Effective from: 12/12/2024
PRIVACY POLICY
This Privacy Policy (the “Policy”) describes the types of information that DILLING A/S, CVR no. 218 715 83 (“Dilling,” “we,” “us,” or “our”), may collect from you or that you may provide when visiting our website, us.dilling.com or dilling.com (collectively, the "Website"). It also outlines our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Policy applies to the services (as defined below) offered through the Website, including any applications that display or link to this Policy (collectively referred to as the "Website").
PLEASE REVIEW THIS POLICY CAREFULLY, AS IT CONTAINS PROVISIONS REGARDING THE TRANSFER AND PROCESSING OF YOUR PERSONAL INFORMATION ON OUR SERVERS LOCATED IN THE EUROPEAN UNION. BY USING OUR SERVICES, YOU EXPLICITLY CONSENT TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY.
1. Information on the Processing of Personal Information
Your data security is important to us, and we are committed to handling your personal information responsibly. Below, you will find details on how we collect and process the personal information we obtain from you as a Data Controller. Additionally, you can learn about your rights concerning our processing of your personal information.
2. Dilling’s Role as a Data Controller
As part of our business operations and the provision of our services to you, we process various types of personal information to ensure the best possible experience for you. In most cases, we collect and process only standard (non-sensitive) personal information.
If you have any questions about our processing of your personal information, you can contact Dilling here:
DILLING A/S
CVR: 218 715 83
Sundsvej 62, 7400 Herning, Denmark
Contact Person:
Name: Merete P. Bilberg
Telephone: (888) 867-0221
E-mail: info@dilling.com
3. What Personal Information We Collect and Its Purpose
We collect information from and about you and your transactions and other interactions with us as outlined below. This may include, but is not limited to, when you visit our Website, social media channels, create an online account with us, make a purchase, sign up for our catalog, newsletters or email lists, participate in sweepstakes, contests or other promotions, participate in a product review, survey, or other similar programs, send a gift or gift card to a person, or otherwise contact us, including via the online chat function, or when we provide our Services (as defined below) to you.
Read more about our processing in the different situations below.
What personal information we collect
Below are the categories of personal information we may collect from you, how we process it, and the duration for which we retain each category of personal information:
Visitors to Dilling’s Websites
| Category of personal information we collect: | When you visit Dilling’s Website or use our other online services (e.g., Facebook, Instagram), we may process information related to your IP address, as well as data about your computer, device, and browser.We also collect data about your visit, including details such as how you access our websites, how you navigate them, which pages you visit, the content you view, your searches, and the advertisements you have seen. This personal information is collected through cookies, log files, and other tracking technologies. (You can read more about our use of cookies [here].)Additionally, we collect personal information you provide when using our Website or Services. This may include details submitted through our online chat, such as your name, address, phone number, email address, product interests, and any other information you choose to share with us. |
| How personal information is processed: | We collect and use your personal information to provide you with relevant products, deliveries, services, and offers (“Services”). Additionally, we use this information to enhance your experience on our Websites and Services, as well as to improve the Services we offer.We also use your personal information to personalize the content displayed on our Websites and third-party platforms based on your activities and preferences. Furthermore, we may use this data to limit the number of times you see the same content. |
| How long do we retain the personal information we collect? | We store personal information collected in connection with your visit to our Website for 24 months. |
Customer Information
| Category of personal information we collect: | When you make a purchase through Dilling’s webshop on our Website, we process personal information, including your name, age, date of birth, email address, purchase details, payment information, fraud risk analysis, shopping cart contents (including apparel size), delivery details, shipping and billing addresses, order ID, purchase history, and any other information you provide to us. |
| How personal information is processed: | We collect and process your personal information to fulfill our agreement with our customers, for delivering the Services, invoicing, keeping statistics, conducting quality management, maintaining our customer register, and providing general service, marketing, and sales to our customers. |
| How long do we retain the personal information we collect? | We store personal information about our customers for 5 years after the last contact or as long as necessary for legal reasons or to protect our interests and as permitted by law. |
Recipients of Marketing
| Category of personal information we collect: | When you receive marketing, including newsletters from Dilling, we process personal information such as your name, address, phone number, email address, and product interests.We also collect information about your preferences regarding marketing or communication, your use of the marketing we send (e.g., whether you have opened an email from us, whether the email has been read, and which links you have clicked), as well as any other information you provide to us. |
| How personal information is processed: | We collect and process your personal information to market our business and Services, as well as to create and manage your marketing subscription. We also use information about your preferences and usage to better understand how our customers engage with our marketing efforts and to enhance future marketing strategies for you and others.We only send marketing materials via email or other electronic channels when we have obtained your consent, as required by applicable marketing laws.Additionally, we use your personal information to tailor content on our Website and third-party platforms based on your activities and preferences. This includes limiting the number of times you see the same content and measuring the effectiveness of our marketing efforts. To achieve this, we may upload your email address to advertising platforms such as Google or Facebook to deliver targeted marketing, as further detailed below. |
| How long do we retain the personal information we collect? | We retain personal information about recipients of marketing for 1 year after unsubscribing. |
Competition Participants
| Category of personal information we collect: | When you participate in competitions, we process personal information such as your name and responses to the given competition. |
| How personal information is processed: | We collect and process your personal information for the purpose of administering competitions, selecting winners, etc. |
| How long do we retain the personal information we collect? | We delete the above-mentioned information after the competition ends. |
Visitors to Dilling’s Office(s)
| Category of personal information we collect: | Where we have CCTV surveillance, we inform you in accordance with section § 3 (1) of Danish law regarding CCTV. All recordings are stored securely and only viewed, if necessary, for example, in the event of a security breach. Recordings are only viewed by individuals who have a work-related need. The recordings are typically automatically overwritten after a short period, unless an issue requiring investigation, such as theft, is identified. |
| How long do we retain the personal information we collect? | We retain material collected through CCTV for 30 days. |
Partners and/or Suppliers to Dilling
| Category of personal information we collect: | When you are a partner or supplier to Dilling, or a contact person for a partner/supplier, we process personal information such as name, company address, work phone number, email address, job title, publicly available information, and any other information you provide to us. |
| How personal information is processed: | We collect and process the personal information for contract management and to receive goods and services from our suppliers and partners, and where relevant, to fulfil agreements with our customers. |
| How long do we retain the personal information we collect? | We retain the above information about partners and/or suppliers for 5 years after the last contact. |
4. What information does Dilling share with others?
Dilling shares personal information and your communications with others to improve our services and offerings to you and to enhance the functionality of the Websites or Services. Generally, we will attempt to limit the disclosure of data in personally identifiable form and to minimize the sharing of information that can be attributed to you personally. For California residents, please see the State-Specific Privacy Information section below. In addition, Dilling may share your personal information collected from and about you in the following ways:
Affiliates and Subsidiaries
We disclose your data to our affiliates and subsidiaries for business purposes and to perform functions on our behalf (such as those who process credit cards and payments, perform shipping and deliveries; host, manage and service our data; provide technical support or logistics services; secure our Website; distribute emails; perform research and analysis; manage brand and product promotions; and administer certain services and features on our Websites).
Service Providers; Vendors
We engage other companies to provide services to us or on our behalf, including web analytics, marketing, chat support and functionality (including conversational artificial intelligence), data analysis, credit card processing, shipping, stocking orders, customer service, and fraud protection. These third-party "service providers" (also referred to as "vendors") perform services on our behalf when the information is necessary for them to fulfill their responsibilities.
Examples include:
- We share most of your data with certain cloud service providers and other technical or platform service providers.
- We share your payment and purchase information, usage information, and other data with our fraud prevention and data analytics providers.
Our service providers, with whom we share your personal information, are:
- Prohibited from using personal information for any purpose other than the agreed-upon services.
- Contractually required to comply with all applicable laws and regulations, including payment card industry and data security standards if they process or transmit payments on our behalf.
Legal Disclosures
Dilling may transfer and/or disclose the information we collect from and about you in the following circumstances:
- To comply with a legal obligation.
- To provide information to law enforcement or other governmental authorities in accordance with applicable law.
- When we believe in good faith that the law requires such disclosure.
- For fraud prevention and credit risk reduction.
- To detect and address technical or security vulnerabilities.
- To prevent or respond to security incidents.
- To enforce our Terms of Service or other applicable policies.
- To protect the rights, property, safety, or security of third parties, users of the Services, Dilling, or the public.
Corporation Transactions
We may disclose personal information as part of a corporate transaction, such as a merger or sale of assets.
Content you Post
Any information you choose to post in public areas of the Website, such as message boards or feedback sections, becomes publicly available.
Advertising and Social Media Platform and Networks
We may disclose or make personal information available to third-party platforms and providers to obtain personalized and tailored advertising services, to enable certain features or portions of the Website, or as necessary to respond to your requests. For example, we share information collected via cookies and similar technologies on our Website with third-party advertising companies to serve you relevant ads and content, as well as to manage, improve, and measure our advertising campaigns.
For more information, please refer to us.dilling.com/cookie-policy
We also use third-party services to match the information we possess with personal information from their databases, enabling the creation of custom audiences and the delivery of personalized advertising tailored to your interests across the Internet, including on social media platforms, in compliance with applicable laws.
Providing tailored advertising services may be considered a “sale,” “sharing” for cross-context behavioral advertising, or “targeted advertising,” as defined by applicable law. We do not disclose, sell, or share personal information to third parties for money¬ or compensation. You may opt-out of cross-context behavioral advertising or targeted advertising by using the relevant settings available in our Website.
Other Parties Consent.
We may also disclose your personal information to any other third party where you have provided your consent.
5. STORAGE, DATA INTEGRITY, AND SECURITY
The servers and databases where your personal information may be stored are hosted in the European Union. As a result, your data may be located outside the country from which you accessed our Services and Website, potentially in jurisdictions with data protection and other laws that differ from those in your country of residence. Your personal information may also be disclosed in response to inquiries or requests from government authorities or to comply with judicial processes in the countries where we operate.
When your personal information is no longer needed, we ensure its secure deletion.
We are committed to protecting your personal information by implementing appropriate technical and organizational security measures. To safeguard all personal data we process, we have established robust security protocols and conduct regular internal reviews to assess the adequacy and compliance of our policies and security measures.
6. YOUR PRIVACY RIGHTS AND CHOICES
You may have certain rights regarding your personal information, as outlined below. Additionally, depending on the applicable laws in your place of residence, you may be entitled to additional rights concerning your personal data.
We reserve the right, at our sole discretion, to voluntarily extend some or all of these rights to you, regardless of your place of residence.
Updating Account Information
You may review and modify your account information at any time by signing into your online account, if you have registered an account at the Website.
Withdrawal of Consent to Process
You may – unconditionally and at any time – withdraw any consent. This can be done by sending us an email to info@dilling.com. Withdrawal of your consent will not have any negative impact. However, it may mean that we can no longer fulfil specific requests from you or provide certain Services. Withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.
Furthermore, it will not affect any processing carried out on another legal basis.
Access, Rectification, and Deletion of Information
You may request access to, rectification of, or deletion of the information we have about you, as described below:
| Right of access: | You have the right to access the personal information we process about you and request to receive your personal information in a structured, commonly used, and machine- readable format, and to have your personal information transferred from one data controller to another. |
| Right to rectification: | You have the right to request correction of inaccurate personal information about yourself or incomplete personal information completed. |
| Right to erasure (the right to be forgotten): | You have the right to request the personal information we about you to be deleted before we would normally delete your personal information. |
To request access or deletion of your personal information, please contact info@dilling.com
OPTING OUT OF TARGETED ADVERTISING
You can opt out and change your settings used for targeted advertising purposes as outlined in our Cookie Policy.
As explained in the Cookie Policy, we process personal information (and allow others to process it) to display targeted ads on non-Dilling websites and applications. This is done using cookies and other tracking technologies. In some cases, we may share certain information, such as your email address or phone number, with our advertising partners. These partners convert the information into a unique identifier, which is then used to deliver ads that are tailored to your interests across websites and mobile apps.
Please note that you may still see ads for Dilling on third-party websites and services; however, these ads may be less relevant as they will not be personalized based on your interests.
7. Other Privacy, Security and Legal Information
Children
We do not knowingly collect or solicit personal information from children under 13.
International
The Website linked to this Policy is intended for users in the United States. As a European provider, if you choose to provide Dilling with your information and purchase products from us, you explicitly consent to the transfer and storage of that information on our servers located in the European Union. The information collected by Dilling may be subject to international laws as well as U.S. state and federal regulations. By using our Website or Services, you consent to the transfer and use of your personal information in accordance with this Policy.
Our Basis for Processing Personal information Under the General Data Protection Regulation (GDPR) are:
Processing of Data on the Website
Our basis for processing is our legitimate interest in making our website (and online services) available to you (GDPR Article 6(1)(f)) or your consent (GDPR Article 6(1)(a)), as outlined in the Cookie Order § 3.
Customer Information
Our basis for processing is the agreement with you (GDPR Article 6(1)(b)) or our legitimate interest in managing your information as a customer (GDPR Article 6(1)(f)).
Marketing
Our basis for processing is our legitimate interest in fulfilling your request to receive marketing communications, for which you have given consent under the Danish Marketing Practices Act (GDPR Article 6(1)(f)).
Competition Participants
Our basis for processing is our legitimate interest in running competitions and contacting the winners (GDPR Article 6(1)(f)).
You can at any time file a complaint with the Data Protection Authority about our processing of personal data. See more at www.datatilsynet.dk, where you can also find additional information about your rights as a data subject.
8. Changes to this Policy
We will revise this Policy as needed to accommodate changes in our services, legal obligations, or customer feedback. Whenever updates are made, the "last updated" date at the top of this Policy will be adjusted accordingly. For significant changes to this Policy or how Dilling handles your personal information, we will provide additional notice, such as by posting a statement on the Website or sending you a notification. We encourage you to review this Policy regularly to stay informed about our data practices and the choices available to you.
9. Information for Specific State Law
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. This section provides California, Colorado, Connecticut, Florida, Montana, Oregon, Texas and Virginia residents with additional information regarding our collection, use and disclosure of their personal information that supplements the disclosures in our Policy above.
Category of personal information we collect
We collect the personal information described in Section 3, “What Personal Information We Collect and Its Purpose”, above. This information includes the following categories of personal information:
- Identifiers and contact information, such as real name, postal address, online identifier, Internet Protocol address, email address, account name, or other similar identifiers
- Purchase and order information
- Commercial information, such as records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- Payment information, such as credit card number, debit card number, or any other financial information:
- Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
- Geolocation data, such as physical location or movements.
- Information you share during communications and interactions with us
- Inferences
Categories of personal information processed for business purposes
The personal information we process varies based on our relationship and interactions with you. We may disclose the categories of personal information described above for the business purposes outlined in Section 3, “What Personal Information We Collect and Its Purpose”, above.
Categories of personal information disclosed for business purposes
As outlined in Section 4, "What Information Does Dilling Share with Others?", we may disclose your personal information for business purposes to the following recipients, who may have also received such information within the past 12 months:
- Order processing, fulfillment, shipping, and logistics vendors
- Financial institutions and payment processors
- research and analytics vendors
- Information technology vendors
- Fraud prevention and security vendor
- Vendors supporting legal, compliance, accounting, audits, and other internal functions
Privacy Rights
As outlined in Section 6, “YOUR PRIVACY RIGHTS AND CHOICES”, you have the rights described in that section, which include, among other things:
- To know what personal information is collected
- To access personal information
- To correct personal information
- To delete personal information
- To opt-out of the “sale” of personal information and sharing” of personal information for cross-context behavioral advertising
For Customers residing in California and other states
Do Not Sell or Share My Personal Information
As outlined above, we collaborate with certain advertising partners to display ads tailored to your interests. Under California law, these activities may be considered the "selling" or "sharing" of your personal information. You have a right to opt out. To opt out cookie consent, you must change your setting in our cookie policy page. If you would like to opt out from our newsletter subscription, please contact info@dilling.com.
Please note that we may continue to collect and share your personal information with third parties to provide services to you, as long as such sharing is for purposes other than targeted advertising and permitted by law.
Adjusting your settings through the provided link will only opt you out of sharing activities on the specific browser and device you are using for Dilling’s Website (e.g., www.dilling.com) once you click the "confirm" button.
Additionally, we do not knowingly "sell" or "share" the personal information of consumers under the age of 16.
Dilling does not collect, process, or use sensitive personal information to make inferences about you. We handle sensitive personal information only as outlined in this Policy and as permitted by applicable law.
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