1. INTRODUCTION

- actee.com is the website (“Website”) through which members of the Actee Group offer a learning management system (LMS) that focuses on gamification as a tool for organizational development, change management, leadership management, and other work- and employee-related development. The various parts of Actee’ LMS are made available partly as hardcopies that are delivered to the Customer, and partly as online modules via the Website and via apps, that can be accessed by the Customers and their employees through the use of a designated User ID and a password.

- Complimentary use of the Website and/or Actee’ apps does not require a User to submit any personal information. Businesses who sign up as Subscribers to all or parts of Actee’ LMS, as well as those of their employees (jointly referred to as Users) who shall have access to the LMS, need to submit certain information in order to be granted access to the restricted parts of actee.com and/or to Actee’ apps. Most of the information that needs to be submitted will be company and business information. However, some personal information needs to be submitted, incl. e.g. name, title, phone number and email of Users and Subscriber’s designated contact person or system administrator.

- This Policy (together with our Terms of Use, the Disclaimer, the Terms of Subscription, and any other document referred to in it) sets out the basis on which any personal data we collect from Users or Users provide to us, will be processed and stored by us.

- This Policy applies to Actee’ Websites and mobile applications (the apps).

- We take Users’ privacy seriously and provide this Policy to inform Users of our practices with respect to how we collect/receive, use, store and protect personal information about visitors to and users of our Websites and apps.

Personal information is information that is personally identifiable like a User’s name, email address, phone number, mailing address, etc.

By using this Website and the apps, the User consents to the terms described in this Policy.

- This Policy may be amended by Actee from time to time without notice to Users. Users can review the most current version of the Policy on the Website.

- Only the English version of the privacy policy (the “Policy”) is legally binding. Translations – if any - have been provided purely for the User’s convenience. In the event of a discrepancy between a translation and the English version, the English version shall prevail.

 

2. INFORMATION ABOUT US

- Actee ApS is registered in Denmark under company number 32273920. The address of our registered office and principal place of business is Kornerups Vænge 12. 1., 4000 Roskilde, Denmark.

- In most instances, Actee will be the data processer in respect of personal information, while Subscriber or User will be the data controller. However, for certain types of personal information, Actee may be the responsible data controller.

 

3. INFORMATION COLLECTION

- Actee may collect and process the following personal data about Users of the Website and/or apps:

- Information that Users provide by filling in forms on the Website or apps. This includes information provided at the time of registering to use our Website or apps, signing up as a Subscriber to our service, posting material or requesting further services. We may also ask a User for information when a User reports a problem with our Website or apps;

- A record of any correspondence with User;

- Details of which services User is interested in;

- Details of User’s visits to our Website and apps including, but not limited to traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that User accesses;

- Information on whether User has opened and clicked on certain content in our emails sent to User;

- Information about User’s computer, including where available User’s IP address, operating system, browser type and device ID, for system administration and to report aggregate information to our Subscribers or advertisers; and information obtained from cookies. Please read further under Cookie Policy. This information does not necessarily enable us to personally identify the User.

• • Actee does not require Users to enter any personal information in order to make searches on the open parts of Actee’ Websites or apps, nor when being transferred to third-party websites.
  • When a Subscriber registers as a Subscriber to or when a User registers as a user of our services, we request Subscribers and Users to provide information about the Subscriber and/or the User such as:

- Subscriber’s name, phone number, and email address;

- Name, phone number, email address, and position with Subscriber of the person appointed as a point of contact and/or system administrators, who may grant access to other Authorized Users to the restricted parts of our Website and our apps;

- Subscriber’s and User’s name, phone number, email address, and position;

- Social networking. If User chooses to log in with Facebook Login https://developers.facebook.com/products/login/ or LinkedIn Sign-in
https://developer.linkedin.com/docs/signin-with-linkedin

User is permitting Actee to use and store that information related to the profile, allowing us to make use of any social media features on our Website or apps. The social media provider may send us information in line with their policies which may include the User’s name, profile picture, gender, friend lists and any other information User has chosen to make available on his/her network. Other information regarding recommendations exchanged between the User and the User’s friends or colleagues may also be shared. Please note that, if a User’s Facebook or LinkedIn friends are using Actee, they may have shared information about the User with us through Facebook Login or Google+ Sign-in. If the User wishes to prevent such sharing, the User can do so by editing his/her Facebook or LinkedIn privacy settings or the relevant settings/preferences for other social media providers.

- It is stated expressly on our Website and/or apps whether the data requested by us is mandatory or not.

 

4. INFORMATION USE

- The purposes of the processing of User’s personal information are as follows:

- Administer this Website and our apps;

- To enable User’s access to and use of the Website and/or apps services and to verify User’s authorization to access certain features of the Website and/or apps;

- To fulfil User’s requests for Products or Services;

- To personalize and customize the content and relevant Product/Services Data that Users are offered;

- To optimize and personalize User’s visits by remembering location and language configurations as well as previous searches;

- To contact User, e.g. if User has subscribed to a newsletter or permitted Actee to do direct marketing;

- Send User marketing communications;

- To improve our Products and Services;

- To provide reporting to Subscribers.

           - In order for Actee to best protect any personal information, Actee will on an ongoing basis evaluate the risk that our data processing may adversely affect the User’s fundamental rights. In particular, we are conscious of the risk of ID theft or discrimination, or that the User suffers an economical loss, damage to reputation or loss of data privacy.

          - To the extent that the use of the Website and/or apps require our processing of sensitive personal information, biometric data, or information about criminal records, Actee will conduct an analysis of the consequences of the data processing to the User’s privacy. Such analysis will be conducted prior to our collection of personal information about the User.     

          - Actee collects, processes and stores only such personal information as is relevant, necessary and sufficient in relation to the fulfilment of Actee’ regulatory or contractual duties and obligations. Accordingly, our systems are designed to collect only such personal information, which is necessary for the intended purpose or other permitted use. Furthermore, our systems are designed to ensure that the processing of collected personal information is as limited as possible and that the time of storage of such data is as short as possible. Actee may also consider whether the type of personal information submitted by a User may be used in an anonymized or pseudonymized form, provided such use does not adversely affect Actee’ ability to meet its contractual or regulatory obligations.

          - It is the User’s responsibility to submit such personal information as is required for use of our Products and Services and to ensure that personal information submitted to us is correct and complete. Actee reserves the right to check the accuracy, integrity and completeness of personal information submitted to us by a User.

 

5. INFORMATION SHARING AND DISCLOSURE

- Actee will not sell User’s Personal Data to third parties, except in the event of a sale of Actee’ business. Actee shares data about User in the following situations:

- To provide the Services User has requested including, without limitation Products and Services data, and data of services from third parties such as:

- Suppliers, such as Microsoft Azure

- Third-party vendors

- Business partners

- Referring websites

- Subsidiaries

- Where required by law

- Or when we have the User’s permission.

        - Also, Actee shares data about the User under the following circumstances:

- Actee may use third-party vendors (data processors, data storages and web-hotels) to assist us in providing our Services and may transfer User’s personally identifiable information to such vendors who have entered into a contract with us that protects the confidentiality of User’s personal information and permits the vendor to use it only as necessary to fulfil its contract with Actee.

- We may disclose the User’s personal information for any of the purposes mentioned above to any member of the Actee Group, which includes our subsidiaries, our ultimate holding company and its subsidiaries. This also includes entities that we may acquire as part of an acquisition at a future date.

- In response to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights or defend against legal claims.

- When we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Actee’ Terms of Use or Actee’ Subscription Agreements, or as otherwise required by law.

 

6. DATA STORAGE

- All personal information that the User provides to us is stored on secure ISO/IEC approved third-party servers where Actee has purchased server storage capacity. At present we have servers located within the EAA (European Economic Area). The personal information that we collect from the User may be transferred to and stored at a destination outside the European Economic Area ("EEA"). The transfer may be to any other member of the Actee Group, or to third parties as set out in this Policy. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting the User’s personal information, the User agrees to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that the User’s personal information is treated securely and in accordance with this Policy.

- We may be required by law, to hold the User’s personal information in a specific location dependent upon the location from which the User will access Actee Services. Regardless of the location in which the User’s personal information is stored, we will take adequate measures to protect the security of the User’s personal information.

These countries may have different and/or less stringent privacy/data protection and data security rules than those of the User’s own country. As a result, the User’s personal information may be subject to access requests from governments, courts, or law enforcement in those countries according to the laws in those countries.

 

7. LINKS TO THIRD PARTY SITES

- Actee provides links to third party websites and apps, e.g. after a search, and may provide referrals to certain third parties' products or services. If User chooses to visit a third party's website or use its products or services through any link provided by Actee, please be aware that this Policy will not govern User’s activities and any information that User discloses to such third parties. We strongly encourage User to read the privacy policies of the third-party websites and apps that User visits. We are not in any way responsible for the content of the websites and apps that we provide links to.

 

8. CONFIDENTIALITY AND SECURITY

- We limit access to personal information about User to employees who we believe have a legitimate need to come into contact with that information to provide Services to User or in order to do their jobs. Actee will take reasonable technical and organizational measures to prevent the loss, misuse, alteration, unauthorized access or disclosure of your personal information. While no website or app can guarantee full security, we have implemented appropriate organizational, technical, and physical security procedures to help protect User’s personal information. We also use encryption when transmitting personal information that is sensitive to the User between the User’s systems and ours.

 

9. COMMUNITY – INFORMATION SHARING AMONG ACTEE’ USERS

- If the User chooses to include personally identifiable information in User’s comments, open text fields, or other areas of the Website or the apps intended for public viewing, other users will be able to view and use this information. We recommend against posting the User’s email address and other personally identifiable information in this manner unless the User is comfortable with the possibility of receiving unwanted contact.

10. ACCESSING, REVIEWING AND CHANGING USER’S PERSONAL INFORMATION

- We will offer the User the ability to access, review and change certain personal information via the registration page on the Website or in the apps. Actee will delete personal information when it is no longer required for the purpose for which it was collected. Furthermore, upon the User’s request, we will deactivate the User’s or its representative's personal profile, and remove the User’s or its representative's personal information from active service. The user’s profile will be deactivated or blocked as soon as reasonably possible based on the User’s activity.

We will retain in our files and databases some personal information to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, Disclaimer and/or a Subscription Agreement, and comply with legal requirements as permitted by law. Therefore, the User should not expect that all of their personal information will be completely removed from our databases in response to the User’s request.

 

11. USER’S RIGHTS

- User is entitled at any time to get information of which personal data we possess and process about User, where the personal information originates from, and what Actee uses it for. Furthermore, the User is entitled to be informed of for how long we will possess the personal information and information of who gets the User’s personal information to the extent that we share the information with others. However, Users rights may be restricted to the extent required for the protection of other individual’s personal information, protection of any business secrets or protection of any intellectual property rights.

- Upon termination of a Subscription Agreement with Actee, Subscriber is entitled to receive a copy of any personal information transferred to us. Such copy will be provided in digitally readable form.

- User is entitled to have any incorrect personal information that Actee holds corrected or deleted.

- Users may at any time request that we delete the personal information that we possess about them. The aforesaid notwithstanding, Actee is permitted to keep such personal information as long as it is required in order for Actee to meet its contractual or legal obligations.

- User is entitled to object to our use of personal information about User, including our sharing of personal information for marketing purposes.

- User is entitled to receive a copy of any personal information that we possess about the User. The user is furthermore entitled to request that we transfer the personal information that we hold to another data processing provider (data portability) in the event that the Subscriber decides to terminate the Subscription Agreement with Actee.

 

12. CHANGES TO THIS PRIVACY POLICY

- Actee may update this Policy from time to time. We will notify the User about significant changes in the way we treat personal information by sending a notice to the email address specified in the User’s Actee profile or by placing a notice on our Website.

 

13. COOKIES

- When using the Website, the Website sets and accesses cookies on your computer.

For further details, see our Cookie Policy, which is available on our Website.

 

14. LAW AND VENUE

- This Policy shall be governed by and construed exclusively under Danish law without regard to the conflicts of law rules of Denmark or any other jurisdiction and any dispute between a User and Actee arising out of this Policy which cannot be settled amicably shall be subject to the sole and exclusive jurisdiction of the District Court of Copenhagen, Denmark, subject to normal appeal under applicable Danish law.

15. CONTACT

- For any questions about this Policy, please contact us on:

Email: support@actee.dk

Tel.: +45 70 70 75 05

16. USER’S CONSENT

- User is informed that his/her employer has entered into a Subscription Agreement with Actee for its Products and Services. User is further aware that to the extent that Subscriber wishes to provide its employees with access to the Services available via Actee’ Website and apps, the Subscription Agreement requires User’s employer to submit certain corporate and business information to Actee, as well as certain personal information in respect of the nominated User and representatives of User’s employer.

User hereby consents to Actee’s collection of such personal information about User as is required for the purpose of the Subscription Agreement and for the use of the Website and the apps and the Products and Services made available through these.

- Where User uses Facebook Login or LinkedIn Sign-in for accessing actee.com, User is permitting Actee to use and store information related to those profiles, allowing us to make use of any social media features on our Website or apps.

- User is further informed and consents to that Actee may share User’s personal information with third parties, as set out in clause 1 and clause 5.2 above.

- User is aware and consent to that Actee may use User’s personal information for the purpose of conducting marketing activities towards User, including newsletters.

- These consents have been given of the User’s own free will, and the User may revoke his/her consent at any time.

Annexe To Data Privacy Policy

List of typical personal information collected through the use of the Application

INFORMATION	SOURCE
A.     Customer:
1.      Name	Entered by Customer or by Actee upon receipt of information from Customer in digital format.
2.      Address	Entered by Customer or collected automatically from the companies register when Customer has provided information of company’s registration number.
3.      Reg. No.	Entered by Customer
4.      Contact details for Customer	Entered by Customer
5.      Contact details of liaison officer of the Customer	Entered by Customer
6.      Bank accounts for use of payments to Actee	Entered by Customer
B.      Customer’s employees:
1.      Name	Entered by Customer or by the employee, or by Actee upon receipt of information from Customer in digital format.
2.      Address	Entered by Customer or by the employee, or by Actee upon receipt of information from Customer in digital format.
3.      ID No.	Entered by Customer or by the employee, or by Actee upon receipt of information from Customer in digital format.
4.      Contact details	Entered by Customer or by the employee, or by Actee upon receipt of information from Customer in digital format.
C.      Partners/Consultants:
1.      Name	Entered by Partner/Consultant upon entering into Partnership/Consultancy Agreement
2.      Address	Entered by Partner/Consultant or collected automatically from the companies register when Partner/Consultant has provided information of company’s registration number.
3.      Reg. No.	Entered by Partner/Consultant
4.      Contact details for Partner/Consultant	Entered by Partner/Consultant
5.      Contact details of liaison officer of the Partner/Consultant	Entered by Partner/Consultant
D.     Supporters:
1.      Name	Entered by Supporter upon entering into Support Services Agreement
2.      Address	Entered by Supporter or collected automatically from the companies register when Supporter has provided information of company’s registration number.
3.      Reg. No.	Entered by Supporter
4.      Contact details for Supporter	Entered by Supporter
5.      Contact details of liaison officer of the Supporter	Entered by Supporter
E.      Visitors on Website:
1.      Which pages have the visitor visited or when – i.e. the electronic trail of the visitor.	Collected automatically via the Website’s cookies
2.      Which browser the visitor uses	Collected automatically via the Website’s cookies
3.      Which IP address the visitor has	Collected automatically via the Website’s cookies
F.      Subscribers to Actee newsletters and/or news magazines:
1.      Name	Entered by subscriber
2.      Address	Entered by subscriber
3.      Company/Business	Entered by subscriber
4.      Contact details of the subscriber	Entered by subscriber
5.      Particular areas/topics of interest	Entered by subscriber