Privacy Policy Whistleblower arrangement

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Privacy policy for GlobalConnect A/S

Privacy policy for GlobalConnect Invest DK A/S

 

Privacy policy for GlobalConnect A/S 

This Privacy Policy explains how GlobalConnect A/S (“GlobalConnect”, “we” or “us”) processes personal information in connection with reports to Global-Connect’s Whistleblower Arrangement.

Below is a description of the personal data processing that takes place and the rights you have if you are reported through the Whistleblower Arrangement, as well as your rights if you use the Whistleblower Arrangement to report another person.

Reference is also made to GlobalConnect’s Whistleblower Policy, containing information about who can submit reports and who can be reported.

This policy only concerns the handling and the investigation of reports submitted through the Whistleblower Arrangement. Therefore, this policy must – in relation to employees – be seen in connection with GlobalConnect’s other relevant policies and procedures.

 

1. Data controller

The legal entity responsible for the processing of your personal information is:

GlobalConnect A/S
CVR.no.: 26759722
Havneholmen 6, st.
2450 København SV
Denmark
E-mail: info@globalconnect.dk

 

2. Desciption of the processing

2.1 Mandatory Whistleblower Arrangement pursuant to the Danish Whistleblower Act

The following is a description of how GlobalConnect will process information on the person who is reported about (the “Reported Person”) as well as the person who is submitting the report (the “Whistleblower”) in connection with reports to GlobalConnect’s Whistleblower Arrangement established pursuant to the Danish Whistleblower Act.

 

3. Information to the reported person and rectification 

If you are subject to a report submitted through the Whistleblower Arrangement, you will be notified as soon as possible after an initial investigation has taken place and all relevant evidence is secured. In this connection, you will receive information about:

  • The identity of the person(s) who is/are responsible for the investigation of the report
  • A description of the contents of the report

As mentioned below in the section about your general rights, you have a right of access to the report that was submitted about you. However, your right to access to the report might be limited in accordance with the Danish Whistleblower Act.

You also have the right to request rectification of the information in the report if you believe this to be false, misleading, or incomplete. If your request in this respect cannot be met, the information will be supplemented with your comments.

 

4. Consequences of the processing 

Reports and investigation of reports to the Whistleblower Arrangement may have significant consequences for the person who is reported, as reports con-cern violations or suspected violations of the law, as further outlined in the separate guidelines for the Arrangement.

Likewise, a report to the Whistleblower Arrangement may have significant consequences for the person who has submitted the report in case of a deliber-ately false report. Such cases may have criminal consequences.

 

5. Transfer to countries outside the EU/EEA 
Your personal data will not be transferred to countries outside the EU/EEA.

 

6. Your general rights 

You have the following rights:

  • You have the right to request access to and rectification or deletion of your personal data.
  • You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
  • You have the right to receive the personal information provided by yourself in a structured, commonly used and machine-readable format (data portability).
  • You may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency.
  • You are furthermore entitled to dispute our processing of your personal data in the following events:
  • If our processing of your personal data is based on the GDPR, Article 6.1 (e) (public interest or exercise of official authority) or Article 6.1 (f) (bal-ancing of interests), see above under legal basis for the processing, you are, at any time, entitled to dispute such processing for reasons related to your particular situation.

There may be conditions or limitations on these rights, e.g., you may not be entitled to deletion of your personal data in a specific case – this depends on the specific circumstances of the processing activities.
You can make use of your rights by contacting GlobalConnect’s HR department (camkri@globalconnect.dk).

 

7. IT policy
For employees of GlobalConnect, reference is made to GlobalConnect’s staff manual/IT Policy containing information on GlobalConnect’s IT and email policy.

 

8. Questions
If you have any questions regarding this policy, please feel free to contact GlobalConnect’s HR department (camkri@globalconnect.dk), Internal Audit (kamwen@globalconnect.dk) or Legal & Regulatory (rassve@globalconnect.dk).

Last updated: 16 December 2021

 

 

Privacy policy for whistleblower arrangement for GlobalConnect Invest DK A/S 

This Privacy Policy explains how GlobalConnect Invest DK A/S (“GlobalConnect Invest”, “we” or “us“) processes personal information in connection with reports to GlobalConnect Invest’s Whistleblower Arrangement.

Below is a description of the personal data processing that takes place and the rights you have if you are reported through the Whistleblower Arrangement, as well as your rights if you use the Whistleblower Arrangement to report another person.

Reference is also made to GlobalConnect Invest’s Whistleblower Policy, containing information about who can submit reports and who can be reported.

This policy only concerns the handling and the investigation of reports submitted through the Whistleblower Arrangement. Therefore, this policy must – in relation to employees – be seen in connection with GlobalConnect Invest’s other relevant policies and procedures.

 

1. Data controller 

The legal entity responsible for the processing of your personal information is:

GlobalConnect Invest DK A/S
CVR.no.: 38374893
c/o GlobalConnect A/S
Havneholmen 6, st.
2450 København SV
Denmark
E-mail: info@globalconnect.dk

 

2. Description of the processing 

2.1 Voluntary Whistleblower Arrangement
The following is a description of how GlobalConnect Invest will process information on the person who is reported about (the “Reported Person”) as well as the person who is submitting the report (the “Whistleblower”) in connection with reports to GlobalConnect Invest’s voluntary Whistleblower Arrangement.

 

3. Information to the reported person and rectification

If you are subject to a report submitted through the Whistleblower Arrangement, you will be notified as soon as possible after an initial investigation has taken place and all relevant evidence is secured. In this connection, you will receive information about:

  • The identity of the person(s) who is/are responsible for the investigation of the report
  • A description of the contents of the report

As mentioned below in the section about your general rights, you have a right of access to the report that was submitted about you.

You also have the right to request rectification of the information in the report if you believe this to be false, misleading, or incomplete. If your request in this respect cannot be met, the information will be supplemented with your comments.

 

4. Consequences of the processing

Reports and investigation of reports to the Whistleblower Arrangement may have significant consequences for the person who is reported, as reports concern violations or suspected violations of the law, as further outlined in the separate guidelines for the Arrangement.

Likewise, a report to the Whistleblower Arrangement may have significant consequences for the person who has submitted the report in case of a deliberately false report. Such cases may have criminal consequences.

 

5. Tranfers to countries outside the EU/EEA 

Your personal data will not be transferred to countries outside the EU/EEA.

 

6. Your general rights 

You have the following rights:

  • You have the right to request access to and rectification or deletion of your personal data.
  • You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
  • You have the right to receive the personal information provided by yourself in a structured, commonly used and machine-readable format (data portability).
  • You may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency-
  • You are furthermore entitled to dispute our processing of your personal data in the following events:
  • If our processing of your personal data is based on the GDPR, Article 6.1 (e) (public interest or exercise of official authority) or Article 6.1 (f) (balancing of interests), see above under legal basis for the processing, you are, at any time, entitled to dispute such processing for reasons related to your particular situation.

There may be conditions or limitations on these rights, e.g., you may not be entitled to deletion of your personal data in a specific case – this depends on the specific circumstances of the processing activities.
You can make use of your rights by contacting GlobalConnect Invest’s HR department (camkri@globalconnect.dk).

 

7. IT policy 
For employees of GlobalConnect Invest, reference is made to GlobalConnect Invest’s staff manual/IT Policy containing information on GlobalConnect In-vest’s IT and email policy.

 

8. Questions
If you have any questions regarding this policy, please feel free to contact GlobalConnect Invest’s HR department camkri@globalconnect.dk), Internal Audit (kamwen@globalconnect.dk) or Legal & Regulatory (rassve@globalconnect.dk).

 

Last updated: 16 December 2021