Privacy Policy
At Sophie Bille Brahe ApS (”Sophie Bille Brahe”, ”we”, ”us” or ”our”) confidentiality and data protection is a high priority. This privacy policy sets out the guidelines for Sophie Bille Brahe’s processing of your personal data and provides you with the information you have the right to receive according to applicable data protection law. You must read the privacy policy before submitting your personal data to Sophie Bille Brahe.
Data controller and contact information
The data controller for your personal data is:
Sophie Bille Brahe ApS
Hovedvagtsgade 8, 2. floor
1103 Copenhagen
Denmark
Company registration no.: 33971087
1. If you visit our website
This section sets out the policy of Sophie Bille Brahe’s processing of personal data regarding users of Sophie Bille Brahe’s website www.sophiebillebrahe.com.
1.1 Cookies
Types of personal data
Sophie Bille Brahe uses cookies on our website and applications. Sophie Bille Brahe may collect, process and store the following personal data about you via cookies when you visit our website or applications:
- IP address
- Hardware, software and internet browser used to access our website
- Date and time of your access to our website or applications
- Time zone
- Preferences and click behaviour
- Browsing history
We use cookies to collect the personal data stated above. You can find more information regarding our use of cookies in our cookie information banner on our website.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Promotional marketing in general
- Product and service development
- Statistics and analysis
Legal basis
Sophie Bille Brahe will mainly process your personal data based on the following legal basis:
- Legitimate interests: The processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis, marketing activities (where consent is not required), as well as improving and developing our products and services (Article 6 (1) (f) of the GDPR).
- Consent: In some cases, we need your consent, e.g. in order for us to place cookies on your devices (Article 6 (1)(a) of the GDPR).
Retention period
Your personal data will be deleted when it is no longer needed for one or more of the purposes mentioned above. Please refer to our cookie information banner on our website for information about the expiry of cookies placed on your device.
The personal data may, however, be processed and stored for a longer period of time if anonymised.
1.2 Chat, booking of private appointments and other inquiries
Types of personal data
When you use the chat window, the form for booking of private appointments or other contact forms on our website or otherwise contact or communicate with us, Sophie Bille Brahe collects, processes and stores the following personal data about you:
- Name, email address, phone number
- What your inquiry or the communication concerns
- Date and time of your inquiry
- Other personal data you submit as part of your inquiry or communication with us. We recommend that you do not submit sensitive personal data, unless it is strictly necessary in relation to your inquiry. If you submit sensitive or otherwise confidential personal data by email, we recommend that you use encryption.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Handling of your inquiry
- General communication with you
- Marketing in general
- Customer service
- Statistics and analysis
Legal basis
Sophie Bille Brahe will mainly process your personal data based on one or more of the following legal bases:
- Legitimate interests: The processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis and developing our products and services as well as our legitimate interest in promoting our brand and sending marketing material (where consent is not required) (Article 6 (1) (f) of the GDPR).
- Contractual obligation: If your inquiry concerns conclusion of a (potential) contract with Sophie Bille Brahe, we process your personal data to make arrangements prior to the conclusion of the contract (Article 6 (1) (b) of the GDPR).
Retention period
Your personal data will be kept for 2 years from your last inquiry.
Anonymized personal data may, however, be kept for a longer period of time.
If you are a customer or employed with one of our business partners, we refer to section 2 and 4 below.
2. Customers
Types of personal data
When you purchase an item from Sophie Bille Brahe, we collect, process and store the following personal data about you:
- Contact information such as name, email address, address and phone number
- Billing address and shipping address
- Payment information (including credit card information)
- Order number
- Time and date of your purchase
- Information about your order, such as which items you have purchased or any special remarks you have submitted in relation to your order, e.g. a personal card or engraving
- Delivery information, such as when your purchased items were delivered
- Order/purchase history
- Whether you return the purchased items and, if so, when you return them
- Complaints or notices of defects
Purposes of the processing
Your personal data may be processed for the following purposes:
- Fulfillment of orders
- Customer service
- Marketing in general
- Statistics and analytics
Legal basis
Sophie Bille Brahe will mainly process your personal data based on one or more of the following legal bases:
- Legitimate interests: The processing of your personal data will be based on our legitimate interest in providing customer service, conducting statistics and analysis for developing our products and services as well as our legitimate interest in promoting our brand and sending marketing material (where consent is not required) (Article 6 (1) (f) of the GDPR).
- Contractual obligation: We process your personal data to fulfill the order you have placed with Sophie Bille Brahe (Article 6 (1) (b) of the GDPR).
Retention period
Your personal data will be kept for 3 years from your last purchase.
Any personal data included in bookkeeping records will be stored for 5 years as from expiry of the financial year at which time the data will be deleted. The storage period has been determined on the basis of the storage requirements laid down in s. 10 of the Consolidated Bookkeeping Act and, consequently, with a view to complying with applicable law.
Anonymized personal data may, however, be kept for a longer period of time.
3. If you subscribe to our newsletter or other marketing material
This section sets out the policy for Sophie Bille Brahe’s processing of personal data when you have subscribed to our newsletter or other marketing material.
Types of personal data
When you subscribe to our newsletter or other marketing material, Sophie Bille Brahe collects, processes and stores the following personal data about you:
- Name and email address
- Your consent
- Your click behaviour in relation to marketing material we have sent you
- IP address
- Which items you may have abandoned in the webshop basket
Purposes of the processing
Your personal data may be processed for the following purposes:
- Promotional marketing
- Statistics and analysis
Legal basis
Sophie Bille Brahe will process your personal data based on one or more of the following legal bases:
- Consent: Sophie Bille Brahe will only use your personal data in order to send you product information, newsletters and other marketing material if you have provided your prior and explicit consent hereto (Article 6 (1) (a) of the GDPR).
- Legitimate interests: The processing of your personal data for statistics and analysis will be based on our legitimate interest in improving and developing our products and services (Article 6 (1) (f) of the GDPR).
Retention period
Your personal data will be retained for as long as your consent to receive newsletters is active.
You may revoke your consent by clicking the unsubscribe link in the bottom of each e-mail or by contacting us as described below. The revocation of your consent does not affect the legality of the processing prior to the withdrawal.
The documentation for your marketing consent will be kept for two years after revocation. This retention period is based on Sophie Bille Brahe’s legitimate interest in being able to document that direct marketing activities have been carried out in compliance with applicable legislation (Article 6 (1) (f) of the GDPR).
Anonymized personal data may be kept for a longer period of time.
4. Private Client Relations
This privacy policy applies for our processing of personal data in relation to private client relations marketing.
Types of personal data
Sophie Bille Brahe collects, processes, and stores your personal data for marketing purposes when you sign up for our private client relations marketing material. Sophie Bille Brahe may collect, pro-cess, and store the following types of your personal data:
- Name, phone number and email address
- Age and gender
- Purchase history
- Private appointment history
- Ring size(s)
- Preferences and wish list
- Special occasions such as birthdays and anniversaries
- Your consent
- Your click-behaviour in relation to published material
- IP address
We will obtain from your order history, your interaction with our marketing material, our correspond-ence and during private appointments.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Marketing and personal service in regard to care and maintenance of your purchases, guidance on styling and purchases, wish lists and sizes
- Analytics and statistics
- Documentation of your consent
Legal basis
Sophie Bille Brahe processes your personal data on one or more of the following grounds:
- Consent: Sophie Bille Brahe processes your personal data for direct marketing and profiling, including for sending out newsletters, if you have given your prior and explicit consent to this (Article 6(1)(a) of the General Data Protection Regulation).
- Legitimate interests: The processing of your personal data will, in connection with documentation of your consent and analysis 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 is active.
You can always withdraw your consent by clicking on the unsubscribe link at the bottom of each email or by contacting us as described below. However, withdrawing your consent does not affect the legality of the processing that preceded the withdrawal.
Documentation of your marketing consent is kept for 2 years from the time you have withdrawn your consent to receive direct marketing material. The retention period is determined based on Sophie Bille Brahe's legitimate interest in being able to document that direct marketing has been carried out in accordance with the applicable legislation (Article 6(1)(f) of the General Data Protection Regulation).
In addition, the information can be stored for a longer period in anonymised form.
Profiling
If you have provided your consent to receiving customized marketing material as described in this privacy policy, Sophie Bille Brahe may make use of profiling, meaning that Sophie Bille Brahe may organise marketing material for you for it to consider preferences and interests that you have indicat-ed, e.g. on the basis of information on click behaviour, previous purchases, age, gender and special occasions such as birthdays and anniversaries. The profiling will affect the marketing material you receive from Sophie Bille Brahe, as the purpose of such profiling is to target you and your interests and needs in the best possible way.
5. Contact persons at suppliers and other business partners
This section sets out the policy for Sophie Bille Brahe’s processing of personal data collected from owners of sole proprietorships or contact persons at suppliers and other business partners who collaborate with Sophie Bille Brahe.
Collection of personal data
Sophie Bille Brahe may collect, process and store personal data about you in the following instances:
- When your company or the company you are employed with enters into an agreement with Sophie Bille Brahe
- When you have shown an interest in Sophie Bille Brahe, e.g., by providing your business card to Sophie Bille Brahe
- When you collaborate and communicate with Sophie Bille Brahe
Types of personal data
Sophie Bille Brahe may collect, process and store the following personal data:
- Name, email address, telephone number and similar identification data
- Individual data, such as preferred language and home country
- Organizational data, such as company name, company address, job position, business area, primary work location and country
- Contractual data, such as purchase orders, invoices, contracts and other agreements between your company (or your employer) and Sophie Bille Brahe, that may include e.g., your contact information
- Any feedback you provide if you participate in surveys or similar
- Financial data, such as payment terms and bank account details
Such information may be provided directly by you (primarily via emails and other correspondence) or by a third party such as your employer.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Generally, to plan, perform and manage the business relationship, including any contracts
- Administration, such as processing payments, evaluation of credit ratings, performing accounting, auditing, and billing
- Completion of requests received from you
- General communication
- Statistics and analytics
- Marketing
- Market research
- Dispute handling
Legal basis
Sophie Bille Brahe will mainly process your personal data based on the following legal bases:
- Contractual obligation: The processing of your personal data will in some cases be necessary for the performance of a contract (Article 6 (1) (b) of the GDPR).
- Legitimate interests: We may process your personal data pursuant to our legitimate interest in, for instance, to manage daily operations according to lawful and fair business practices, including planning, performing and managing the business relationship or our legitimate interest in e.g. statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services. The processing may also be necessary for our legitimate interests in preventing fraud or establish, exercise, or defend legal claims (Article 6 (1) (f) of the GDPR).
- Legal obligation: The processing of your personal data will in some cases be necessary to comply with legal obligations, such as our obligations to prevent illegal activity (Article 6 (1) (c) of the GDPR).
Retention period
Your personal data will be retained for 3 years from the end of the business relationship.
Any personal data included in bookkeeping records will be stored for 5 years as from expiry of the financial year at which time the data will be deleted. The storage period has been determined on the basis of the storage requirements laid down in s. 10 of the Consolidated Bookkeeping Act and, consequently, with a view to complying with applicable law.
Anonymized personal data may be kept for a longer period of time.
6. If you apply for a job
This section sets out the policy for Sophie Bille Brahe’s processing of personal data in relation to recruitment.
Types of personal data
Sophie Bille Brahe may collect, process, and store the following personal data:
- Personal data which you have disclosed in your job application and CV as well as any attachments
- Personal data you disclose during any job interviews
- Information about you, including information regarding your previous jobs, activities, competencies, performance, as well as your general appearance, which is publicly available on the internet, including on social media
- Results of personality tests etc.
- Criminal records
- References from your previous and/or current employers
- Credit information and rating if the position you have applied for involves financial responsibilities (e.g., bookkeeping or accounting)
- Health information if the position you have applied for demands special requirements for your health
Purposes of the processing
- Your personal data will be processed for the purpose of assessing whether we can offer you a position.
Legal basis
Sophie Bille Brahe will mainly process your personal data based on the following legal bases:
- Request to enter into an employment contract with us: We may process your personal data on the basis of your request to enter into an employment contract with Sophie Bille Brahe (Article 6 (1) (b) of the GDPR).
- Legitimate interests: We may process your personal data on the basis of our legitimate interests in carrying out further assessments of whether we want to hire you, including on the basis of personality tests, publicly available information on the internet and – if the position entails a financial responsibility - credit information and rating (Article 6 (1) (f) of the GDPR).
- Consent: In exceptional cases and only when no other legal basis can be applied, Sophie Bille Brahe may ask separately for your consent to process your personal data (Article 6 (1) (a) and 9 (2) (a) of the GDPR and s. 8 (3) of the Danish Data Protection Act). Sophie Bille Brahe will, for instance, only take references from your previous and/or current employers or collect your health information or criminal records if you have consented to this.
Retention period
If you are offered a position with Sophie Bille Brahe, 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 obtained 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.
If we have collected your criminal records, we will delete them immediately after we have received and reviewed them.
7. If you visit our profiles or fan pages on social media
This section sets out the policy for Sophie Bille Brahe’s processing of personal data collected via Sophie Bille Brahe’s profiles or fan pages on social media.
Sophie Bille Brahe and the providers of social media are joint data controllers for the processing of your personal data collected when you visit Sophie Bille Brahe’s profile or fan pages on social media. Sophie Bille Brahe complies with the guidelines of the European supervisory authorities concerning joint data controllership and, using the applicable tools the best way possible, Sophie Bille Brahe attempts to ensure that you receive information on the processing of your personal data when you visit Sophie Bille Brahe’s profiles or fan pages on social media.
Sophie Bille Brahe has profiles or fan pages on the following social media:
- Facebook and Instagram (Facebook Ireland Ltd.)
- YouTube (Google LLC)
- LinkedIn (LinkedIn Ireland Unlimited Company)
- Pinterest (Pinterest Europe Ltd.)
- Pinterest’s privacy policy is available here
- Manage your privacy settings on Pinterest in “privacy settings” under “settings”
- Vimeo (Vimeo.com, Inc.)
Collection of personal data
Depending on your conduct on the social media, Sophie Bille Brahe and the provider of the social media in question may retrieve the following personal data about you:
- Your "likes" or other reactions expressed on Sophie Bille Brahe’s profile or fan page
- Comments left by you on Sophie Bille Brahe’s profile or fan page
- Your visits to Sophie Bille Brahe’s profile or fan page
- Age, gender, relationship status, place of work, lifestyle, geographical information and fields of interest
Purpose of the processing
Sophie Bille Brahe may process your personal data for the following purposes:
- To communicate with you if you comment on our posts or send us a direct message
- Improve our products and services, including our profiles and fan pages on social media
- Statistics and analytics
Legal basis
Sophie Bille Brahe will mainly process your personal data based on the following legal bases:
- Legitimate interests: We may process your personal data on the basis of our legitimate interests in being able to improve Sophie Bille Brahe’s products and services (Article 6 (1) (f) of the GDPR).
The providers of the social media process, among other things, your personal data to enable them to improve their advertisement system and to provide Sophie Bille Brahe with statistics, which the provider, for example, works out on the basis of your visit to Sophie Bille Brahe’s profile or fan page on the social media in question, with a view to advertising and customising the activities on the profile or fan page. The providers of the social media process your personal data as a consequence of their legitimate interests, including their interest in providing innovative, customised, secure and profitable services (Article 6 (1) (f) of the GDPR).
- Consent: The providers of social media may also processes your personal data in accordance with your consent, which you are entitled to withdraw at any point in time via the settings on the website of the social media in question (Article 6 (1) (a) of the GDPR).
Retention period
Your personal data will be retained by Sophie Bille Brahe for two years from your interaction with Sophie Bille Brahe on social media. Sophie Bille Brahe does not delete reviews, comments, likes or other interactions you leave publicly on our profiles and fan pages. You may delete such expressions or interactions by removing your review, comment, like or other interaction from our profile or fan page.
Please refer to the privacy policy of the provider of the relevant social media for information on their retention of your personal data.
Anonymized personal data may be kept for a longer period of time.
Who do providers of social media share your personal data with?
The providers of social media may, among other things, share your personal data with the following categories of recipients:
- Other undertakings in the group which the provider of the social media in question is a part of
- Externally with partners providing analytical services
- Advertisers
- Other individuals using our profile or fan page on the social media in question
- Surveying partners
- Researchers and academics
For more information on the parties with whom the providers of social media share your personal data, we refer to the providers’ general privacy policies.
Your personal data may be transferred by the providers of social media to recipients outside the EU/EEA in accordance with the European data protection standards applicable from time to time. You may read more in the providers of social media’s general privacy policies.
For information of who Sophie Bille Brahe shares your personal with, please refer to section 7 below.
8. If you visit our physical locations
This section sets out the policy for Sophie Bille Brahe’s processing of personal data collected from video surveillance when visiting our physical locations.
Collection of personal data
Sophie Bille Brahe has installed video surveillance in certain areas of our locations, such as the entrances to our premises, our showroom and back stairs. These areas are clearly marked with signs.
The video surveillance is monitored (live streaming) by Sophie Bille Brahe’s customer service team and is recorded. Recordings which will only be accessed in case of suspicion of criminal offences, violation og internal guidelines or in relation to internal/external audits.
The recordings may be disclosed to the Police for criminal investigations if the personal data are processed for the purpose of safeguarding public or private interests which clearly override the interests of secrecy, cf. Article 6(1)(f) of the GDPR or if the disclosure is otherwise required by law, cf. Article 6(1)(c) of the GDPR. If disclosure is necessary for other purposes than the above mentioned, we will ask you to consent to such disclosure if you are part of the recordings, cf. Article 6(1)(a) of the GDPR.
Types of personal data
- Image and audio material from the video surveillance.
- Location of the camera
- Date and time of the recording
Purposes and legal basis of the processing
The purpose of the video surveillance is security, including prevention of crime, and to ensure safety for our employees and third parties, and compliance of our internal rules, cf. Article 6 (1) (f) of the GDPR.
Retention period
Recordings from video surveillance which has been conducted for the purposes of preventing crime are deleted or anonymized no later than 30 days after the recording has taken place, unless is it necessary for Sophie Bille Brahe to keep the recordings for the purpose of dealing with a specific dispute, e.g. in relation to solving a crime.
9. Disclosure to other data controllers and sharing with data processors
To fulfil the purposes described above we may provide access to your personal data for third parties who, on the basis of a contractual relationship with Sophie Bille Brahe, provide relevant services, e.g. IT-providers, email providers and marketing providers. Such service providers will only process personal data in accordance with our instructions pursuant to the data processor agreements entered into.
In connection with Sophie Bille Brahe’s development, the company structure may change, e.g. through a full or partial sale of Sophie Bille Brahe. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, as a general rule, Article 6 (1) (f) of the GDPR, as Sophie Bille Brahe has a legitimate interest in handing over part of its assets as well as making commercial changes.
Aside from above, it is a general rule that your personal data is not disclosed to a third party without your permission. However, under certain circumstances and in accordance with applicable law, we may need to disclose your personal data to
- Police
- Lawyers
- Auditors
- Courts
- Public authorities
- Prospective buyers
- Affiliated companies
If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA which does not have an adequate level of protection, such transfer will be based on the EU Commission’s standard contracts or binding corporate rules.
10. 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 have your personal data rectified and deleted, with 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 your personal data which you have provided us with to another data controller (data portability)
- You may, at all times, withdraw any consent you may have given. We will then delete your personal data, unless we can continue the processing on another basis. Our newsletter can be unsubscribed by clicking the link at the bottom of the newsletter
11. Questions or complaints
If you have any questions in relation to this privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us:
Sophie Bille Brahe ApS
Hovedvagtsgade 8, 2. floor
1103 Copenhagen K
Denmark
Email: info@sophiebillebrahe.com
If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to the supervisory authority in your country. A list of European supervisory authorities is available here.
12. Changes to the privacy policy
We reserve the right to make changes to this privacy policy from time to time. When updated, the date at the bottom of the privacy policy will be updated accordingly. The, at all times, applicable privacy policy will be available at our website.
November 2, 2022.