CETA Partners – Legal specialists dedicated to accelerating the clean energy transition

Data Privacy Policy

Version 1 (Nov. 2021).

This privacy policy describes how CETA Partners (“we” or “us”) process personal data in connection with providing our clients with services, administrative procedures, anti-money laundering measures, marketing and use of our website.

DATA CONTROLLER

The legal entity responsible for the processing of your personal data is:

CETA Partners ApS
Company Registration (CVR) No: 42 33 69 63
Helgas Høj 55,
2950 Vedbæk, Denmark 
info@ceta.partners

CONTACT US

If you have any questions concerning our processing of personal data, please contact us by mail or by email info@ceta.partners.

DESCRIPTION OF THE PROCESSING

We process personal data for the following purpose:

Client management

In order to administer, manage and cultivate the relationship with our clients, we process personal data about you as a client or a potential client. As part of our client management, the following types of information are processed. The information is processed without regard to the field in which you are receiving advice from CETA Partners.

  • Ordinary personal data. These include identification information and contact information about clients, owners of the client and/or contact persons, as well as representatives of the client. Furthermore, we process information about our relationship with the client, including correspondence, and information about accounts receivable and outstanding amounts. In certain cases, we collect credit information about clients.

  • The legal basis for the processing is Article 6(1)(b) of the GDPR, according to which personal data can be processed if necessary for the performance of a contract, in this case the task or the potential task. Furthermore, personal data can be processed if necessary for the purposes of CETA Partner’s legitimate interests, including the establishment and cultivation of a relationship with a client, see Article 6(1)(f) of the GDPR; just as there might be situations where we store your personal data even if we do not enter into a consultancy agreement.

Regulatory requirements 

In cases where CETA Partners provides assistance on transactions that require official registration with authorities or is required by a counterparty or advisor during a transaction (e.g. a lender or a local law firm), there is a number of requirements in the anti-money laundering legislation that CETA Partners must meet.

  • Identity data (ordinary personal data). Including processing of information, such as name, Civil Registration No. (alternatively passport number or another national identification number), the information is compared with a reliable and independent source, e.g. the Danish central national register, digital signature or NemID, or copy of picture ID (e.g. passport, driver’s licence or the like), CVR number, owner and control structure, beneficial owners, alternatively the day-to-day management (must be authenticated by identity information).

  • The legal basis for the processing is Article 6(1)(c) of the GDPR, according to which personal data can be processed when necessary for compliance with a legal obligation. 

Providing services
CETA Partners processes personal data about you as business owner, beneficial owner, board member, employee, customer and suppliers in connection with providing its services. These data are processed in order to advise our clients on matters pertaining to commercial law.

  • Ordinary information that may be processed includes: identification information, including Civil Registration No., contact information, copy of ID (health insurance card, passport, driver’s licence), information about criminal offences (anti-mafia certification), bank and payment information, financial and tax information, ownership records, contractual relationships, employment information and other types of personal data that may be relevant to a transaction or the services requested by a client.

  • Basis of processing when processing is necessary for the performance of a contract (the task), compliance with a legal obligation, CETA Partners and the client’s legitimate interests in relation to conducting legal proceedings, advising and practising law, see Article 6(1)(b)(c) and (f) of the GDPR.

Implementing transactions with parties, counterparties parties, representatives and other third parties:
If you are a party, opposing party, representative or other third-party participant in a transaction dealt with by CETA Partners, we will generally process your personal data in order to be able to assist our client in the transaction in question.

  • We may process your identification, contact and professional data, including name, email address, telephone number, your private address, your position, your involvement in the case and other general personal data included in the case, such as financial data.

  • The legal basis for our processing is our legitimate interest in assisting our clients as counsel in handling the case in question, see Article 6(1)(f) of the GDPR. In some cases, the legal basis may also be compliance with a legal obligation, see Article 6(1)(c) of the GDPR.

SOURCES OF PERSONAL DATA

CETA Partners primarily obtains personal data from the client but may also obtain information from publicly available sources, public authorities and counterparties.
Please note that when you visit our website, you automatically submit information about your activities, usage, etc. on our website to CETA Partners and third parties. 

DISCLOSURE AND TRANSFER OF PERSONAL DATA

Your personal data is disclosed only in connection with providing services and regulatory requirements, and only when CETA Partners is legally obliged to do so, or when you have given your consent. You can always withdraw your consent by contacting CETA Partners via the above contact information. Data may be disclosed to the following parties:

  • The parties to the case

  • Public authorities, including the courts, the registration court, tax authorities, authorities responsible for foreign investment, etc.

  • Insurance companies and lenders

In addition, CETA Partners discloses your personal data to data processors, who are assisting CETA Partners in our business operations.

In principle, CETA Partners does not transfer your information to countries outside the EU/EEA. However, transfer may take place if you or a party to the case is located in a so-called third country. In this case, the legal basis is Article 49(1)(e) of the GDPR, according to which transfer may take place if necessary for the establishment, exercise or defence of legal claims, just like transfer may take place if you have given your consent. You can always withdraw your consent by contacting CETA Partners via the above contact information.

ERASURE

CETA Partners processes your information for as long as it is necessary to fulfil the purpose of the processing.
In connection with providing services, client management and regulatory requirements, CETA Partners generally stores your information for five years from the end of the year in which the transaction was closed, unless otherwise required according to legislation or in case of original documents such as contracts, etc.

If no relationship has been created with CETA Partners and we have registered information about you only in connection with creating a possible relationship, we will store your information for up to two years after ending the correspondence.
In relation to marketing and the website, CETA Partners stores your information for up to two years after you have participated in an event or unsubscribed to our newsletter.

YOUR RIGHTS

As a data subject, you have certain rights according to the GDPR when your personal data are being processed. Below is a specification of your rights when CETA Partners processes personal data about you.

If you want to exercise one or more of your rights as a data subject, you must contact CETA Partners in writing via the e-mail address indicated above. Please state your full name and your e-mail address. You may be requested to provide further identification.

In general, you can exercise your rights at any time. However, exercising your rights must not affect the rights and freedoms of others and in such an event, CETA Partners may therefore refuse to comply with your rights wholly or in part.

Right of access
As a data subject, you have the right to obtain access to your personal data being processed by CETA Partners. By contacting CETA Partners, you can obtain information about the categories of personal data that we as data controller are processing about you, the purpose of the processing, the recipients to whom the personal data have been disclosed, etc.

If you request further copies of the personal data undergoing processing, CETA Partners may charge a fee. If the inquiry is manifestly unfounded or excessive, we may either charge a fee for providing the information or reject your request.

Right to rectification
You have the right to obtain rectification of your personal data if these are inaccurate or misleading. If CETA Partners does not agree that the data are inaccurate, however, we are not obliged to correct them, but to add that you as a data subject do not think that the data are correct.

Right to erasure
In certain cases, you have the right to obtain erasure of your personal data if CETA Partners no longer has a purpose in processing your personal data or you object to the processing of your personal data for the purposes of direct marketing or pursuant to Article 6(1)(f) of the GDPR. If CETA Partners can demonstrate overriding  legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is necessary for a legal claim to be established, exercised or defended, however, CETA Partners is not obliged to erase your personal data.

Right to restriction of processing
In certain cases, you have the right to obtain restriction of processing of your personal data, e.g. if you contest the accuracy of the personal data collected about you or if you have objected to the processing of your personal data based on legitimate interests pursuant to Article 6(1)(f) of the GDPR. In such an event, CETA Partners will only store your personal data until your objection has been considered. If CETA Partners lifts the restriction of our processing of your personal data, you will be notified in advance.

Right to object
On grounds relating to your particular situation, you have the right to object to CETA Partners processing of your personal data, if the processing is based on legitimate interests, see Article 6(1)(f) of the GDPR. If you object to CETA Partners processing of your personal data, we are no longer entitled to process your personal data, unless we can demonstrate overriding legitimate grounds for the continued processing that override your interests, rights or freedoms, or the processing is necessary for a legal claim to be established, exercised or defended.
You always have the right to object to the processing of your personal data if the processing takes place for the purposes of direct marketing.

Right to data portability
In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have those data transmitted from one data controller to another data controller. This right applies only when the processing of your personal data is based on a contract pursuant to Article 6(1)(b) of the GDPR or your consent, see Article 6(1)(a) of the GDPR.

Right not to be subject to a decision based solely on automated processing, including profiling
Your personal data are not subject to decisions based solely on automated processing, including profiling.

Right to withdraw your consent
To the extent that we process your personal data based on your consent, you can always withdraw your consent to any future processing. You can withdraw your consent by sending an e-mail to info@ceta.partners 

LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

As a data subject, you can lodge a complaint with CETA Partners as data controller if you are not satisfied with the way that we process your personal data. You can find our contact information above.

You can always lodge a complaint with the Danish Data Protection Agency on their website http://www.datatilsynet.dk/, by telephone: +45 33 19 32 00, or by e-mail dt@datatilsynet.dk.

CHANGES TO OUR DATA PRIVACY POLICY

Our Data Privacy Policy will be updated on an ongoing basis so that it is always up-to-date. You can always find the date of the last updated version of the Data Privacy Policy at the top of this page.

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