Privacy Policy

Revision 22.3

From 01/03/2022

We protect your personal data (Privacy Policy)

Bricksite places great emphasis on protecting users' privacy and personal information. This policy describes how we collect and use information, as well as the options and rights that visitors and users have in relation to the information.

Bricksite encourages you to read this Privacy Policy and ensure that you fully understand it before accessing or using Bricksite (our services). If you do not read, understand, and accept this Privacy Policy, you must immediately leave Bricksite (website, CMS, and other services under Bricksite) and avoid using and cease using Bricksite's services.

Bricksite respects your privacy, and this Privacy Policy will describe our commitment to securing your personal information and your rights.

Bricksite provides software-as-a-service to individuals, as well as private and public companies and institutions. Bricksite is headquartered in Randers, Denmark, and is subject to Danish, including European, law.

Use and acceptance

This Policy applies to all Bricksite websites, branded websites, mobile solutions, domains, and services. You may only visit and use Bricksite if you fully accept this Privacy Policy, Bricksite's Terms & Conditions, the Data Processing Agreement, including Annexes, and other Supplements to the Agreement. When accessing or using Bricksite, you confirm and acknowledge your informed consent to this Privacy Policy, including the collection and processing of personal information according to the definition and description below.

Personal information is the information that can identify you as a person. For example, name, email, address, phone number, etc. It is necessary for Bricksite to process your personal information to best serve you. Do not use Bricksite or our services if you cannot accept the way we process your personal information according to this Privacy Policy.

Bricksite's roles

Bricksite has several roles towards the Customer. This Policy contains information about Bricksite's processing of your personal data when Bricksite acts as Data Controller.

In the role of Data Controller, Bricksite uses a number of Data Processors/Service Providers to enable the delivery of Bricksite's main service and serve you. Bricksite processes personal information from contact persons, job seekers, including employees, contact or users affiliated with our customers. We also process personal information about potential customers (leads) who actively contact Bricksite, via Bricksite pages or other channels. Bricksite also processes data on behalf of our customers, where the customer controls the processing.

In the role of Data Processor, Bricksite uses a number of specific approved Sub-Data Processors. The Customer must always be informed about these and pre-approve them. Separate terms apply, regulated in Bricksite's Data Processing Agreement, which you approve when entering into the main Agreement.

Data Controller

Bricksite processes personal information to generally manage our customer relationships and fulfill our customer obligations. We process this personal information for:

Managing support and user forums, which educate and enable interaction between the user and Bricksite.

Processing billing, orders, and payments

Preventing and preventing abuse of our products and services

Carrying out sales and contract processes to customers

Providing customer service to users of Bricksite

Improving and further developing functionality, quality, and user experience of Bricksite services and products

Promoting relevant products and services via interest profiles

Performing maintenance, troubleshooting, and error correction

Recording, limiting, and preventing security threats.

Bricksite has, based on the above purposes, a legal basis for processing personal information. The purpose of the processing is primarily based on Bricksite having a legitimate business interest in processing your personal data, which does not conflict with your rights regarding personal data protection and self-determination. Bricksite also bases a number of activities on your consent, including marketing, which we will cease if you withdraw your consent. In addition, in certain cases, we have a legal obligation to disclose your personal data, including when you purchase a domain.

Profiling

In order to provide relevant and targeted content to potential customers, Bricksite may build an interest profile based on your activity and actions on Bricksite websites and based on responses to marketing. The legal basis for such processing is primarily your consent.

Collection of personal information

In general, Bricksite only collects personal information directly from you. Information may also be collected from a partner company if you have purchased services through such a company. If, for example, you ask another person to contact us on your behalf, we collect your personal data from a third party. In such cases, Bricksite will always ensure that any proxy relationship is identified before we can disclose your personal data to third parties.

We do not process personal information about children who we know are under 13 years old unless we have obtained explicit consent from the holder of parental responsibility. If we discover that personal information about a child is being processed without the parents' consent, this personal information will be deleted as soon as we become aware of it.

Cookie Declaration and Pixels

We also use cookies and other tracking tools when you use Bricksite pages and when you communicate and interact with us via email. We do this to optimize your experience of Bricksite. In some cases, we may also use other sources to collect information. These may include marketing partners, public sources, or third-party social networks.

Cookies are a small text file that creates a unique identification of a user. Most browsers are set up by default to accept cookies, as they are required by most websites to access them. You can change the settings in your browser settings and block cookies in this way. Tracking pixels are scripts that are executed when a user visits a website.

You can read more about cookies at www.allaboutcookies.org.

Examples of our cookies

Analytics

This cookie allows us to see information about website activities for users, including - but not limited to - page views, source, and time spent on a website. The information is anonymized and displayed as numbers, meaning it cannot be traced back to individuals. This helps protect your privacy.

Remarketing

Places cookies on your computer, which means that when you leave our website, we can show you ads about Bricksite that you may be interested in based on your previous behavior on our website. This information is not personally identifiable.

Google AdWords

By using Google AdWords, we can see which pages were helpful in leading to submissions through our contact form. This allows us to make better use of our budget. This information is not personally identifiable. Google has a tool to prevent the collection of cookies (Google Analytics Opt-out Browser Add-on).

Facebook Remarketing

Facebook Pixel places cookies on your computer, which tells Facebook that you have visited the website. We then assume that you have an interest in Bricksite and its content. When you visit Facebook, you will then be exposed to information or campaigns with similar content. Please use your privacy settings on Facebook to limit exposure to marketing of this type.

Customer Service

When you communicate with Bricksite and use our services, we collect personal information to identify you and help you.

The type of personal information may include:

Basic contact information such as name, address, phone number, and email

Feedback, comments, or questions about Bricksite or our products and services

Financial information, such as payment details

Browsing traffic information provided by your web browser, such as browser type, device, language, and the address of the website you came from, and other traffic information, including IP address

Clickstream behavior and activity on Bricksite pages, our products, and services

Email behavior, such as which emails from Bricksite you open

Other personal information contained in your profile that you have voluntarily provided on third-party social networks, such as Facebook, etc.

Free text when you write to us, which may contain an undefined number and categories of personal information.

Personal Information We May Share with Third Parties

Police and public authorities may require personal information from Bricksite to be disclosed. Bricksite will only disclose the information if there is a legal basis for doing so.

In connection with mergers, divestments of all or parts of Bricksite's business, consultants may gain access to personal information upon entering into a confidentiality agreement.

If legitimate from a business perspective and in accordance with applicable data protection legislation, business partners may gain access to parts of personal information in order to be able to deliver a service or product.

Communities where you post, comment, or similar will be publicly available to anyone with access to the relevant forum. Bricksite is not responsible for personal information you submit in forums on Bricksite pages or other communities, but we naturally moderate the content in our communities.

Bricksite will not publish your comments, recommendations, or similar without your consent.

Rights

You have the right to opt-out of marketing communications from Bricksite. This can be unsubscribed in the relevant marketing communication or you can contact us at privacy@bricksite.com. Please be aware that you may still receive administrative messages from Bricksite. These may be order confirmations and system messages, which are important and necessary to manage your account or the services we provide. There will also be important announcements about system updates, such as security or similar, where, as a user, it requires action from you.

As a user, you have the right to access your personal information by requesting an overview of personal information about you, and you may have a right to data portability. You also have the right to request Bricksite to correct inaccuracies in your personal information. You can do this when you are logged in to your account. You have the right to request the deletion of personal information and to limit or object to our processing of your personal information in accordance with this Privacy Statement or other service-specific terms. Please write to privacy@bricksite.com to submit all requests mentioned in this section. Bricksite must comply with your request for deletion within 30 days, provided we can identify you. You also have the right to file a complaint with the Data Inspectorate regarding Bricksite's processing of your personal information if you believe that we violate your rights or the processing is illegal.

Data Storage and Security

Bricksite takes security very seriously. Bricksite is committed to preventing unauthorized access, monitoring, or disclosure of personal information. Bricksite must ensure the availability and confidentiality of the personal information we process in accordance with applicable personal data protection legislation. Bricksite takes reasonable organizational, technical, and physical procedures and precautions to protect information. Bricksite's employees are part of a strong corporate culture where vigilance and respect for personal data are fundamental and important.

Bricksite has the following precautions in this regard:

Organizational precautions: E-learning courses and information material on data protection, procedures for processing personal data, and data processing agreements with suppliers who process data on behalf of Bricksite.

Technical precautions: Limiting access to personal data to those who need it in connection with agreements, legislation, security assessments, and analysis of existing technical measures to protect data, assessing encryption and pseudonymization, and risk-limiting measures. To provide optimal security, all customer passwords are stored either in encrypted form or as a hash value.

Bricksite only stores your personal information for as long as necessary to best serve you and takes into account our need to answer inquiries and solve problems. Bricksite therefore only stores your personal information for a reasonable period after your last interaction with Bricksite. When collected information is no longer necessary, we delete it. In some cases, we may process data for statistical purposes. In these cases, the data will be pseudonymized or anonymized.

Changes

Bricksite may make changes to this Privacy Statement with reasonable notice, taking operational considerations into account. We encourage you to review the Statement regularly. If we make significant changes to our Statement that significantly change our personal data protection practices, we may also notify you in other ways, for example, by sending an email or by posting a notice on our website and/or through social media, before the changes take effect.

Contact

If you have any comments or questions regarding our Privacy Statement, unresolved issues regarding data protection and data use, or a possible breach of your personal data protection, please send your inquiry in writing to:

Bricksite ApS

Attn: The Data Protection Officer

privacy@bricksite.com

Normansvej 1

8920 Randers NV

Denmark

We treat your requests confidentially. We will contact you to address your issues and the possibilities for resolving them. Our goal is to ensure that inquiries are resolved in a timely and appropriate manner.

List of Bricksite's suppliers

In its role as Data Controller, Bricksite entrusts certain types of data processing to other suppliers. Bricksite tries to use suppliers within the EU as much as possible, but in some cases, it may export data to a location outside the EU. This could be, for example, a cloud service provider or other IT hosting services.

When using such suppliers, Bricksite will enter into a Data Processing Agreement (DPA) with the suppliers to ensure your personal data rights and to fulfill our obligations to our customers. You can be confident that your personal data is treated with the utmost confidentiality by our suppliers. Note that each Data Processor may have its own Sub-processors. These are specified in the individual service's Privacy Policy.

When a supplier is located outside the EU, Bricksite ensures the legal basis for such international transfers on behalf of our customers, for example, by using the Data Protection Authority's Standard Contractual Clauses.

Services where Bricksite is the data controller

ActiveCampaign LLC (4935812)

Country: USA

Purpose: Marketing, Newsletters

Transfer basis: Standard contract

Processing basis: Consent.

Amazon Web Services EMEA SARL ("Amazon Europe") (FC034225)

Country: EU

Purpose: Application monitoring (Sentry)

Processing basis: Necessary for the fulfillment of the contract.

Circles & Squares ApS (DK39805685)

Country: DK

Purpose: Accounting, Invoicing

Processing basis: Legal obligation.

Crisp IM SARL (FR833085806)

Country: EU

Purpose: Customer service

Processing basis: Necessary for the fulfillment of the contract (customer relationship). Otherwise, legitimate interest.

Google Ireland Ltd. (IE368047)

Country: EU

Purpose: Email, Customer service

Processing basis: Necessary for the fulfillment of the contract (customer relationship, employment relationship). Otherwise, legitimate interest.

Hotjar Ltd. (MT21846014)

Country: EU

Purpose: Application monitoring, extended

Processing basis: Legitimate interest.

Mailerlite UAB (LT302942057)

Country: EU

Purpose: Marketing, Newsletters

Processing basis: Consent.

Mailgun Technologies Inc. (USTX0802653513)

Country: USA

Purpose: System notifications (Classic customers only)

Transfer basis: Standard contract (https://www.mailgun.com/dpa)

Processing basis: Necessary for the fulfillment of the contract.

Nuuday A/S ("Relatel") (DK40075291)

Country: DK

Purpose: Customer service (telephony)

Processing basis: Necessary for the fulfillment of the contract (customer relationship). Otherwise, legitimate interest.

Sendinblue SAS (498 019 298 00070)

Country: EU

Purpose: System notifications

Processing basis: Necessary for the fulfillment of the contract.

Twilio International Inc. (USTX0803586706)

Country: USA — NOTE, Twilio is launching a European data center in H2 2022, where we will migrate data as soon as possible

Purpose: Customer service (SMS service)

Transfer basis: Standard contract (https://www.twilio.com/legal/bcr/processor) Processing basis: Necessary for the fulfillment of the contract (customer relationship). Otherwise, legitimate interest.

Visma e-conomic A/S (DK29403473)

Country: DK

Purpose: Accounting, Invoicing

Processing basis: Legal obligation.

Services where third party is the data controller, or there is a shared data responsibility

Some services require Bricksite to disclose data to third parties. This is not a data processor construction, and therefore these data are processed according to the service's separate Terms & Conditions and Privacy Policy. Third parties may further process your data for their own purposes, including with respect to their legal obligations.

Clearhaus A/S (DK33749996)

Terms & Conditions: https://www.clearhaus.com/dk/terms

Country: DK

Purpose: Payment processing (international payment cards)

Processing basis: Necessary for the fulfillment of the contract.

DK Hostmaster A/S (DK833085806)

Terms & Conditions: https://www.dk-hostmaster.dk/da/mine-vilkar

Confidentiality in WHOIS: https://www.dk-hostmaster.dk/da/anonymitet

Country: DK

Purpose 1: Ordering of .dk domains

Processing basis 1: Fulfillment of contract

Purpose 2: Disclosure of registrant information, including for use in the Danish WHOIS register of domain owners

Processing basis 2: Legal obligation (Act on Internet Domains, etc.).

Facebook Ireland Ltd. (IE462932)

Terms & Conditions: https://www.facebook.com/terms

Country: EU

Purpose: Advertising based on profiling

Additional: The customer can manage and personalize banner ads through Facebook

Processing basis: Legitimate interest.

Google Ireland Ltd. (IE368047)

Country: EU

Purpose: Advertising based on profiling

Processing basis: Legitimate interest.

IMC Ltd. ("White Label Services")

Country: Israel

Purpose: Debugging at the customer's request. Used only for software technical errors of a more serious nature, where Bricksite cannot resolve the error itself.

Transfer basis: Adequacy decision

Processing basis: Legitimate interest.

Key-Systems GmbH ("RRPproxy") (HR B 18835)

Terms & Conditions: https://www.rrpproxy.net/Legal/Terms_and_Conditions

Domain terms (depending on the domain's country of origin): https://www.rrpproxy.net/Domains/TLD_Portfolio

Additional Terms: Additional disclosure may occur, for which Key-Systems GmbH is responsible. Certain international domains may require citizenship/affiliation or be subject to national legislation in the third country, which overrides your European rights.

Confidentiality in WHOIS: https://www.rrpproxy.net/Domains/Whois_Privacy_Solution

Country: Depends on the domain's country of origin (TLD/gTLD/ccTLD)

Purpose 1: Ordering of international domains

Processing basis 1: Necessary for the fulfillment of the contract

Purpose 2: Disclosure of registrant information to the national WHOIS register of domain owners

Processing basis 2: Legal obligation / Necessary for the fulfillment of the contract (depending on the domain's country of origin).

Nets A/S (DK37427497)

Terms & Conditions: https://dankort.dk/dk/support/erhverv/regler-og-vilkaar-dankort

Country: DK

Purpose: Payment processing (Dankort & VisaDankort)

Processing basis: Necessary for the fulfillment of the contract.

QuickPay ApS (DK21822434)

Terms & Conditions: https://quickpay.net/dk/terms-of-service

Country: DK

Purpose: Payment gateway (PSP). Storage of payment card and transaction information for recurring payments (all payment cards). We receive updated payment card information upon expiration and reissuance of payment cards when technically possible.

Processing basis: Necessary for the fulfillment of the contract.

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