Privacy policy
At PWT Group A/S (hereinafter "Lindbergh") we prioritise confidentiality and data security. In this privacy policy, we provide you with the information you are entitled to receive in accordance with applicable data protection legislation.
We encourage you to read our privacy policy before submitting your personal data to Lindbergh.
1. Data controller and contact details
The data controller for the processing of your personal data is:
PWT Group A/S
CVR no. 31081610
Gøteborgvej 15-17
9200 Aalborg SV
E-mail: [email protected]
Phone: +45 72 45 44 43
2. If you visit our website
The following section describes our processing of personal data about visitors to www.lindberghfashion.com.
2.1 Cookies
We use cookies on our website to, among other things, optimise the user experience and prevent abuse and downtime. The use of cookies and the processing of personal data in this context is described in more detail in our cookie banner, which is displayed on the front page when you visit our website for the first time.
You can always change your cookie settings by clicking on the small cookie symbol in the bottom left corner of the website.
Types of personal data
When you visit our website, we may collect the following information about you.
- IP address
- Browsing history
- General behaviour on the website, including click behaviour
- Information about your device, including type, browser, operating system, MAC address
Purposes of processing
Your personal data may be processed for the following purposes:
- Targeted marketing, including retargeting
- Product and service development
- Statistics and analysis
Basis for processing
We process your personal data on the following basis:
- We base the processing of your personal data on our legitimate interests in, for example, conducting statistics, analyses, providing support as well as improving and developing our products and services and marketing ourselves to you (Article 6(1)(f) of the GDPR).
- When you visit our website, we ask for your informed consent to place non-functional cookies in accordance with the cookie rules. You have the right to withdraw your cookie consent at any time by clicking on the small cookie symbol in the bottom left corner of the website.
Retention period
Cookies are deleted in accordance with our cookie policy, which is available via our cookie banner.
However, the information may be stored longer in anonymised form.
Disclosure
We may disclose information about your use of our website to our social media, advertising and analytics partners. We and our partners may combine the above personal data with other data about you or comparable users. This may, for example, be information that you have provided yourself or information that our business partners have collected from your or others' use of their services. The purpose of the disclosure is to target and personalise marketing to you via our or third parties' websites. We disclose your personal data on the basis of our legitimate interest in showing you targeted, personalised marketing (Article 6(1)(f) of the General Data Protection Regulation). The prerequisite for offering you this service is your prior cookie consent for marketing as described above.
Some of our business partners collect and process your personal data for their own purposes, and we therefore encourage you to read the privacy policies of our business partners, which you can find links to via our cookie banner.
Right to object
For the sake of good order, please note that you always have the right to object to our processing of your personal data for direct marketing purposes. If you object to direct marketing, you will only receive general marketing that is not customised to you. You can, among other things, revisit your cookie settings via our website and decide which cookies you want to accept.
2.2 Club [clubbrand]
Types of personal data
If you register as a member of Club [clubbrand] via our website, we will process your personal data. We may collect, process and store the following types of personal data about you:
- Name, email, phone number, birthday, gender and address
- Log-in, including password and username
- Order history and receipts
- Consent to marketing
- Click behaviour on the website and in distributed material
Purposes of processing
Your personal data is processed for the following purposes:
- Managing your membership
- Statistics and analysis
- Targeted marketing. Information collected via cookies (when you have given your cookie consent) is compared with the information from your member account in order to personalise and target our marketing so that we only send you marketing that we believe is of interest to you. See also section 2.1 above.
Basis for processing
We process your personal data on the following basis:
- We process your personal data on the basis of our legitimate interest in administering the created member accounts, our legitimate interest in conducting statistics and analyses to improve the user experience and our legitimate interest in sending you targeted marketing (Article 6(1)(f) of the General Data Protection Regulation).
- Lindbergh may use your personal data for direct marketing purposes, including sending newsletters, if you have given your prior and explicit consent to this (section 10(1) of the Danish Marketing Practices Act).
Storage period
Your personal data will generally be stored for 3 years from the last registered activity on your member account.
You can always withdraw your marketing consent by clicking the unsubscribe link at the bottom of each email or by contacting us as described below. However, revocation of your consent does not affect the lawfulness of the processing preceding the revocation.
We will retain documentation of your marketing consent for two years after you have withdrawn your consent to receive direct marketing material. We have determined the retention period based on our legitimate interest in being able to document that we have sent direct marketing in accordance with applicable law (Article 6(1)(f) of the General Data Protection Regulation).
2.3 Webshop
Types of personal data
When you use our webshop, we process your personal data. We may collect, process and store the following types of personal data about you:
- Your name, email address, phone number and address
- Your payment details
- Information about your order/purchase history
- Information you provide when you complete a purchase or otherwise communicate with us
- Use of discount codes
- Digital footprints (e.g. information about how you use Lindbergh's webshop)
Purposes of processing
Your personal data is processed for the following purposes:
- Order fulfilment in our webshop
- Management of shipments, complaints, returns
- Member account management and your use of our member benefits
- Sending marketing without consent based on previous purchases with us in cases where we choose to utilise this option in the Danish Marketing Practices Act.
- Follow-up on "lost basket" if you have given your consent.
- Statistics and analysis
Basis for processing
We process your personal data on the following basis:
- We process your personal data on the basis of our legitimate interest in marketing ourselves to you in cases where consent is not required, as well as our legitimate interest in being able to conduct statistics and analyses in order to develop and improve our services (Article 6(1)(f) of the GDPR).
- We process your personal data to fulfil the purchase agreement entered into with you, including to be able to deliver the ordered goods, handle order confirmations, complaints, returns, etc. (Article 6(1)(b) of the GDPR).
- We follow up on lost baskets based on your consent (Article 6(1)(a) of the General Data Protection Regulation).
Storage period
Personal data registered in connection with purchases on Lindbergh's webshop is stored for up to 6 years. The retention period is determined on the basis of the retention requirement in section 12 of the Danish Bookkeeping Act.
However, the data may be processed and stored longer in anonymised form or if we are required to do so by law.
2.4 Newsletter(s)
Types of personal data
Lindbergh collects, processes and stores your personal data for marketing purposes when you sign up for our newsletter(s). We may collect, process and store the following types of personal data about you:
- Name, email address, phone number and address
- Your consent
- Click behaviour on the website and in distributed material
- Order history, including any previous correspondence
- Your preferences, e.g. preferred materials
Purposes of processing
Your personal data may be processed for the following purposes:
- Targeted marketing, including by sending personalised emails, SMS messages and newsletters with, among other things, current member benefits and offers.
- Analyse and statistics
Legal basis for processing
We process your personal data on one or more of the following bases:
- The processing of your personal data for analysis and statistics is based on our legitimate interests in improving and developing our services (Article 6(1)(f) of the GDPR).
- We use your personal data for direct marketing purposes, including sending newsletters, if you have given your prior and explicit consent to this (section 10(1) of the Danish Marketing Practices Act and article 6(1)(a) of the General Data Protection Regulation).
Storage period
Your personal data will be stored as long as your consent to receive newsletters is active.
If you no longer wish to receive our newsletters, you can unsubscribe via the link at the bottom of each email, alternatively you can write to: [email protected]. However, revocation of your consent does not affect the lawfulness of the processing preceding the revocation.
We will retain documentation of your marketing consent for two years after you have withdrawn your consent to receive direct marketing material. The retention period is determined on the basis of our legitimate interest in being able to document that we have sent direct marketing in accordance with applicable law (Article 6(1)(f) of the General Data Protection Regulation).
2.5 Chat function, customer service and other communication
Types of personal data
When you use our chat function on the website, contact our customer service or otherwise communicate with us in other contexts, including via social media, we process the following types of personal data about you:
- Name, email address, phone number
- What your enquiry is about, e.g. order and payment details
- Date of your enquiry
- Other information you provide in connection with your enquiry. We encourage you not to provide us with sensitive personal data or civil registration numbers unless it is strictly necessary for the processing of your enquiry. If you send sensitive information or civil registration number via email, the information should be sent in highly encrypted form.
Purposes of processing
Your personal data is processed for the following purposes:
- Handling your enquiry and any orders
- Observance of any rights
- General communication
- Statistics and analysis
Basis for processing
We process your personal data on the below basis depending on the nature of your enquiry.
- We may process your personal data based on our legitimate interests in handling your enquiry, communicating with you and developing our products and services (Article 6(1)(f) of the GDPR).
- If your enquiry relates to the (potential) conclusion of a contract, we process your personal data in order to be able to carry out pre-contractual measures (Article 6(1)(b) of the GDPR).
Storage period
How long we keep correspondence with you depends on the content of your enquiry. As a rule, we do not store correspondence for longer than 3 years, unless we need to be able to document the correspondence for a longer period of time.
Accounting material, including personal data that we are obliged to store in accordance with the Danish Bookkeeping Act, is stored for up to 6 years.
3. If you visit our physical locations
When you visit us at our physical locations, including our stores, offices and warehouses, Lindbergh may process your personal data via CCTV. Clear signage is posted where CCTV is installed.
Types of personal data
When you visit our physical locations, we process the following types of personal data about you:
- Date and time of your visit
- Photo and video material in connection with CCTV surveillance
Purposes of processing
Your personal data is processed for the following purposes:
- To ensure and maintain the security of our office facilities and warehouses
- To prevent and solve crime
- Servicing incoming trucks
Basis for processing
We process your personal data on the following basis:
- We base the processing of your personal data on our legitimate interests in protecting our physical premises (Article 6(1)(f) of the GDPR). Information about criminal offences collected via CCTV surveillance is also processed on the basis of our legitimate interests in solving criminal offences (section 8(3) of the Danish Data Protection Act).
Retention period
Recordings from CCTV surveillance made for crime prevention purposes will be deleted or anonymised no later than 30 days after recording, unless it is necessary for Lindbergh to retain the recordings for the purpose of handling a specific dispute, e.g. in connection with solving an offence.
Disclosure
In case of criminal offences or suspicion thereof, the recordings may be disclosed to the police. Lindbergh's surveillance cameras are registered in the police camera register. Disclosure may also take place if required by law.
4. If you are a contact person at a supplier, business partner, etc.
If you work with Lindbergh in your professional capacity, including as the owner of a sole proprietorship or as a contact person at one of our suppliers or other business partners, you can read more about our processing of your personal data here.
Types of personal data
Lindbergh may collect, process and store the following types of personal data about you:
- Name, company, job title
- Your work-related contact details, e.g. email address, phone number and address
- Contractual information such as orders, invoices, contracts and other agreements between your company (or your employer) and Lindbergh, which may contain e.g. your contact details
We may receive the above information directly from you (primarily through emails and other correspondence with you) or from your employer. We process your data if your company or the company you work for enters into an agreement with Lindbergh, if you have shown interest in our products, e.g. by sharing your contact information with us or in connection with other co-operation.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Management of professional collaborations, including fulfilment of agreements
- Statistics and analysis
Legal basis for processing
Lindbergh primarily processes your personal data on one or more of the following bases:
- In certain cases, the processing of your personal data is necessary for the performance of a contract to which you are party (Article 6(1)(b) of the GDPR).
- We may process your personal data on the basis of our legitimate interests in managing the day-to-day operations, including managing our rights and obligations under the agreements, etc. that we have entered into with our business partners (Article 6(1)(f) of the General Data Protection Regulation).
Storage period
Personal data in connection with business collaborations is generally stored for up to 6 years after the termination of the agreement or collaboration, unless there are special considerations that justify a longer storage period.
5. If you visit our social media profiles
Our social media profiles and pages contain a link to this privacy policy, and you can therefore read more about our processing of your personal data in relation to your visit to our social media profiles in this section.
Some stores that operate independently under the Lindbergh name and logo manage their own social media profiles and pages. For more information about the processing of personal data on these pages, please refer to the information and contact details on the relevant page.
Lindbergh and the social media providers are joint data controllers for the processing of personal data collected in connection with your visit to Lindbergh's profile or page on the individual social media.
We have profiles or pages on the following social media platforms:
- Facebook (Meta Platforms Ireland Ltd.)
- YouTube (Google LLC)
- LinkedIn (LinkedIn Ireland Unlimited Company)
- Instagram (Meta Platforms Ireland Ltd.)
- TikTok (TikTok Technology Limited)
- WhatsApp (WhatsApp LLC)
Types of personal data
When you visit or interact with our social media profiles, Lindbergh 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, marital status, workplace, interests and city
- Whether you have "liked" or used other reactions on our profile
- Comments you leave on our posts, including in connection with competitions
- That you have visited our profile
Purposes of processing
We process your personal data 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, including organising competitions
- Recruitment
Social media providers process your personal data for the following purposes, among others:
- Improving their ad system
- To provide Lindbergh with statistics that the social media providers compile based on, among other things, your visit to our profiles and pages
- Advertising and customisation of activities on the site
Basis for processing
The processing of your personal data is based on the following legal basis:
- We base the processing of your personal data on our legitimate interests in being able to communicate with and market ourselves to you on our social media profiles, as well as our legitimate interest in improving our products and services (Article 6(1)(f) of the GDPR).
The social media providers base the processing of your personal data on their legitimate interests, including their interest in improving their advertising system and providing statistics to Lindbergh, which the social media provider, for example, compiles based on your visit to our profile or social media page. In addition, the social media providers have a legitimate interest in providing an innovative, personalised, secure and profitable service (Article 6(1)(f) of the GDPR).
- The social media providers process certain of your personal data in accordance with your consent, which you can withdraw at any time via your privacy settings on the social media (Article 6(1)(a) of the GDPR).
Storage period
We encourage you to delete comments, likes and other interactions you have left on our profile if you no longer want them to appear on our pages. Lindbergh does not delete such publicly available interactions.
If you communicate with us via the messaging function on social media, please refer to section 2.5.
Please refer to the privacy policy of the individual 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 share your personal data with the following categories of recipients, among others:
- Other entities in the group the social media provider is part of
- Externally with partners who provide analytics and research services
- Advertisers
- Other individuals who visit our profile or social media page (to the extent your information is publicly available)
- Researchers and other academics
You can find more information about with whom the social media providers share your personal data in the privacy policy of each provider. The social media providers may transfer your personal data to recipients outside the EU/EEA in accordance with applicable data protection legislation. You can read more in the individual providers' privacy policies.
6. If you're applying for a job at Lindbergh
If you apply for a job at Lindbergh via our recruitment portal, you can read more about our processing of your personal data in connection with the recruitment process in this section.
We recommend that your application does not include a social security number or sensitive personal data, such as personal data that reveals racial or ethnic background, religion, union membership, sexuality or health information.
Types of personal data
Lindbergh may collect, process and store the following types of personal data about you:
- Contact details such as name, email address and phone number
- Information that appears in the application, CV and any attachments
- Relevant information that is publicly available on the internet and social media, especially information about previous employment, activities, competences, performance and general appearance
- Results of personality tests, if you take them
- Criminal record, if required for the position you have applied for
- References from previous and/or current employers that you have provided in your application or that you have consented to us contacting
Purpose of processing
Your personal data will be used to assess whether we wish to offer you a position at Lindbergh.
Treatment basics
Lindbergh processes your personal data on one or more of the following bases:
- We process your personal data on the basis of our legitimate interest in assessing whether we wish to offer you employment, including on the basis of relevant information publicly available on the internet and social media (Article 6(1)(f) of the GDPR).
- If we wish to obtain references from previous and/or current employers that you have not listed as references in your application, we will only do so if we have your consent (Article 6(1)(a) of the General Data Protection Regulation). If we need to see your criminal record as part of our assessment, we will ask for your consent (Article 8(3) of the Data Protection Act).
Storage period
If we can offer you a position at Lindbergh, your application and other relevant personal data collected during the recruitment process will be stored in your personal file with us.
If we unfortunately cannot offer you a position, we will store your personal data for up to 6 months after our rejection, unless you have given your consent for longer storage.
You may at any time withdraw any consent you may have given as part of our recruitment procedure. Withdrawal of your consent will have an effect on the future processing of your personal data, but will not affect the lawfulness of the processing based on the consent before the withdrawal. If you wish to withdraw your consent, please contact us as indicated below.
Criminal records are deleted immediately after we have reviewed them.
7. If you use our whistleblower programme
The purpose of our whistleblowing programme
Suspicions of misconduct and violations of applicable law or internal guidelines can be reported via our whistleblower scheme.
When a report is made, we will process personal data of the data subjects who are part of the report (i.e. the sender of the report, the reported person and other third parties involved) for the purpose of handling and investigating the report.
If you report a suspected infringement, such report will remain confidential and, at your option, anonymous. However, you should in any case provide an email address where you can be contacted, as we may need to obtain additional information about the offence in order to properly handle the matter.
Types of personal data
We may process the following personal data about the reported person:
- Name, position, contact details and reported information
- Description of the alleged offence
The following personal data may be processed about other third parties mentioned in the report:
- Name, position, contact details and other reported information
The purposes of the processing
Your personal data is processed for the following purposes:
- Administration of the whistleblower programme
- Handling reported incidents, including clarification of potential criminal offences
Treatment basics
Lindbergh processes personal data on the following basis.
- We may process your personal data on the basis of our legitimate interests in investigating reported matters (Article 6(1)(f) of the GDPR).
- As Lindbergh is required by law to have a whistleblower scheme, we process the personal data to fulfil our legal obligation (Article 6(1)(c) of the GDPR).
Storage period
We store the personal data for as long as necessary to be able to handle the specific reports.
8. Disclosure to other controllers and transfer to processors
In order to fulfil the above purposes, we may give third parties access to your personal data who, based on a contractual relationship with Lindbergh, provide relevant services. These may be, for example, IT suppliers, mail and marketing providers and IT solution providers. Such service providers will only process personal data in accordance with our instructions under data processing agreements.
As described in the previous sections, Lindbergh may also disclose your personal data to partners in areas such as social media, advertising and analytics. The purpose of the disclosure is to target and personalise the marketing to you via our or third parties' websites.
In connection with Lindbergh's development, the company structure may change, e.g. through a full or partial sale of the company. In the event of a partial transfer of assets containing personal data, the legal basis for the related transfer of personal data is generally Article 6(1)(f) of the GDPR, as Lindbergh has a legitimate interest in transferring parts of its assets and making commercial changes.
As a general rule, your personal data will not be disclosed to a third party without your permission, except as described above. However, under certain circumstances and in accordance with the law (Article 6(1)(c) of the General Data Protection Regulation), it may be necessary to disclose your personal data to: the police, lawyers, auditors, the courts, public authorities and potential buyers.
If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA that do not have an adequate level of protection, such transfer will be based on the EU Commission's standard contracts or another lawful basis for transfer in accordance with Chapter V of the General Data Protection Regulation. If you have any questions or want to know more about specific transfers, including the transfer basis, you are always welcome to contact us by e-mail: [email protected].
9. Your rights
- You have the right to access the personal data we process about you
- You have the right to object to our collection and further processing of your personal data
- You have the right to rectification and erasure of your personal data, subject to certain statutory exceptions, including the Bookkeeping Act
- You have the right to request us to restrict the processing of your personal data
- Under certain circumstances, you may also request to receive a copy of your personal data as well as the transmission of the personal data you have provided to us to another data controller (data portability)
- You can revoke any consent you may have given at any time. We will then delete your personal data unless we can continue processing on another basis. You can unsubscribe from our newsletter by clicking the link at the bottom of the newsletter
10. Links to other websites etc.
Our website may contain links to other websites or to integrated websites. We are not responsible for the content of other companies' websites or for their personal data processing practices. When visiting other websites, you are encouraged to read the owner's privacy policy and other relevant policies.
11. Questions and complaints
If you have any questions about this privacy policy or if you wish to complain about our processing of your personal data, you can always contact Lindbergh by email or phone as indicated below.
PWT Group A/S
CVR no. 31081610
Gøteborgvej 15-17
9200 Aalborg SV
E-mail: [email protected]
Phone: +45 72 45 44 43
If your complaint is not resolved by us and you want to take the matter further, you can complain to the Danish Data Protection Agency. You can find the Danish Data Protection Agency's contact details via this link and alternatively you can write to: [email protected].
Updated on 11.1.2023