Politica sulla privacy

Updated: December 2023

You are using a platform for the mediation of holiday homes (hereafter "Platform"), owned by Landfolk A/S, business registration number 42074640, Bülowsgade 68, 3 tv, 8000 Aarhus C (hereafter "Landfolk", "us", "we", "our"). Landfolk is the data controller for the processing of the personal data we have received about you.

Categories of Personal Information We Process and the Legal Basis

Below you will find a description of which personal information we will collect about you and how we process them. You can also read more about your rights in this regard. The personal data are necessary for managing your user profile, and for us to be able to service you. We will only store your information for as long as necessary to fulfil the purposes for which it was collected, or to comply with legal requirements.

Management of Your User Profile and Mediation of Agreement

To manage your user profile and to mediate the agreement, we collect information about you that you provide when you create or manage your user profile, including but not limited to:

• Your name
• Your contact details, including your home address, email address, and phone number, as well as SoMe information (e.g., links to Instagram accounts)
• Your login information, including your username and password
• Information about the holiday home being rented out on the Platform, including the address and property number (consisting of a 3-digit municipality code followed by a running number of up to 6 digits)
• Information contained in any images or other content that the landlord themselves uploads to the Platform, or which we have taken of the landlord and holiday home by agreement
• Information about booking(s), including the date of booking, duration of booking, information about the holiday home, payment details, etc.
• The information you provide us when you communicate directly with Landfolk or other users of the Platform, including tenants/landlords, via our messaging center.

The above information is processed on the basis of our legitimate interest in managing the user accounts created, handling your inquiries, and to conduct statistics and analysis so that we can improve the user experience, cf. GDPR Article 6(1)(f). We also process your information to fulfill our contract with you, cf. GDPR Article 6(1)(b).

Your personal data is stored for up to 30 days after your Landfolk user profile is deleted.

Information relating to a concluded agreement, including bookings of holiday homes, is however stored for a period of 3 years after the agreement was made due to statute of limitations, after which they are anonymized.

We also process the above information about bookings in connection with billing, so we can fulfil our legal obligations according to the accounting law, cf. GDPR Article 6(1)(c). Accounting material (including name, address and booking information) included in invoices is securely stored for 5 years from the end of the year to which the accounting material relates, cf. the accounting law § 12.

In specific cases, we may store your personal data longer if otherwise required by law or if necessary to establish, exercise, or defend a legal claim.

Targeted Marketing

If you have given us your consent, we process personal data associated with your user profile with the aim of sending you offers, news, and inspiration from the Landfolk Universe as well as perform profiling so we can better target the content of our correspondence to your interests, cf. GDPR Article 6(1)(a).

For this purpose, we process the information mentioned above under the point "Management of Your User Profile and Mediation of Agreement" as well as:

• Information about your behavior on our Platform, including click and search behavior
• Reviews that you create on our Platform.

We store the above information until you withdraw your consent, and you can withdraw your consent at any time. If you withdraw your consent, however, we will store documentation for your consent for 5 years after the withdrawal in consideration of the statute of limitations.

Newsletters

If you sign up for our newsletter, you give us consent to be able to send you news, information about summer houses and services, invitations to events, etc. The newsletter is sent out 1-2 times a week.

Along with your consent to receive our newsletter, you provide your email address, your first name, and possibly whether you are a summer house owner. The purpose of the processing is marketing and analysis and statistics. The legal basis for processing your personal data in relation to direct marketing is your consent, cf. GDPR article 6(1)(a).

Our newsletter provider stores your data until you ask us to delete your data.

Social Media

We use social media such as Instagram, Facebook, Pinterest, LinkedIn, and our podcast Summerhouse Life for marketing and to create a community where photo/video and content about Landfolk, Landfolk's summer houses, hosts/guests, and summer house life can be shared.

We have profiles or pages on the following social media:

• Facebook (Meta Platforms Ireland Ltd.)
  • Facebook's privacy policy is available here
• YouTube (Google Ireland Ltd.)
  • Google's privacy policy is available here
• LinkedIn (LinkedIn Ireland Unlimited Company)
  • LinkedIn's privacy policy is available here
• Instagram (Meta Platforms Ireland Ltd.)
  • Instagram's privacy policy is available here
• Pinterest (Pinterest Europe Ltd.)
  • Pinterest's privacy policy is available here

For LinkedIn, Facebook, Instagram, and Pinterest, we are joint data controllers with the providers of the social media for the processing of personal data collected in connection with your interactions with the profiles, including the profile posts.

Landfolk and the providers of LinkedIn, Facebook, Instagram, and Pinterest have entered into an agreement for the distribution of data protection related tasks. According to these agreements, Landfolk and the providers of the social media each stand for the tasks associated with the processing we each perform. However, it has been agreed between us and the provider of Facebook and Instagram that the provider is responsible for enabling you to exercise your rights as described in the 'Your rights' section below, in connection with the use of Facebook and Instagram, and that it is us who are responsible for giving you the information described below. It is further agreed between us and LinkedIn that LinkedIn is responsible for responding to requests from you regarding the rights described in the 'Your rights' section below.

We also use the provider of YouTube as a data processor in connection with these entities' use of YouTube and share certain information about your interactions, interests, etc., with YouTube. This sharing takes place based on our and Google's legitimate interest in optimizing marketing and the service, including our videos, on YouTube, cf. GDPR Article 6(1)(f).

The information that we and the provider of the social media collect is:

• Information that is available on your profile, including your name, gender, marital status, workplace, interests, picture, and your city
• Whether you "like" or have used other reactions to our profile
• Comments you leave on our posts
• That you have visited our profile
• Your IP address

When we process your personal data, the basis is primarily our interest in providing you with the best possible service, such as responding to your inquiries to us on social media, as well as promoting our business through marketing, cf. GDPR Article 6(1)(f).

For the production and distribution of content for podcasts, social media, videos, etc., consent is given for participation, cf. GDPR Article 6(1)(a). We may also base other parts of the processing, e.g., sharing of personal data with social media, on your consent, cf. GDPR Article 6(1)(a).

Our purpose in processing your personal data is to be able to communicate with you if you comment on a post, make a review or send us a message, as well as for the improvement of our services, including our profiles and pages on social media, statistics and analysis, and general marketing.

The providers of social media process, among other things, your personal data for purposes such as improving the ad system, advertising, and customization, and to give us statistics which the providers of social media partly prepare based on your visit to our profiles and pages. The providers base their processing of personal data on their legitimate interests, cf. GDPR Article 6(1)(f) and your consent, cf. GDPR Article 6(1)(a). You can read more about this in the privacy policies of the providers.

Your personal data will be stored for 30 days from the time you ask us to delete your data. However, the information may be stored longer in anonymized form. Please see the privacy policy of the provider of the individual social media for information on how long they store your personal data.

Who do social media providers share your personal data with?

Providers of social media may share your personal data with the following categories of recipients, among others:

• Other entities in the group to which the provider of the social media belongs
• External collaborative partners that provide analysis and survey services
• Advertisers
• Other individuals who visit our profile or page on the social media (to the extent your information is publicly available)
• Researchers and other academics

You can find more information about who the providers of social media share your personal data with in the individual provider's privacy policy.

Providers of social media may transfer your personal data to recipients outside the EU/EEA in accordance with applicable data protection legislation. You can read more in the privacy policies of the individual providers.

You can read more about who we share your personal data with in the section How we process your personal data below.

Suppliers and Partners

This section contains the policy for our processing of personal data about owners of sole proprietorships or contact persons at suppliers and other partners working with us.

We process personal information when your company or the company you work for enters into an agreement with us or when you collaborate or communicate with us. The personal data we process include contact information, individual information such as preferred language, organizational information such as the company's name and address, job title, and contractual information such as agreements between your company or employer and us that may contain, for example, your contact information. Such information can be received directly from you (mainly through emails and other correspondence with you) or from a third party such as your employer.

The purpose of this processing is general planning, fulfillment, and management of collaborations, including contracts and general communication. We process personal data on the basis of one or several grounds in order to fulfill our contractual obligations, cf. GDPR Article 6(1)(b), our legitimate interests, for example, to manage day-to-day operations in accordance with legal and fair business practices, including planning, execution, and management of the collaboration, cf. GDPR Article 6(1)(f), as well as our fulfillment of legal obligations, cf. GDPR Article 6(1)(c).

Your personal data is stored for 30 days from the time you ask us to delete your data. However, the information may be stored longer in anonymized form.

Statistics and Analysis for Improving your Experience and our Platform

When you visit our website, we use cookies. We process your personal data with the objective of creating statistics and analyses that enable us to improve your user experience of Landfolk as well as our Platform and target marketing.

For this purpose, we process:

• Your IP address
• Your browsing history
• Information about your behavior on our Platform, including click and search behavior

We use cookies to collect the above personal data. You can read more about the use of cookies in our cookie banner.

Our processing is based on our legitimate interest in conducting statistics, analysis, providing support, and marketing ourselves to you cf. GDPR Article 6(1)(f). When you visit our website, we ask for your informed consent to place non-functional cookies, cf. GDPR Article 6(1)(a), in accordance with the cookie rules. You have the right to withdraw your cookie consent at any time.

Cookies are deleted in accordance with our cookie policy, which is available through our cookie banner. However, the information may be stored longer in anonymized form.

We also process the personal data that you provide us in connection with participation in our surveys and satisfaction surveys in order to improve our Platform. Depending on the content of the inquiry, we process your personal data for the purpose of creating statistics and analyses that enable us to improve your user experience of Landfolk and our Platform, cf. GDPR Article 6(1)(f), or to market our services, cf. GDPR Article 6(1)(a).

For this purpose, we process the information mentioned above under the point "Targeted marketing" as well as:

• The information you provide us about your customer experience in questionnaires and satisfaction surveys.

If You Use the Chat Function or Otherwise Communicate with Us:

When you use the chat function or otherwise communicate with us, we collect and process your personal data.

We process your information to be able to handle your inquiry and for general communication. The basis for our processing depends on the nature of your inquiry. We may process your personal data based on our legitimate interests in handling your inquiry, communicating with you, and developing our services, cf. GDPR Article 6(1)(f).

For these purposes, we process:

• Your name and email address
• The subject of your inquiry
• The date of your inquiry
• Other information you provide in connection with your inquiry.

We urge you not to submit sensitive personal data to us unless they are strictly necessary for the processing of your inquiry. In this context, the information should only be sent in a strongly encrypted form if you submit the information via email.

Our provider of the chat function stores your personal data for 9 months from your last visit to our website. However, the information may be stored longer in anonymized form.

Job Applications

If you send an application to us, or connect with us via the job page on our website, you will provide us with some information about yourself, including but not limited to name, home address, phone number, email address, CV, and photo. We recommend that your application does not contain social security numbers or sensitive personal information such as personal data revealing racial or ethnic origin, religion, union membership, sexuality or health information.

Our processing of your personal data in connection with the job application is based on our legitimate interest in processing your request for us to process your application prior to the conclusion of an employment contract, and our legitimate interest in assessing whether we wish to offer you employment, including based on the information you provide in the CV, application and any attachments and other information you provide us in connection with the recruitment process. The processing may also be necessary for our legitimate interest in defending or asserting legal claims cf. GDPR Article 6(1)(f).

If you are offered a position with us, your application and additional relevant personal data collected during the employment procedure will be stored in your personnel folder with us.

If you are not offered a position with us, your application or created connection will be deleted after 6 months unless you consent to storage for a longer period.

You can withdraw any consents you may have given as part of our recruitment process at any time. Withdrawal of your consent will have an effect on the future processing of your personal data but does not affect the legality of the processing based on the consent before the withdrawal. If you wish to withdraw your consent, please contact us as indicated below.

How We Process Your Personal Data

We will give access to your personal data to the extent it is relevant to the following categories of recipients:

• Third parties with whom you choose through our Platform that we should share your information, including your contracting party
• Affiliated companies
• Third parties that carry out cleaning of the vacation property or perform marketing activities
• Service providers who, for example, provide IT support and CRM system providers
• Professional advisors
• Public authorities including TAX insofar as it is required by law, including the law on the responsibility to report gross rental income, by court order, or where it is necessary to establish, exercise or defend our legal rights
• Other third parties if you consent to it, or if they are involved in a merger or acquisition involving all or part of our business or assets therein.

Many of these companies are data processors and process your personal data – which we are data controllers for – following our instructions. Data processors may only use the information to fulfill their agreement with us and must treat the information confidentially. We have data processing agreements with our data processors, who process personal data on our behalf.

In cases where your personal data is disclosed to third parties that are independently responsible for data (e.g., the tax authorities), then the processing will take place according to these third parties' own privacy policies, and we have no control over this. There may also be situations where information is passed on to a third party, such as our suppliers and partners performing cleaning of the vacation property. Processing of personal data to coordinate cleaning is necessary for the fulfillment of the contract, cf. GDPR Article 6(1)(b).

The personal data that we collect from you may be transferred to and stored at a destination outside the EU/EEA.

If this happens, we ensure that the processing of your personal data is still covered by an adequate level of data protection and complies with the data protection regulation. Such a transfer can only take place when a transfer basis has been secured. Furthermore, the transfer will be based on the EU-US Data Privacy Framework and/or the European Commission's standard contracts, which you have the right to receive a copy of. If you have questions about the basis for transfers to countries outside the EU/EEA please contact us as indicated below.

Your rights

Under the data protection regulations, you have certain rights, which we briefly outlined below:

• Right to information
  • You have the right to request information from us or access to your personal information. However, there are exceptions, which means you do not always receive all the information that we process.
• Right to object
  • You have the right to object to our processing of your personal data. This means you can stop or prevent us from processing your personal data. However, this only applies in certain cases, and we do not need to stop processing your personal data if we can provide legitimate reasons for continuing to process your personal data.
• Right to erasure
  • In certain cases, you have the right to request erasure of your personal data.
• Right to data portability
  • You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format by contacting us through the contact details listed below. If technically possible, you have the right to request that the personal data be transmitted directly to another company or person acting as the data controller.
• Right to rectification
  • You have the right to have inaccurate personal data about you corrected. You also have the right to have incomplete personal data completed. You can see, review, and change most of your personal data by logging in to your user profile on our website. Please update your personal data immediately if they change or are incorrect.
• Right to restriction of processing
  • In certain cases, you have the right to have the processing of your personal data restricted.

If you wish to complain about our processing of your personal data, you can file a complaint with the Data Protection Agency (Carl Jacobsens Vej 35, 2500 Valby, Tel. 33 19 32 00, mail: dt@datatilsynet.dk)

Contact Information

If you have questions about our processing of your personal data or want to exercise your rights, do not hesitate to reach out to us via support@landfolk.com.