ personal data is ensured. This entails that we apply a valid transfer mechanism in accordance with the EU General Data Protection Regulation.

As a general rule, transfers to third countries are based on the European Commission’s Standard Contractual Clauses, cf. Article 46 of the GDPR, and, where required, supplementary technical and organizational measures are implemented to safeguard the personal data. To the extent that the European Commission has adopted a valid adequacy decision for a third country, transfers may be carried out on this basis.

Transfers to third countries may occur in connection with the use of:
- technical operations and hosting solutions
- customer service and communication systems, including chat and support functions
- analytics, monitoring, and security tools
- marketing and advertising platforms

In connection with the use of automated chat and support solutions, information that you provide during your interaction may be processed by external service providers. These providers act solely as data processors in accordance with our instructions, do not use the information for their own purposes, and process the information only for the purpose of responding to your inquiry. The information is not retained longer than necessary and is subject to appropriate technical and organizational security measures, including encryption.

§ 5 Your rights

5.1: In order to ensure transparency regarding the processing of your personal data, we, as the data controller, are obliged to inform you of your rights.

5.2: Right of Access

5.2.1: You are at any time entitled to request information from us regarding, among other things, what personal data we have registered about you, the purposes of the processing, the categories of personal data and recipients of such data, as well as information about the origin of the data.

5.2.2: You have the right to obtain a copy of the personal data we process about you. If you wish to receive a copy of your personal data, you must submit a written request to [email protected]. You may be required to provide documentation verifying your identity.

5.3: Right to Rectification

5.3.1: You have the right to have inaccurate personal data concerning you rectified by us. If you become aware that the information we have registered about you is incorrect, you are encouraged to contact us in writing so that the information can be corrected.

5.3.2: Information collected in connection with your subscription may be corrected by you via login to your user profile.

5.4: Right to Erasure

5.4.1: In certain circumstances, you have the right to have all or certain of your personal data erased by us, for example if you withdraw your consent and we do not have another legal basis for continuing the processing. To the extent that continued processing of your data is necessary, for example in order to comply with our legal obligations or to establish, exercise, or defend legal claims, we are not obliged to delete your personal data.

5.5: Right to Restriction of Processing

5.5.1: In certain circumstances, you have the right to request that the processing of your personal data be restricted to storage only, for example if you believe that the data we process about you is inaccurate.

5.6: Right to Data Portability

5.6.1: In certain circumstances, you have the right to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit such data to another data controller.

5.7: Right to Object

5.7.1: You have the right at any time to object to our processing of your personal data for the purposes of direct marketing, including profiling carried out in order to target such marketing.

5.7.2: You also have the right, at any time and on grounds relating to your particular situation, to object to the processing of your personal data where such processing is based on our legitimate interests, cf. Sections 2.1 and 2.3.

5.8: Right to Withdraw Consent

5.8.1: You have the right at any time to withdraw any consent you have given us for the processing of your personal data, including profiling in connection with your subscription. If you wish to withdraw your consent, please contact us at [email protected].

5.8.2: You may at any time withdraw your consent to cookies that are not necessary for the functionality of the website. See relevant cookie settings.

5.8.3: You may at any time withdraw your consent to receive newsletter emails by using the unsubscribe link at the bottom of such emails or by contacting us at [email protected].

5.8.4: It is not possible to withdraw consent in relation to necessary service emails associated with your subscription with Elome. We use service emails to notify you of changes to your membership or to inform you about the status of your account.

5.9: Right to Lodge a Complaint

5.9.1: You have the right at any time to lodge a complaint with the Danish Data Protection Agency (Datatilsynet), Borgergade 28, 5, 1300 Copenhagen K, regarding our processing of your personal data. Complaints may, among other methods, be submitted via email at [email protected] or by telephone at +45 33 19 32 00.

§ 6 Deletion of Personal Data

6.1: Information collected regarding your use of the Website, cf. section 2.1, will be deleted no later than when you have not used the Website for a period of one (1) year.

6.2: Information collected in connection with your subscription to our newsletter will be deleted when your consent to receive the newsletter is withdrawn, unless we have another legal basis for processing such information.

6.3: Information collected in connection with purchases you have made on the Website, cf. section 2.2, will, as a general rule, be deleted five (5) years after the end of the calendar year in which you made your purchase. However, such information may be retained for a longer period if we have a legitimate need for extended retention, for example where it is necessary to establish, exercise, or defend legal claims, or where retention is required in order to comply with legal obligations. Accounting records are retained for five (5) years until the end of a financial year in order to comply with the requirements of applicable bookkeeping legislation.

6.4: Information collected in connection with your registration for and during your membership of our subscription, cf. section 2.4, will be automatically deleted: a) if you have not logged into your user profile for a period of five (5) years; b) if you terminate (or suspend) your subscription and do not reactivate it within the following five (5) years; or c) if you unsubscribe from your subscription.

§ 7 Safety

7.1: We have implemented appropriate technical and organizational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, or degradation, as well as against unauthorized disclosure or misuse.

7.2: Only employees who have a legitimate need to access your personal data in order to perform their duties are granted access to such data.

§ 8 Contact information

8.1: Elome ApS is the data controller for the personal data collected via the Website.

8.2: If you have any questions or comments regarding this Privacy Policy, or if you wish to exercise one or more of your rights as described in §5, you may contact:

Elome ApS
ATT: Data Protection Office
Elome ApS
Hammerholmen 11K
2650 Hvidovre

Email: [email protected]

§ 9. Changes to the Privacy Policy

Ongoing developments in digital solutions, technology, and legislation may necessitate changes to our processing of personal data. We therefore reserve the right to update and amend this Privacy Policy.

The version of the Privacy Policy applicable at any given time will always be available on our platforms. In the event of material changes to the Privacy Policy, we will provide notice of such changes through a visible announcement on our platforms.

§ 10 Versions