Cookie policy

Privacy Policy

Last updated: 3 June 2022

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your Personal Data when You use Our Services and tells You about Your privacy rights and how the privacy law protects You.

We use Your Personal Data to provide and improve the Service. By using the Services, You agree to the collection and use of Personal Data in accordance with this Privacy Policy.

This Privacy Policy describes what types of Personal Data we collect, how we process the Personal Data and who you can contact if you have any questions or comments with respect to our processing of Personal Data. This Privacy Policy has been made with reference to the GDPR (General Data Protection Regulation (EU) 2016/679 (“GDPR”)) and, for Denmark, the Danish Data Protection Act (Act No. 502 of 23/05/2018) (“Data Protection Act”).

Please note that the purpose of this Privacy Policy mainly is to describe our processing of Personal Data as “Data Controller” of Personal Data. Our processing of Personal Data on behalf of customers, as “Data Processor” for such customers, is regulated by the Data Processing Agreement we enter into with customers using Our Services.

 

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Services or parts of our Services.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Applications means the software program provided by the Company downloaded and/or used by You on any electronic device, named CONSENSUS CONNECT, CONSENSUS AR or ).

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to CONSENSUS ApS, Århusgade 88, 4. København Ø, DK-2100, Denmark.

For the purpose of the GDPR, the Company is the Data Controller with respect to this Privacy Policy, however, see the initial comments above regarding Our processing of Personal Data on behalf of customers as “Data Processor”.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Denmark

Data Controller and Data Processor shall mean “controller” and “processor” respectively as defined in the GDPR. Data Processing Agreement shall mean the Data Processing Agreement entered into between the customer and the Company in connection to the customer’s use of the Services rendered by the Company.

Device means any device that can access the Services such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

Services refers to the Applications or the Website or both.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform Services related to the Services or to assist the Company in analyzing how the Services is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Third-party Social Media Services refers to any website or any social network website through which a User can log in or create an account to use the Services.

Usage Data refers to data collected automatically, either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).

Website refers to CONSENSUS-CONNECT, accessible from www.consensus.dk  

You means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Services.

 

 

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Services, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personal data includes

Email address

First name and last name

Phone number

Address, Country / State, Province, ZIP/Postal code and City

Organisation and work title

Usage Data

Financial information (bank account number, transfer of value amounts and dates, etc.)

Personal Data

Usage Data is collected automatically when using the Services.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Services by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Services or when You access the Services by or through a mobile device.

Information Collected while Using the Applications

While using Our Application, in order to provide features of Our Applications, We may collect, with Your prior permission:

  • Pictures and other information from your Device’s camera and photo library

 

If You use the Video Coach (AI) Application, the following Personal Data will be processed:

  • Video/digital recordings of speeches and presentations recorded online
  • Automated transcription of the speeches and presentations recorded online ½(using Microsoft text-to-speech technology)
  • Digital feedback
  • Automated learning score (based on pre-defined parameters, e.g. a script)
  • Analytic and statistical data based on video and audio analysis of the presentation

 

Processing of Your Personal Data related to the Video Coach (AI) Application is necessary for Us provide the services to You (the data controller) and its designated users, including real-time data driven measurements to score and certify sales representative across all lines of business

In other words, we only use this information to provide features of Our Services, to improve and customize Our Services. The information may be uploaded to the Company’s servers and/or a Services Provider’s server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

 

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Services. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Services. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Services may use Cookies.
  • Flash Cookies. Certain features of our Services may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Services. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: All About Cookies by TermsFeed.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with Services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the Services that You have asked for cannot be provided, and We only use these Cookies to provide You with those Services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

 

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Services, including to monitor the usage of our Services.

To manage Your Account: to manage Your registration as a user of the Services. The Personal Data You provide can give You access to different functionalities of the Services that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or Services You have purchased or of any other contract with Us through the Services.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted Services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, Services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Services users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, Services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Services, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, Services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Services, Your contacts on the Third-Party Social Media Services may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Services, or We are legally obligated to retain this data for longer time periods.

Upon termination of the contractual relationship with a customer or supplier, we will delete the Personal Data from the customer or supplier in question or supplier relationship as soon as it is no longer necessary to retain the applicable Personal Data. However, the fact that we may protect Your or Our interests through possible liability may involve the retention of Personal Data for 3 years (or in exceptional circumstances for a longer period) after the end of our agreement with the customer or supplier.

However, several other considerations, as well as specific rules, mean that Personal Data should not always or must not be deleted until a certain period has elapsed.

The accounting rules mean that Personal Data linked to a payment must be kept for 5 years + the current calendar year after the end of the financial year.

If Personal Data is obtained based on your consent, we will generally delete the Personal Data obtained based on consent immediately after you withdraw your consent. However, with regard to marketing, we are obliged to keep the documentation, stating that we lawfully asked for your consent, for 2 years from the latest marketing material sent to you.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Transfer of Personal Data to third countries

As a rule, Personal Data is located within the EU/EEA .

However, if it is necessary to transfer Personal Data to a third country or international organization located outside the EU/EEA, we shall ensure prior to the transfer of Personal Data to the third country or international organization that the transfer of Personal Data is carried out in a manner that constitutes sufficient guarantees that the Personal Data is protected, including, where relevant, the use of the EU Commission’s Standard Contractual Clauses on data transfers and any supplementary measures deemed necessary to protect Your Personal Data.

 

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

Security of Your Personal Data

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

We have taken the necessary technical and organizational security measures to protect your Personal Data from accidental or unlawful destruction, loss or change and from unauthorized public disclosure, misuse or other conduct in violation of applicable law.

Access to Personal Data is limited to persons who have a need for access to Personal Data. Employees who process Personal Data are instructed and trained to know what to do with Personal Data and how to protect Personal Data.

When documents (papers, filing data, etc.) with Personal Data are thrown out, shredding or other measures are used to prevent unauthorized persons from accessing Personal Data.

Passwords are used to access PCs and other electronic devices with Personal Data. Only the persons who need access will have a code and then only for the systems that he or she needs to use. Persons with access codes must not leave the code to others or leave it for other to see. Check-ups on assigned codes will be carried out at least once every six months.

If Personal Data is stored on a USB-stick, the Personal Data must be protected. For example, on a USB-stick with a password and encryption. Otherwise, the USB-stick must be stored in a locked drawer or cabinet. The same applies when storing Personal Data on other portable data media.

PC’s connected to the Internet have an updated firewall and virus control installed.

If sensitive Personal Data or Social Security number is sent by email over the Internet, such emails must be encrypted. If you send Personal Data to us by email, please be aware that this is not secure if your emails are not encrypted. We advise you to not send us confidential or sensitive Personal Data by email unless this is specifically agreed in advance so that we can ensure the necessary level of security.

In connection with the repair and Services of data equipment containing Personal Data and when data media is to be sold or discarded, we take the necessary measures to ensure that the Personal Data cannot come to the attention of unauthorized persons. For example, by using declarations of confidence.

When using an external data processer to process Personal Data, a written agreement is signed between us and the data processor. This applies, for example, when an external document is used or if cloud systems are used in the processing of Personal Data – including communication with the customer. Similarly, a written agreement is always made between us and our customers if we act as data processors. The data processing agreements are also available electronically.

Backup

We take backup of all data bases and files on shared drives. Back-up is stored on an external server.

All backup data and files are overwritten (deleted) in intervals of 30 days.

 

DATA PROCESSING ON BEHALF OF CUSTOMERS

With respect to all Personal Data entered, transferred or stored by the Company on behalf of the customers in Our databases or databases of third-party suppliers related to Our provision of the Services, the customer is the Data Controller, and We are the Data Processor.

The Company’s processing of Personal Data on behalf of the customer in relation to the Services is regulated by the Data Processing Agreement, which We enter into upon the customer’s purchase of the Services.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Services in accordance with their Privacy Policies.

We may use third-party Service providers to monitor and analyze the use of our Services, such as:

Microsoft Inc.

Azure (cloud service / hosting)

Google Analytics

Google Analytics is a web analytics Services offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google Services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. When you visit Our Website, we ask for your consent to use cookies, including cookies placed by Google Analytics.

You can also at any time opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245

For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or apps webpage: https://policies.google.com/technologies/partner-sites

AWS (Amazon Web Services)

Cloud service / hosting

AWS’ Privacy Policy can be viewed at https://aws.amazon.com/privacy/

Sendgrid/ Twilio

Their Privacy Policy can be viewed at https://www.twilio.com/legal/privacy

Wowsa Media Systems LLC

Streaming services

 

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Our legal basis for processing Personal Data lies first and foremost in Our relationship with You and in order for Us to comply with and continuously administrate Our agreement with You. As a rule, we will have the right to process the necessary Personal Data in accordance with Article 6 (1), points a-c and point f, and article 9 (2), points a and f, and sections 6 and 7 of the Danish Data Protection Act.

The above-mentioned provisions govern the basis for processing Personal Data if (i) consent has been provided by the data subject, (ii) the processing is necessary to perform Our Services under a license agreement or to take other actions at Your request, (iii) the processing is necessary to comply with a legal obligation to which the Company is subject, (iv) the processing is necessary to fulfil the legitimate interests of the Company that exceed the interests of the data subject, or (v) the processing is necessary for a legal claim to be established; claimed or defended by the Company. 

It is our assessment that the Personal Data, which We process in relation to a customer (and its users), a business partner, a supplier or a public authority will largely be provided for in the above-mentioned provisions.

 

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Services.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

In Denmark, the Data Protection Authority is the Danish Data Protection Agency (in Danish: “Datatilsynet”). See the Data Protection Agency’s website here for contact information.

 

Links to Other Websites

Our Services may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or Services.

 

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Services, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

Contact Us

If you have any questions about this Privacy Policy, You can contact us: