PUFIN ID PRIVACY POLICY

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Version 2. Dated May 10, 2022.

1. Data Controller

The data controller responsible for processing of your personal data Is:

Pufin ID A/S (“Pufin ID”)
Fruebjergvej 3
2100 Copenhagen
Denmark

Pufin ID is a company registered in Denmark with registration number 40911332. If you have any requests concerning your personal data or any queries about these practices, please contact Pufin ID at info@pufin.id.

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2. What is personal data?

Personal data is all data about a person that allows for direct or indirect identification of that person.

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3. Pufin ID’s collection of your personal data

Pufin ID collects certain personal data about our users, customers, potential customers (leads), partners, and all individuals who engages with Pufin ID either through our web page, SoMe platforms, mobile apps or directly e.g. via email, phone calls, and meetings.

Pufin ID collects this data for example for the following purposes:

• Responding to requests for new business
• Providing you with information about products and services
• Conducting retargeted marketing and campaigns
• Sending newsletters and posts via email, SoMe platforms, and mobile app to our subscribers, users, and followers
• Profiling of customers, leads, partners and all other individuals who engages with Pufin ID and/or our services
• Other business-related purposes
• Authenticating you on our platforms, products and services, and enabling your use of our solutions, incl. obtaining your consent to share data with Pufin ID
• Tracking, logging and improving the use and performance of our products and services
• Processing job applications sent to us
• Pufin ID also uses analytics on our website to learn more about how it is used and how it can be improved.

This Privacy Policy describes how your personal information is collected, used, and shared – and on what legal basis.

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Customer, leads, partners and other business contacts

Pufin ID collects Personal Data from you if you are

• an existing Pufin ID customer, partner, or supplier
• have subscribed to our newsletter
• requested a contact regarding new business opportunities
• opted to receive one of our whitepapers
• if Pufin ID wish to contact you because Pufin ID believes our products and service to be relevant to you or the business you are engaged in
• if Pufin ID wish to contact you because Pufin ID believes that a partnership between you and Pufin ID would be mutually beneficial or because Pufin ID wishes to purchase items or services from you or the business you are engaged in

In order to share information with you and to be able to stay in touch with you, Pufin ID collects and process the following data:

• Name, title, contact information
• Information on your organization and your position in it
• Your request, capabilities, and communication with Pufin ID and the necessary information and notes concerning such contacts between you and Pufin ID (such as billing information, information on meetings and communication between you and Pufin ID)
• Information on newsletter, marketing, event or invitation concerning you
• Data created based on the above-described data Pufin ID already has.

Pufin ID obtains this data when we engage with you via phone, email, meetings, SoMe platforms, web page or mobile app and by collecting additional data from reliable public sources such as public company databases, or in the context of your dealings with us (e.g. contact details to communicate with you about our existing client relationship).

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Mobile App users

Pufin ID might collect the following information when you use our mobile app:

• User registration information including account ID, user name, passwords, postings, email address, telephone number, postcode and country;
• Content you send or receive through the mobile app, including any images that you capture while using the app.
• Information about your use of the mobile app, such as settings, and in-app usage information, including menus and settings clicked, features used, frequency and duration of use of the app, and crash report data (including crash logs and error messages displayed);
• Device information, such as firmware version, operating system and device identifiers, including MAC address and serial number.
• Location data: GPS, Bluetooth and WiFi signals and other information related to your location and with your permission your device’s precise geolocation when you use location-based features.

Pufin ID uses the information collected for the following purposes:

• To identify and authenticate you so you may use the mobile app(s)
• To provide you with mobile app(s), including allowing you to interact with and connect to other third-party content
• To respond to your requests, inquiries and instructions made through and about the mobile app(s)
• To deliver customized content and recommendations tailored to your interests and the manner in which you interact with the mobile app
• To operate, evaluate and improve our business (including developing new products, enhancing and improving our products and the mobile app(s), managing our communications, analyzing our products, performing data analytics, and performing accounting, auditing and other internal functions)
• To protect against, identify and prevent fraud and other criminal activity, claims and other liabilities
• To comply with and enforce applicable legal requirements, relevant industry standards and our policies

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Web page users

Pufin ID uses Google to collect and analyze information about how users interact with our website. Pufin ID uses the information to compile reports and to help us improve the site. The analytics allows us to assess the number of visitors to the website, where visitors have come to the website from, pages they visited, etc. For more information about Google Analytics privacy policy, please refer to https://policies.google.com/privacy.

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LinkedIn users

Pufin ID uses LinkedIn analytics to collect and analyze information about how people and companies interact with our LinkedIn profile and posts, and to evaluate LinkedIn campaigns. For more information about the data collected that’s collected about you and made available to us via the LinkedIn platform, please refer to https://www.linkedin.com/legal/privacy-policy

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Job applicants

If you apply for a job at Pufin ID we will collect more specific Personal Data about you, such as your name and contact information, qualifications, interests and skills, career history, cover letter, CV, link to your LinkedIn profile, third party references and interview notes. Any Personal Data you provide to us in relation to a job vacancy will be processed in accordance with this privacy notice. Pufin ID uses this data only for the purposes of processing your application and communicating with you during our recruitment process.

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Legal basis

Pufin ID collects personal data for the purposes described above. The legal basis for processing the data, incl. the associated legitimate interests of Pufin ID to do so is outlined below:

Keeping our promise to you: GDPR Article 6(1)(b)

●        Identifying and authenticating you

●        Providing you with the mobile app(s), such as allowing you to sync your data to the cloud

●        Responding to your requests, instructions and inquiries

To pursue our legitimate interests: GDPR Article 6(1)(f)

●        Operating, evaluating, and improving the mobile app(s)

●        Maintaining adequate security measures

●        Protecting against liability, including complying with industry standards and enforcing our policies

To comply with the law and legal processes: GDPR Article 6(1)(c)

With your consent:
GDPR Article 6(1)(a)

●        Provide notifications (such as via push notifications)

●        Providing you with customized content, such as insight messages

●        Allowing you to interact with and connect to other Pufin ID and third-party content

●        Processing of image data

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5. Pufin ID’s use and sharing of your personal data

Pufin ID uses your personal data to

• Processing requests sent to us, providing our services and pursuing the legitimate interests of Pufin ID related to such request and services
• Promoting our services, communicating with you and sending newsletters or other material you have subscribed to
• Analyzing, planning, executing, and improving our operations
• Evaluating possible job candidates, partners and suppliers

Pufin ID may outsource our processing of personal data to an external service provider if the needed processing requires us to do so, e.g. if Pufin ID is using an external recruitment service for filling a vacancy. All external service providers who are granted access to personal data have entered into the Pufin ID Data Processing Agreement which ensures that your personal data is processed confidentially and in accordance with this Privacy Policy and any applicable laws (see https://pufin.id). Otherwise, personal data is not shared with any other parties outside of Pufin ID, unless expressly required by applicable laws or public authorities. Pufin ID does not sell personal data to any third party for any reason.

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Profiling

Pufin ID uses your data for the purpose of developing, improving and spreading awareness of our services. Based on your data, Pufin ID may assess, which other services may be relevant to you. Pufin ID can also personalize inquiries to you, such as newsletters or web pages, to make them as relevant as possible. Pufin ID can do this automatically with IT tools. This means that Pufin ID can use what is called ‘profiling’ and ‘automated decision-making’.

The data Pufin ID uses for profiling is data about you, e.g. your title and employment, your company’s geographic location, industry and size, as well as data about the relation and the use of Pufin ID’s platforms and services by you, your company, or others similar to you and your company.

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Marketing

Pufin ID only sends direct marketing to you via e-mail if you have given your consent, according to the rules of the Danish Marketing Act. Pufin ID can use profiling for direct marketing, e.g. via LinkedIn.

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Statistics

Pufin ID also processes your data for the purpose of compiling statistics and building business intelligence.

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6. Storing and securing

Pufin ID considers all personal data we collect to be confidential and your personal data can only be accessed by Pufin ID employees or external data processing providers who have entered into Pufin ID’s Data Processing Agreement (see https://pufin.id), ref. section 5.

The network and IT-equipment of Pufin ID has been secured by using appropriate measures to protect the personal data (as well as all other Pufin information) against unauthorized access and accidental or unlawful destruction, alteration, disclosure, transfer or other unlawful forms of processing.

Pufin ID keeps personal data for mobile app users, customer, leads, partners and other business contacts for up to 24 months after an active relation between you and Pufin ID has been terminated, and for up to five years after all legal obligations have been fulfilled.  Notwithstanding the above, Pufin ID may retain limited information after the end of the applicable retention period, if required by applicable law

For job candidates, Pufin ID stores the data collected in connection with the application process for 1 year from the date of last contact with you. If you wish, Pufin ID may also store your data for a longer period in order to get in touch about future opportunities but this requires a specific, written consent.

Statistical data and data used for business intelligence is anonymous and is stored for as long as relevant for Pufin ID.

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7. Your rights

You have the right to request access to, erasing and correcting your personal data as held and processed by Pufin ID, as well as to send us any other requests based on then applicable data protection laws (e.g. request restriction of processing of the data). Further, you always have the right to prohibit us from sending newsletters or other marketing messages to you. Please send any requests concerning your data to the email addresses provided in Section 1.

Data protection laws are supervised in Denmark by Datatilsynet, The Danish Data Protection Agency, an independent authority that supervises compliance with the rules on protection of personal data. If you have questions belonging to the jurisdiction of the Data Protection, or if you wish to lodge a complaint regarding processing of personal data, you may contact the Datatilsynet at https://www.datatilsynet.dk/

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8. Changes to this Privacy Policy

Pufin ID reserves the right to alter and change information provided in this document at our own discretion. It is therefore your own responsibility to review the Policy every time you submit information to us.

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