Privacy Policy

1. General visitors to the website www.streaam.dk

When you visit and click around www.streaam.dk, we process a range of personal data.

Types of data and purposes

We collect and process the following types of personal data:

• IP address, operating system, language settings, browser type, device type, etc.
• Your navigation on the website as well as immediately before and after your visit to www.streaam.dk.
• Times and duration of visits to pages and subpages, etc.
• Interests and preferences.

Streaam ApS collects this information via cookies on www.streaam.dk. You can read more about this in our cookie policy.

The purposes for which we collect and process the information are:

• To retrieve the website from the server so that it can be displayed in your browser.
• To optimise the website and give you the best possible experience.
• To compile statistics on your and others’ use of the website.
• To compile statistics and analyses with a view to improving products, services and technologies.
• Marketing purposes, including profiling and behaviour-based marketing, so that our product information and offers to you are as tailored as possible.
• To register you as a customer.
• To comply with applicable legislation (e.g. the EU General Data Protection Regulation and e-privacy rules), for example:
  • Documentation obligations.
  • Compliance with the basic principles for the processing of personal data and the legal basis for the processing (e.g. obtaining consent).
  • Implementation and maintenance of technical and organisational security measures.
  • Investigation of suspected or known security breaches and reporting to authorities.
  • Handling of requests and complaints from data subjects and third parties.
  • Handling of inspections and enquiries from supervisory authorities.
  • Handling of disputes with data subjects and third parties.
  • Statistical reports on the use of the website.

Sources

The information about your behaviour is collected through the use of cookies on the website. Read more in our cookie policy. Information may also be collected directly from you, from our IT systems or from third parties.

The legal basis for collection and processing

The legal basis for our collection of your personal data through the use of cookies, including for profiling, is your consent, cf. section 3 of the Danish “Cookie Executive Order”.

The personal data may be processed for other purposes and on other legal bases, including documentation of compliance with legislation, cf. Article 6(1)(c) of the General Data Protection Regulation, and the pursuit of legal claims, based on Streaam ApS’ legitimate interest in being able to safeguard its legal interests, cf. Article 6(1)(f) of the General Data Protection Regulation.

You have the right to withdraw your consent, without this affecting any processing or disclosure that took place prior to the withdrawal. The withdrawal therefore only has effect going forward.

If you wish to withdraw your consent to data collection and processing through the use of cookies, you can do so by changing your cookie settings. If you wish to withdraw your consent to the processing of personal data collected from sources other than cookies, you can write to us at kontakt@streaam.dk.

Transfer of personal data to data processors

We transfer your personal data to certain subcontractors, including digital media partners and creative and digital agency partners, etc., which process and store the personal data on behalf of Streaam ApS.

Whether the collection is voluntary or mandatory

Providing the personal data is voluntary. The consequence of not providing the information is that you cannot access the website or use certain features on the website, etc.

Transfer to recipients outside the EU/EEA

We transfer your personal data to countries outside the EU/EEA, as we use external suppliers to process and store some of the personal data listed above.

For transfers to companies in the USA that are certified under the EU-US Data Privacy Framework (DPF), the transfer is based on the European Commission’s adequacy decision. For other transfers to third countries that do not ensure an adequate level of protection, we use the EU Standard Contractual Clauses (SCCs) as the transfer mechanism, supplemented by the necessary technical and organisational measures.

2. Customers of Streaam ApS

When you register your company with us – either as a paying customer or through a partner-funded scheme – and use “Mit Streaam” (our self-service area), Streaam ApS processes the following personal data (in addition to section 1 above):

Types of data and purposes

We collect and process the following types of personal data about you:

• Identification data: name, billing address, delivery address, email address and telephone number.
• Company name, CVR number (Danish company registration number) and industry.
• Payment information.
• Login details: username and password.
• Streaam ApS customer number and information about purchases.
• Information about which partner scheme your company is registered under (e.g. a municipality or an energy company), and which programmes the company participates in (e.g. ESG, Core or Sprint).
• The company’s estimated energy consumption, as stated at registration or updated on the platform.
• Your use of Streaam ApS’ website and platform: times of visits, subpages visited, purchases made, recommendations completed and progress in programmes.
• Any additional telephone number.
• Contact history between you and Streaam ApS.
• Recordings of service and sales calls.
• Customer satisfaction information and other data from satisfaction surveys.
• Data obtained from third parties and combined with our data, e.g. the company’s energy consumption obtained from electricity companies and/or Energinet.

The purposes for which we collect and process the information are:

• To enter into and perform a subscription agreement, service agreement, purchase agreement or other agreement with you, including administering your company’s access under a partner-funded scheme.
• To provide customer service and support in connection with the purchase of subscriptions and other enquiries, including conducting satisfaction surveys.
• To identify you if a dispute arises regarding a purchase, and to handle such a dispute.
• To provide a self-service solution where you can administer, change or terminate your agreements with Streaam ApS in accordance with the relevant terms of agreement.
• To document and report on partner-funded schemes to the partner funding the scheme, cf. the subsection “Disclosure to partners” below.
• Marketing: the information collected may be used for marketing purposes, including profiling and marketing by direct contact with you and your company.
• Compliance with applicable legislation (e.g. the EU General Data Protection Regulation), including documentation, security measures, handling of enquiries, complaints, inspections and disputes as well as statistical reports on the use of the website and our products.

Sources

The personal data is collected from you when you register your company, make purchases, are in contact with our employees or make updates in Streaam ApS’ self-service solution. Information about your use of subscriptions and services is in some cases recorded by Streaam ApS’ employees, e.g. when providing general customer service and advice. In addition, information may be collected from publicly available sources, e.g. business registers (CVR), address and telephone directories and energy suppliers. From CVR we obtain, among other things, the company’s industry and legal form, which we use to assess whether information about the company constitutes personal data.

The legal basis for collection and processing

The legal basis for our collection and processing of your identification data, your customer number, payment information, information about your purchases and use of subscriptions, partner affiliation and contact history is:

• The processing is necessary for the conclusion and performance of a contract with you, cf. Article 6(1)(b) of the General Data Protection Regulation.

The legal basis for our processing of your use of the website, enrichment of your data, customer satisfaction information and recording of sales calls is:

• The processing is necessary for us to pursue a legitimate interest, cf. Article 6(1)(f) of the General Data Protection Regulation.
• The legitimate interest we pursue by enriching your personal data is being able to identify you in relation to purchases, e.g. in the event of a dispute about a purchase.
• The legitimate interest we pursue by enriching your data is targeting our marketing based on profiling.
• The legitimate interest we pursue through customer satisfaction surveys is improving our products and services and thereby ensuring your overall satisfaction as a customer.
• The legitimate interest we pursue by recording service and sales calls is improving our customer handling and employee training and thereby the overall customer experience.
• Our legitimate interest in being able to pursue and defend legal claims.

The legal basis for disclosing information about sole proprietorships and other personally owned businesses to partners is your consent, cf. Article 6(1)(a) of the General Data Protection Regulation. See the subsection “Disclosure to partners” below.

The personal data may be processed to document compliance with legislation, cf. Article 6(1)(c) of the General Data Protection Regulation.

You have the right to withdraw a consent with effect for the future. If you wish to withdraw your consent, you can write to us at kontakt@streaam.dk.

Disclosure to partners in the case of partner-funded access

If your company’s access to Streaam is funded by a partner, e.g. a municipality, we disclose certain information about the company to the partner so that the partner can evaluate, document, follow up on and report on the scheme it funds. The terms of the disclosure are also set out in section 4.2 of the user agreement.

Which information is disclosed

• The company’s name and CVR number.
• The company’s industry.
• Date of registration and status of the access (active/terminated).
• Which programmes the company participates in (e.g. ESG, Core or Sprint).
• The number of recommendations completed and overall progress in the programme.
• The company’s estimated energy consumption.

Which information is not disclosed

• Your name, your email address, your telephone number and other personal contact details of users and employees.
• Detailed input data, e.g. answers in the ESG report, uploaded documents, meter data, invoices and financial information.
• Login details, behavioural data on the platform and contact history with Streaam.

If the partner wishes to contact participating companies, Streaam sends the partner’s communication on the partner’s behalf. The partner does not receive your contact details.

Recipients

Information at the level of individual companies is only disclosed to partners with whom Streaam has entered into a written data-sharing agreement. The agreement obliges the partner to treat the information confidentially, to use it only for evaluating and reporting on the scheme, and not to use it for marketing, control, sanctions or individual assessment of the company. At present, this is:

Legal basis and the partner’s role

• If your company is a legal entity (e.g. a private or public limited company – ApS or A/S), the information above is company information and not personal data. The disclosure takes place as part of the agreement the company enters into upon registration, cf. section 4.2 of the user agreement.
• If your company is a sole proprietorship, a small personally owned business (PMV) or is otherwise directly attributable to you as a person, the information constitutes personal data. We only disclose it if you have given separate consent, cf. Article 6(1)(a) of the General Data Protection Regulation. The consent is obtained separately from the acceptance of the user agreement; it is voluntary, your access is not conditional on it, and you can withdraw it at any time with effect for the future by writing to kontakt@streaam.dk. Without consent, your company is included only in anonymised and aggregated statistics.
• The partner is an independent data controller for its subsequent processing of the information received. The partner’s processing is described in the partner’s own privacy policy, and rights relating to the partner’s processing are exercised against the partner.

Recipients of your personal data

We distinguish between two types of recipients:

• Data processors, which process personal data on behalf of Streaam ApS and in accordance with our instructions, e.g. providers of hosting, CRM, email, telephony and analytics tools. These are bound by data processing agreements with Streaam ApS.
• Independent data controllers, which receive information for their own purposes, e.g. partners funding your company’s access (see above), as well as public authorities where we are legally obliged to disclose information to them.

Voluntariness

When we collect personal data directly from you for the purpose of entering into an agreement, it is because this is necessary for Streaam ApS to enter into the agreement with you and your company. You are not obliged to provide us with the information, but the consequence will be that we cannot enter into and perform the agreements with you. Consent to the disclosure of information about sole proprietorships to partners, on the other hand, is always voluntary and has no consequence for your access.

Automated individual decision-making

Streaam ApS does not make decisions about you based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. We do, however, use profiling for marketing purposes as described above.

Transfer to recipients outside the EU/EEA

We transfer your personal data to countries outside the EU/EEA, as we use external suppliers to process and store some of the personal data listed above. Transfers are based on the EU-US Data Privacy Framework for certified US recipients and otherwise on the EU Standard Contractual Clauses (SCCs). Information disclosed to partners under the subsection above is not transferred to countries outside the EU/EEA by Streaam ApS.

Retention period

Streaam ApS retains your information for as long as necessary for the purposes stated above. Information about subscriptions, purchases and transactions is retained in accordance with the Danish Bookkeeping Act, i.e. as a rule for 5 full calendar years after the end of the financial year to which the information relates. Contact details not covered by the bookkeeping obligation are, as a rule, deleted no later than 3 months after you are no longer a relevant contact person. Documentation of consents given and withdrawn is retained for as long as necessary to be able to document that the processing has had a valid basis.

In special cases, we retain personal data for longer, for as long as necessary to document compliance with legislation carrying criminal penalties based on the rules on limitation periods, or for as long as we need to be able to assert civil claims or defend ourselves against such claims. If a claim is asserted, we retain the information for longer for the purpose of handling the claim.

3. Subscribers to electronic mail or persons who have completed a form, etc.

When you sign up to receive electronic mail from Streaam ApS or complete a form, e.g. a contact form or our registration form, Streaam ApS processes the following personal data (in addition to section 1 and, where applicable, section 2 above):

Types of data and purposes

• Identification data: name, company name and job title (if applicable), CVR, email address, telephone number and IP address.
• When registering through a partner scheme: which partner you registered through (recorded automatically based on the link you used), the company’s estimated electricity consumption and your choice of programme.
• Any additional telephone number.
• Email logging: number of clicks, number of opens, reading time and returned newsletters (bounces).
• Consents given and withdrawn, including the time and the consent text you accepted.

The purposes for which we collect and process the information are:

• To register your company and give it access to the correct scheme, cf. section 2.
• Marketing purposes, including targeting our communication with you based on your areas of interest and your behaviour (digital behaviour on our websites and in newsletters as well as any purchase history), in order to contact you and send you relevant marketing.
• Compliance with applicable legislation (e.g. the General Data Protection Regulation, the Danish Marketing Practices Act and e-privacy legislation), including documentation of consents, security measures, handling of enquiries, complaints, inspections and disputes as well as statistical reports on the use of direct marketing.

Sources

The personal data is collected from you when you complete a form or make updates in Streaam ApS’ self-service solution, or via tracking in emails and on Streaam ApS’ website. In addition, personal data may be collected from publicly available sources, e.g. telephone directories, social media and VIRK.DK.

The legal basis for collection and processing

• Information provided in the registration form is processed in order to enter into and perform the agreement with you, cf. Article 6(1)(b) of the General Data Protection Regulation.
• Where you have given consent to receive direct marketing, the legal basis is your consent, cf. Article 6(1)(a) of the General Data Protection Regulation and section 10 of the Danish Marketing Practices Act.
• The legitimate interest we pursue by enriching your data is targeting our marketing based on profiling, cf. Article 6(1)(f) of the General Data Protection Regulation.
• Our legitimate interest in being able to pursue and defend legal claims, cf. Article 6(1)(f).

The legal basis for our collection of your personal data through the use of cookies and other tracking, e.g. in emails, is your consent, cf. section 3 of the Danish “Cookie Executive Order”. The personal data may also be processed to document compliance with legislation, cf. Article 6(1)(c) of the General Data Protection Regulation.

You have the right to withdraw a consent with effect for the future. If you wish to withdraw your consent, you can write to us at kontakt@streaam.dk.

Voluntariness

When we collect personal data directly from you for the purpose of sending newsletters, it is voluntary whether you provide the information. If you choose not to provide the information, we cannot send you newsletters. If you do not complete a contact form, we cannot contact you. Fields marked with * in the registration form are required in order to register your company.

4. Common to all sections

Transfer to recipients outside the EU/EEA

We transfer your personal data to countries outside the EU/EEA, as we use external suppliers to process and store the personal data listed above.

For transfers to companies in the USA that are certified under the EU-US Data Privacy Framework, the transfer is based on the European Commission’s adequacy decision. For other transfers to third countries that do not ensure an adequate level of protection, the basis is the EU Standard Contractual Clauses (SCCs). Further information about data processors and transfers to recipients outside the EU/EEA can be obtained by contacting kontakt@streaam.dk.

Retention period

We retain your personal data for as long as necessary to fulfil the purposes stated above and any subsequent lawful purposes.

Personal data collected in connection with subscription services from Streaam ApS is, as a rule, retained until you terminate your customer relationship and for a period of 5 full calendar years thereafter, in accordance with the provisions of the Danish Bookkeeping Act. Personal data collected in connection with the purchase of other services via www.streaam.dk is, as a rule, retained for 5 full calendar years calculated from the date of purchase, in accordance with the provisions of the Danish Bookkeeping Act. Personal data collected for the purpose of sending newsletters or other information is retained until you unsubscribe.

In special cases, we retain personal data for longer, for as long as necessary to document compliance with legislation carrying criminal penalties based on the rules on limitation periods, or for as long as we need to be able to assert civil claims or defend ourselves against such claims. If a claim is asserted, we retain the information for longer for the purpose of handling the claim. For other purposes, including documentation required by law and the implementation of security measures, the personal data is retained for as long as necessary under statutory limitation rules.

Your rights

Subject to the limitations laid down by law, you have, among other things, the right of access to your personal data, the right to have inaccurate information rectified, the right to have information erased, the right to restriction of processing, the right to data portability and the right to object to the processing of your personal data, including in relation to automated individual decision-making.

Where the processing is based on your consent, you have the right to withdraw your consent at any time. This also applies to consent to the disclosure of information to partners. The withdrawal takes effect from the time we receive it and does not affect disclosures that have already taken place. If we have disclosed information to a partner, we will inform the partner of the withdrawal.

If you wish to exercise your rights against a partner that has received information about your company, you must contact the partner, which is an independent data controller for its own processing. We are happy to help you find the right contact.

You also have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet).

Right to object

You have the right – on grounds relating to your particular situation – to object to the processing of personal data where the legal basis is legitimate interests, as stated above. Streaam ApS may then no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or unless the processing is necessary for the establishment, exercise or defence of legal claims.