Privacy policy

Emballage Indberetning ApS is a producer responsibility organisation (PRO). Here we explain which personal data we process, what we use it for, who we share it with, and what rights you have.

This policy covers this website, the member portal at app.emballageindberetning.dk and our other processing of personal data as a PRO.

Who is responsible for your data

Emballage Indberetning ApS is the data controller for the personal data described here.

Emballage Indberetning ApS
CVR no.: 45304418
Nørregade 33, 3., 1165 København K
Email: info@emballageindberetning.dk
Phone: +45 42 90 11 19

When you visit the website

When a page is loaded, our supplier records ordinary technical log data, including IP address, time, which page was loaded and which browser was used. It is used for operations, troubleshooting and security. The legal basis is our legitimate interest in running a secure and functioning website (Article 6(1)(f) of the General Data Protection Regulation).

The website only sets cookies that are necessary for it to work, and they do not require consent. Our quiz pages embed a questionnaire from an external supplier, and it loads measurement tools from Google and Meta as soon as the page opens. Still no cookies are set, but your IP address and your use of the page are sent to those two suppliers, so that we can measure the effect of our advertising. If you would rather not, you can avoid opening the quiz. If we start using other cookies or similar technologies, we will update this page.

When you write or call us

If you write to info@emballageindberetning.dk or call +45 42 90 11 19, we process the information you give us yourself. That is typically name, work email, phone number, company and the content of the enquiry itself.

We use it to answer you, to follow up and to be able to find the case again if you contact us anew. The legal basis is our legitimate interest in answering enquiries (Article 6(1)(f)), or performance of the agreement with you (Article 6(1)(b)) if you are already a member.

When you are a member with us

As a PRO, we take care of your registration in the producer register (with DPA) and report on to DPA on your behalf. For that we process:

• Company information such as name, CVR number and address. It is not personal data in itself, but it is connected to the rest.
• Contact persons at your company, meaning name, job title, work email and phone number.
• User details for the member portal, meaning the email you log in with and the information that keeps your access secure.
• Reporting data, meaning the volumes you place on the Danish market, and which materials and product areas they belong to.
• Invoicing and payment details.
• Correspondence with us, including in connection with self-inspection.

Most of this follows directly from the producer responsibility rules. We cannot be your PRO without it.

Some information we do not get from you directly, but from a partner who refers you to us for the Danish part of producer responsibility. That is typically the company name and a contact person.

The information is not optional. We need it in order to report on to DPA on your behalf, and the terms and conditions oblige you to provide it on time and correctly. If it does not arrive, we may set a provisional estimate of your volumes and invoice on that basis.

What we use the information for, and on what legal basis

We do not ask for sensitive personal data and we do not use it actively. If you write it to us anyway, for example in an enquiry or a support case, we process it only as part of that case and delete it once the purpose has been met. We do not use your data for profiling or for automated decisions.

Who we pass information on to

• DPA (Dansk Producentansvar), when we register you in the producer register and report your volumes on. DPA is an independent data controller for what it receives.
• The Danish Energy Agency and other relevant authorities, when the legislation obliges us to.
• Data processors, meaning suppliers who process information on our behalf. That covers hosting of the website and the member portal, our CRM and customer dialogue system, email and IT operations, finance and invoicing, and sending newsletters. They may only use the information on our instructions, and a data processing agreement is entered into with them.

Some of our suppliers are established in the United States, and personal data is therefore transferred to countries outside the EU and the EEA. That includes our payment and invoicing system and our error monitoring. The transfers take place on the basis of the European Commission's standard contractual clauses or a decision that the country has an adequate level of protection.

How long we keep the information

We keep the information for as long as you are a member, and after that for as long as we are obliged to or have a legitimate need to.

• Bookkeeping and invoice data is kept in accordance with the bookkeeping rules, that is for 5 years from the end of the financial year the data relates to.
• Documentation of reports and self-inspection is kept for as long as the producer responsibility rules require us to be able to produce it.
• Enquiries from people who do not become members are kept only for as long as it is relevant to follow up.
• Technical log data from the website sits with our hosting and CDN supplier and is deleted according to the supplier's own deadline. We do not extract it and we do not use it for anything other than operations and security.

When there is no longer a purpose or a requirement, we delete the information.

Security

We protect the information with technical and organisational measures, and access is limited to the employees and suppliers who need it to do the job. If a personal data breach occurs, we handle it according to the rules and notify the Danish Data Protection Agency and those affected where the rules require it.

Your rights

Under the General Data Protection Regulation you have the right to:

• Access. To be told which information we hold about you, and to get a copy.
• Rectification. To have incorrect information corrected.
• Erasure. To have information deleted when we no longer have a reason to hold it.
• Restriction. To have the processing paused while something is clarified.
• Objection. To object to processing we base on legitimate interest.
• Data portability. To receive information you have given us yourself in a common format.
• Withdrawal of consent. Where we rely on consent, you can withdraw it again.

The rights belong to the individual people whose data we process, that is, typically your contact persons and portal users. They can also contact us directly themselves.

You exercise the rights by writing to info@emballageindberetning.dk. We reply as quickly as possible and no later than within one month. In complicated cases the deadline can be extended, and then we let you know within the first month. Some of the rights have exceptions, for example when the law obliges us to keep certain information. If that happens, we say so and explain why.

Complaints

If you are unhappy with how we process your information, write to us first, so we get the chance to put it right. You can always complain to Datatilsynet, the Danish Data Protection Agency. Contact details and guidance on complaining can be found at datatilsynet.dk.

Changes to the policy

If we change the policy, we update the text here and correct the date at the top. If the change is significant and affects you as a member, we let you know directly.

Contact

If you have questions about how we process your information, or you want to exercise one of your rights, write or call.

Emballage Indberetning ApS
CVR no.: 45304418
Nørregade 33, 3., 1165 København K
Email: info@emballageindberetning.dk
Phone: +45 42 90 11 19

In case of any discrepancy between the Danish and English versions, the Danish version prevails.