Privacy policy

3.1.1 Cookies

A cookie is a small text file that is stored on your device when you visit a website. Cookies are placed either by us (first-party cookies) or by one of our partners (third-party cookies).

Every time you browse the web, you create a digital footprint consisting of a trail of information about your device and browsing behaviour.

You decide what kind of cookies we may store on your device through the cookie banner. When you first visit our website, the cookie banner appears on the front page. After that, you can always find it at the bottom right of our website via the small padlock icon.

Cookies are used for different purposes. Some are necessary for the website to function, others re-member your preferences such as language, and some help display relevant advertisements. They are stored for varying periods of time.

You can always reject or delete cookies in your browser settings. However, please note that if you block all cookies, some website features may stop working, such as login functionality.

Read more about cookies in our cookie policy here or about the different types of cookies in our cook-ie banner, which you can find here.

Types of personal data

When you browse our website, we collect, process and store the following personal data via cookies:

• Your IP address

• Browsing history

• General activity on the website, including click behaviour

• Information on your device type and ID, browser type and operating system

• Domain name

• Length of you visit to our website

• The referring URL or the webpage that led you to our website

• Unique cookie ID / Session ID

• Cookie consent status

• The time of your visit

The purposes of the processing

Your personal data may be processed for the following purposes:

• Marketing in general, for example via third party advertisers

• Product and service development, including through segmentation, click behaviour or other patterns

• Statistics and analysis, including conversion analyses

Legal basis for processing

We process your information based on the following grounds:

• Legitimate interests: We base the processing of your personal data on our legitimate in-terests in, for example, conducting statistics, analysis, providing support, as well as improv-ing and developing our products and services. We process personal data collected via nec-essary cookies (Article 6(1)(f) of the General Data Protection Regulation).

• Consent: When visiting our websites, we ask for your informed consent to place functional cookies, statistical cookies and marketing cookies. You have the right to withdraw your con-sent at any time. Processing of your personal data via functional, statistic and marketing cookies is based on your consent to the cookies in question (Article 6(1)(a) of the General Data Protection Regulation).

Retention period

Cookies are deleted in accordance with our cookie policy. However, the information may be stored for a longer period in anonymised form.

Read more about cookies in our cookie policy here.

Distribution of personal data

We may share information about your use of our website with our partners within social media, ad-vertising, and analytics. We and our partners may combine the above-mentioned personal data with other information about you or similar users. This may include information you have provided your-self, or information that our partners have collected from your or others' use of their services.

The purpose of sharing is to target and personalize marketing to you via our or third-party websites. We share your personal data based on our legitimate interest in showing you targeted, personalized marketing (Article 6(1)(f) of the General Data Protection Regulation). The prerequisite for being able to offer you this service is your prior cookie consent for marketing as described above.

Some of our partners collect and process your personal data for their own purposes, and we there-fore encourage you to read our partners' privacy policies, which you can find links to via our cookie banner.

Right to object

You always have the right to object to our processing of your personal data for use in direct market-ing. If you object to direct marketing, you will only receive general marketing that is not tailored to you. You always have the option to revisit your cookie settings on our website and cookie banner and de-cide which cookies you accept.

3.1.2 If you use a contact form on our websites, order an e-book, book a demo or otherwise communicate with us

Types of personal data

When using the contact form on the websites, contacting customer service, or otherwise communi-cating with us, we collect and process your personal data. We collect, process and store the follow-ing types of personal data about you:

• Name, e-mail address, phone number

• What your inquiry is about

• Date of your inquiry

• Other information you provide in connection with your inquiry, for example workplace, job title, product interest

We encourage you not to provide sensitive personal data to us unless it is strictly necessary for the processing of your inquiry. Sensitive data includes, for example, data concerning health, pregnancy, religious or sexual orientation. In this context, the information should only be sent in a highly encrypt-ed form if you send the information by e-mail. We reserve the right to delete sensitive information immediately, depending on the inquiry.

The purposes of the processing

Your personal data may be processed for the following purposes:

• Handling of your inquiry

• General communication

• Statistics and analysis

Legal basis for processing

We process your information based on the following grounds. The basis depends on the nature of your inquiry:

• Legitimate interests: We may process your personal data on the basis of our legitimate in-terests in handling your inquiry, communicating with you, and developing our products and services (Article 6(1)(f) of the General Data Protection Regulation).

• Contractual obligations: If your inquiry concerns a (potential) formation of contract, we process your data to implement measures before the formation of contract (Article 6(1)(b) of the General Data Protection Regulation).

Retention period

The retention period depends on the nature of the inquiry. General inquiries are retained for up to 2 years. Sensitive information is deleted immediately upon receipt.

If you are a customer or an employee of one of our suppliers, commercial (B2B) customers, or other business partners etc., we refer to section 3.5 below.

3.1.3 Age verification and processing of children’s personal data

We use cookies and tracking technologies to improve our services, but our services are intended for adults, and we do not knowingly process personal data from individuals under the age of 18. To ensu-re this:

• We do not request, collect, or process personal data from children

• We do not target advertising or tracking towards individuals under the age of 18

• Our systems are not designed to collect or analyze data specifically about children

• If we become aware that we have inadvertently collected personal data about an individual under the age of 18, we will immediately delete this information

• We encourage parents and guardians to contact us at dpo@systematic.com if they suspect that their child’s data has been mistakenly collected.

3.1.4 If you sign up for events on our website

Types of personal data

When you sign up for events on our website, we process your personal data. We collect, process and store the following types of personal data about you:

• Name, e-mail address and phone number

• Information about which event you signed up for

• Information about food preferences or specific dietician provided in relation to attending an event

• Other information provided when signing up for the event, for example workplace, job title, product interests

The purposes of the processing

• Your personal data may be processed for the following purposes:

• Handling of your registration to the event and food preferences

• Transmitting information to you about the event

• Statistics and analysis

Legal basis for processing

We process your information based on the following ground:

• Legitimate interests: We may process your personal data on the basis of our legitimate in-terests in handling your inquiry, communicating with you, and developing our products and services (Article 6(1)(f) of the General Data Protection Regulation).

Retention period

Your personal data given when signing up for an event is kept for up to 12 months after the event has taken place. Sensitive data is deleted immediately upon receipt.

If you are a customer or an employee of one of our suppliers, commercial (B2B) customers, or other business partners etc., we refer to section 3.5 below.

Types of personal data

We process your personal data for marketing purposes when you sign up for newsletter(s). We col-lect, process and store the following types of personal data about you:

• Name and e-mail address

• Your consent

• Your click-behaviour in relation to published material

• Your postal code, in order to send you marketing materials relevant to the area you live in.

The purposes of the processing

Your personal data may be processed for the following purposes:

• Marketing

• Analysis and statistics

Legal basis for processing

We process your information based on the following grounds:

• Consent: Systematic will only use your personal data for direct marketing, including for send-ing out newsletters, if you have given your prior and explicit consent to receive communica-tions of this nature (Article 6(1)(a) of the General Data Protection Regulation)

• Legitimate interests: The processing of your personal data will, in connection with analy-sis and statistics, be based on our legitimate interests in being able to improve and develop our service (Article 6(1)(f) of the General Data Protection Regulation).

Retention period

Your personal data will be stored as long as your consent to receive newsletters from us is active.

You can always withdraw your consent by clicking on the unsubscribe link at the bottom of each e-mail or by contacting us as described below. However, withdrawing your consent does not affect the legality of the processing that preceded prior to the withdrawal.

We will keep documentation of your consent for 2 years from the date you withdrew your consent to receive direct marketing material. We have determined the retention period based on our legitimate interest in being able to demonstrate that we have sent direct marketing in compliance with applica-ble legislation (Article 6(1)(f) of the General Data Protection Regulation).

Purpose of the whistleblower scheme

Suspicions of irregular behaviour and violations of applicable law or internal guidelines should be re-ported via our whistleblower service on our website.

When a reporting is made, we will process personal data about the data subjects who are part of the report (i.e., the sender of the report, the reported person, and other third parties involved) in order to handle and investigate the alleged infringement.

If you report an alleged infringement, such reporting will remain confidential and, at your wish, anon-ymous. However, you should in any case provide an e-mail address, as we may need to obtain fur-ther information about the violation in order to handle the case properly.

Types of personal data

We may collect, process and store the following types of personal data about the reported person:

• Name, contact information, job title, and reported information

• Description of the alleged infringement

The following personal data may be processed about third parties mentioned in the report:

• Name, contact information, job title, and other reported information

The purposes of the processing

Your personal data may be processed for the following purposes:

• Administration of the whistleblower scheme

• Administration of reported incidents, including clarification of potentially criminal matters

Legal basis for processing

We process your personal data on one or more of the following legal bases:

• Legitimate interests: We may process your personal data on the basis of our legitimate in-terest in investigating reported incidents (Article 6(1)(f) of the General Data Protection Regu-lation).

• Legal obligation: As it per the 17th of December 2021 is mandatory for Systematic to have a whistleblower scheme, we process your personal data in order to fulfil our legal obligation to keep the scheme in operation and handle the reports that happen via the scheme (Article 6(1)(c) of the General Data Protection Regulation).

Retention period

Your personal data will be stored for as long as it is necessary to handle the specific reports.

When you apply for a job with us, we process your personal data as a part of the recruitment pro-cess. We recommend that your application does not contain a social security number or other per-sonal identification number, or sensitive personal data, such as personal data revealing racial or eth-nic background, trade union membership, religious or sexual orientation, or data concerning health.

Types of personal data

We may collect, process, and store the following personal data:

• Contact information such as name, e-mail address, and phone number

• Information included in the application, CV and other attachments

• Relevant information that is publicly available on the internet and social media, particularly in-formation about previous employment, activities, skills, performance, and general appear-ance

• Criminal record, if necessary for the position you have applied for

• References from previous and/or current employers that you have listed in your application, or that you have given consent for us to contact

• Other information you provide us in connection with the recruitment process

• Results of personality tests if you complete such

• Health information, if the position you have applied for requires special health conditions

The purposes of the processing

Your personal data will be processed for the purpose of assessing whether we can offer you a posi-tion at Systematic.

Legal basis for processing

We process your personal data on the following legal bases:

• Legitimate interests: We may process your personal data based on our legitimate interest in assessing whether we can offer you employment, including based on the information you provide in your CV, application, and any attachments, based on relevant information that is publicly available on the internet and social media, references from referees you have listed in your application, and other information you provide us in connection with the recruitment process (Article 6(1)(f) of the General Data Protection Regulation). If the position applied for requires it, we can later on in the recruitment process ask to see your criminal record based on our legitimate interest in this (The Danish Data Protection Act section 8(3)). The pro-cessing may also be necessary for our legitimate interest in defending or asserting legal claims (6(1)(f) of the General Data Protection Regulation).

• Consent: If the position applied for, exceptionally requires special health conditions we will – after a concrete assessment – ask for your explicit consent before processing such data (Article 6(1)(a) and Article 9 (2)(a) of the General Data Protection Regulation).

Retention period

If you are offered a position with Systematic, your application and additional relevant personal data obtained during the recruitment procedure will be stored in your employee file.

If you are not offered a position, we will store your application and any additional personal data ob-tained during the recruitment procedure for a period of 6 months following our rejection, unless you have provided your consent to the storage hereof for a longer period. This applies whether you re-ceive a rejection for a solicited or unsolicited application.

You can withdraw your consent given as part of the recruitment process at any time. Withdrawal of your consent will affect the future processing of your personal data but will not affect the legality of the processing prior to the withdrawal. If you wish to withdraw your consent, you can contact us as described down below.

If we have collected your criminal records, we will delete them immediately after we have received and reviewed them.

This section contains the policy for our processing of personal data of sole proprietorship owners or contacts of suppliers, commercial customers and other collaborators working with us.

Collection of personal data

We may collect, process, and store your personal data in the following cases:

• When your company or the company you work at, enters into an agreement with us

• When you have shown interest in our products and services, e.g. by providing us with your business card

• When collaborating and communicating with us

Types of personal data

We may collect, process, and store the following types of personal data about you:

• Name, e-mail address, phone number and corresponding contact information

• Individual information, e.g. preferred languages

• Contractual information such as orders, invoices, contracts, and other agreements between your company (or your employer) and Systematic that may contain, e.g. your contact infor-mation

We may receive such information directly from you (primarily through e-mails and other correspond-ence with you) or from a third party such as your employer.

The purposes of the processing

Your personal data may be processed for the following purposes:

• General planning, fulfilment, and the management of collaborations, including contracts

• Administration such as the processing of payments, rating evaluations, accounting, audit-ing, as well as providing support

• Conducting inquiries from you

• General communication

• Product and service development

• Statistics and analysis

• Compliance with applicable laws and regulations, e.g., fulfilment of our obligations to pre-vent illegal activities

• Managing conflicts

Legal basis for processing

We primarily process your personal data on one or more of the following grounds:

• Contractual obligations: In certain cases, the processing of your personal data is nec-essary to fulfil a contract (Article 6(1)(b) of the General Data Protection Regulation).

• Legitimate interests: We may process your personal data on the basis of our legitimate interests in, for example, managing day-to-day operations in accordance with legitimate and fair business practices, including planning, execution and management of the co-operation or our legitimate interest in, for example, performing statistics, analyses, pro-vide support and as well as improvement and development of our products and ser-vices. The processing may also be necessary for our legitimate interest in preventing fraud or establishing, defending, or asserting legal claims (Article 6(1)(f) of the General Data Protection Regulation).

• Legal obligation: The processing of your personal data will in some cases be necessary for compliance with legal obligations, such as our obligation to prevent illegal activities (Article 6(1)(c) of the General Data Protection Regulation).

Retention period

Your personal data will be stored for 2 years from the termination of the cooperation. However, infor-mation included in accounting material may be stored for 5 years from the end of the financial year in order to comply with the rules of the Danish Bookkeeping Act. The information may, however, be re-tained longer in anonymised form.

This section contains a description of our processing of personal data about visitors in our offices and other physical locations.

3.6.1 Name tags for guests

Types of personal data

When you visit our offices or other of our physical locations, Systematic may collect, process, and store the following types of personal data about you:

• Your name

The purposes of the processing

Your personal data may be processed for the following purposes:

• As part of an organisational security measure at Systematic, it is required to wear a name tag to access our offices

Legal basis for processing

We process your personal data on the following ground:

• Legitimate interests: We process your personal data on the grounds of our legitimate in-terests in being able to implement admissions requirements and maintain security in our of-fices (Article 6(1)(f) of the General Data Protection Regulation).

Retention period

Information relating to name tags are kept for 3 years from the moment they are given, after which period they are anonymized. However, we may process your personal data for a longer period in anonymised form.

3.6.2 Video surveillance of our offices

Types of personal data

When visiting our offices, we may collect, process, and store the following types of your personal data:

• Photo and video materials from the surveillance of our offices.

The purposes of the processing

Your personal data may be processed for the following purposes:

• Surveillance is done for safety reasons to ensure and maintain security, and to prevent and re-solve criminal activity.

Legal basis for processing

We process your personal data on the following ground:

• Legitimate interests: We process your personal data on the grounds of our legitimate in-terests in being able to implement admissions requirements and maintain security in our of-fices (Article 6(1)(f) of the General Data Protection Regulation). Data regarding criminal of-fences collected from surveillance is also processed on the grounds of our legitimate inter-ests in resolving criminal activities (The Danish Data Protection Act section 8(3)).

Retention period

Recordings from the surveillance made with a crime preventing purpose will be deleted or anony-mized within 30 days after the recordings, unless it is necessary for Systematic to store it in order to be able to handle a specific dispute, for example regarding a violation of the law.

This section contains a description of our processing of personal data about customers, visitors and other participants in our marketing campaigns.

Types of personal data

When you participate in our marketing material, we may collect, process, and store the following types of your personal data:

• Your name

• Photo and video material in connection with the preparation and execution of campaigns

The purposes of the processing

Your personal data may be processed for the following purpose:

• Marketing

Legal basis for processing

We process your personal data on one or more of the following grounds:

• Legitimate interests: We base the processing of your personal data on our legitimate in-terests in marketing our company (Article 6(1)(f) of the General Data Protection Regulation). We also base our processing on our legitimate interest in being able to contact you again and document your participation in our marketing campaigns.

• Consent: We may use your photos and videos for marketing purposes, including publication on our website and social media when you have given your prior consent to this (Article 6(1)(a) of the General Data Protection Regulation).

Disclosure

We may disclose material containing images or videos of you to sub-suppliers in connection with the preparation of marketing material. The disclosure is based on our legitimate interest in being able to have marketing material prepared (Article 6(1)(f) of the General Data Protection Regulation).

Retention period

Your personal data will be stored until your consent is withdrawn. Documentation of the consent will be stored for up to 2 years after the withdrawal. However, we may process your personal data for a longer period in anonymised form.

This section contains the policy for our processing of personal data collected through our profiles or social media pages.

Social Media Platforms

We have profiles or pages on the following social media platforms:

• Facebook (Meta Platforms Ireland Ltd.)

  • Facebook’s privacy policy is available here: Facebooks privacy policy

  • You can adjust your privacy settings on Facebook here.

• - LinkedIn (LinkedIn Ireland Unlimited Company)

  • LinkedIn’s privacy policy is available here: LinkedIns privacy policy

  • You can adjust your privacy settings on LinkedIn here.

• - Instagram (Meta Platforms Ireland Ltd.)

  • Instagram’s privacy policy is available here: Instagrams privacy policy

  • You can adjust your privacy settings on Instagram here.

• - YouTube (Google Ireland Ltd.)

  • Google’s privacy policy is available here: Googles privacy policy

  • You can adjust your privacy settings on YouTube here.

• - X (X International Unlimited Company)

  • X’s privacy policy is available here: X’s privacy policy

  • You can adjust your privacy settings on X here.

With respect to LinkedIn, Facebook and Instagram, we act as joint data controllers together with the providers of these social media platforms for the processing of personal data collected in connec-tion with your interactions with the profiles, including posts made by said profiles.

Systematic and the providers of LinkedIn, Facebook and Instagram have entered into an agreement concerning the allocation of data protection obligations. Pursuant to these agreements, Systematic and the providers of the social media platforms are individually responsible for the tasks associated with the processing that each party respectively undertakes. However, it has been agreed between Systematic and the provider of Facebook and Instagram that the provider shall be responsible for enabling you to exercise your rights as set forth in the section ‘Your rights' below, in connection with the use of Facebook and Instagram, and that we shall be responsible for providing you with the in-formation described herein. Furthermore, it has been agreed between Systematic and LinkedIn that LinkedIn shall be responsible for responding to your requests concerning the rights set forth in the section ‘Your rights’ below.

Additionally, Systematic engages the provider of YouTube and X as a data processor in connection with our use of YouTube and X. In this context, we also share certain information regarding your in-teractions, interests, etc. with YouTube and X. Such sharing is conducted on the basis of our and the providers' legitimate interest in optimizing marketing and services (Article 6(1)(f) of the General Data Protection Regulation).

Types of personal data

When you visit or interact with our social media profiles, Systematic and the social media provider may collect, process, and store the following types of personal data about you:

• Information available on your profile, including your name, gender, civil status, workplace, inter-ests, image, and your city

• Whether you “like” or have applied other reactions to our profile

• Comments you leave on our posts

• That you have visited our profile

• Your IP address

The purposes of the processing

Your personal data may be processed for the following purposes:

• Improving our products and services, including our social media profiles and pages

• Statistics and analysis

• To be able to communicate with you if you comment on a post, make a review, or send us a message

• Marketing in general

Social Media Providers’ Processing

Social media providers process your personal data for the following purposes:

• Improving their advertising system

• To provide Systematic with statistics which the social media providers produce based on your visit to our profiles and pages

• Advertising and customising the activities on the page

Legal basis for processing

The processing of your personal data is based on the following basis:

• Legitimate interests: We base the processing of your personal data on our legitimate in-terests in being able to communicate with and market us to you on our social media pro-files, as well as our legitimate interest in improving our products and services (Article 6(1)(f) of the General Data Protection Regulation).

Retention period

Direct enquiries are kept for up to 2 years. However, the retention period depends on the content of the enquiry.

We encourage you to delete comments, likes, and other interactions you have left on our profile your-self if you no longer want them shown on our pages. We do not delete such publicly available interac-tions.

Please see the privacy policy of each social media provider for information on how long they store your personal data.

Who do social media providers share your personal data with?

Social media providers may, among other things, share your personal data with the following catego-ries of recipients:

• Other devices in the group of which the social media provider is a part of

• External partners providing analysis- and survey services

• Advertisers

• Other individuals visiting our social media profile or page (to the extent that your information is publicly available)

• Researchers and other academics

You can find more information about who the social media providers share your personal data with, in each provider’s privacy policy.

The social media providers may transfer their personal data to recipients outside the EU/EEA in ac-cordance with applicable data protection legislation. You can read more in each provider’s privacy policy.

You can read more about who Systematic shares your personal data with, in the Section Transmis-sion to other controllers and processors below.