Vision Day GDPR notice

Information about our processing of your personal data

In connection with the Vision's day at Billund Trotting Track, Sunday 29th August 2021, pictures of the various activities on the site will be taken. The purpose of the Vision’s Day is to gather proposals and input from the citizens of Billund for, how KIRKBI A/S can develop the area of the current trotting track (the Trotting Track Project) in the best way.

In this information text you can read more about our processing of your personal data in connection with the Vision’s Day.


If you do not wish to appear in pictures, you can get a "non-photo" sticker on arrival at the site, so that we can be aware of this, either when we take the pictures or at the subsequent review.  

 

  1. Data Controller

KIRKBI A/S ("KIRKBI", "we", "our" or "us") is the data controller for the processing of your personal data. You can find our contact information below

KIRKBI A/S 
Koldingvej 2 
DK-7190 Billund 
Company reg. No. 18591235
Telefon: +45 7533 8833
E-mail: travbanen@kirkbi.com 

 

  1. Purpose, basis of processing and types of personal data

Below we have described the purposes, for which we process your personal data, when you visit Billund Trotting Track on the Vision’s Day.

  • To respond to inquiries

If you contact us via the contact information, we will process your personal data in order to be able to answer your inquiry. We typically process the following personal data about you: Name, e-mail, phone number and the subject of your inquiry.

We use the rule on balancing of legitimate interest in Article 6(1)(f) of the General Data Protection Regulation as our legal basis for this processing. Our legitimate interest is to be able to respond to your inquiry and communicate with you.

We collect the personal data directly from you and will only keep it for as long as necessary to be able to answer your inquiry and for e.g. documentation, which depends on the specific request.

  • Use of pictures

On the Vision’s Day, KIRKBI has engaged photographers to take mood pictures of the activities on the site. In this connection, we may process your personal data (your picture).

We use the pictures internally to be able to communicate about the Vision’s Day, the Trotting Track Project, and for internal evaluation. In addition, we use the pictures to document our involvement of the citizens of Billund city in connection with the preparation of the master plan for the Trotting Track Project. Finally, we use the pictures for external communication about the Vision’s Day and the Trotting Track Project, including in presentations, reports, and other external material. We expect to establish a separate website for the Trotting Track Project, and we may use some of the pictures on this website in order to communicate about the process of citizen involvement in the development of the master plan for the area. We do not use the pictures for marketing.

We use the rule on balancing of legitimate interest in Article 6(1)(f) of the General Data Protection Regulation as our legal basis for this processing. Our legitimate interest is to be able to document the Vision’s Day and citizen involvement and to be able to communicate about the Vision’s Day and the development of the area in connection with the Trotting Track Project, as described above.

We store the pictures for as long as necessary for the above purposes. When we no longer need to process them for the fulfillment of one or more of the purposes listed above, the personal data will be deleted.

 

  • Timelapse recordings of the "Build-your-city" activity

In connection with the "Build-your-city" activity, which takes place on the Vision’s Day in collaboration with CoC Playful Minds A/S, so-called "timelapse" recordings are made of the podium, where the building boards are placed. Timelapse recording is a series of individual pictures that are taken at a fixed interval and are subsequently put together into a short video.

The pictures in the timelapse recording are taken from above and exclusively of the podium, where the building boards are placed. Thus, we do not generally process any personal data in this connection. If we can still identify a participant, for example if a participant looks up at the camera at the time a photo is taken, the image will either be deleted or anonymized, before the footage is stored and used in the timelapse video.

The purpose of the timelapse recordings is to be able to communicate about the activity both internally in KIRKBI and externally, including on the separate website we expect to establish about the Trotting Track Project.

We use the rule on balancing of legitimate interest in Article 6(1)(f) of the General Data Protection Regulation as our legal basis for this processing. Our legitimate interest is to be able to document the Vision’s Day and citizen involvement and to be able to communicate about the Vision’s Day and the development of the site in connection with the Trotting Track Project, as described above.

We anonymize the recordings immediately after the Vision’s Day is held as described above.

 

  • Big screen on the site

On the Vision’s Day, activities on the site are streamed on big screens, so that other visitors to the area can follow the activities. There is no storage of the recordings.

We use the rule of balancing of interest in Article 6(1)(f) of the General Data Protection Regulation as our legal basis for this processing. Our interest is to be able to share the activities on the site with the other visitors.

  1. Recipients

In order to fulfil the above purpose, we may provide access to your personal data to third parties who, based on a contractual relationship with KIRKBI A/S, provide relevant services, such as IT services. Such service providers are subject to a data processor agreement, and data processors may not use your information for any purpose other than to process it on behalf of us.

We disclose some of the pictures from the Vision’s Day to Billund Municipality to enable Billund Municipality to communicate about the Trotting Track Project and the citizen involvement that has taken place in connection with the project, including on the Vision’s Day. We use the rule on balancing of legitimate interest in Article 6(1)(f) of the General Data Protection Regulation as our legal basis for this disclosure. Our legitimate interest is to support the communication on the Vision’s Day and citizen involvement in connection with the Trotting Track Project.

In addition, we will share the Timelapse video from the "Build-your-city" activity with CoC Playful Minds A/S for them to share on their own website. We only share the Timelapse video with CoC Playful Minds A/S in anonymized form.

Your personal data will in general not be disclosed to a third party without your permission, unless we are obliged to do so under applicable law.

 

  1. Processing of personal data outside the EU/EEA

KIRKBI A/S transfers, stores, and processes your data (including personal data and content) both inside and outside Denmark. Wherever in the world your personal data is transferred, stored, or processed by us or by companies carrying out such services on our behalf, we will take reasonable steps to ensure that your personal data is adequately protected in accordance with applicable data protection laws.

If your personal data is transferred to countries outside the EU/EEA, such a transfer will be made on the following legal basis:

  • Binding Corporate Rules
  • The country has been approved by the European Commission as having an adequate level of security
  • If the country is not approved by the European Commission as having an adequate level of security, we will transfer the data by use of "Model Contracts for the Transfer of Personal Data to Third Countries" (Standard Contractual Clauses), as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities

We use Microsoft 365 for data storage within the EU/EEA. However, in some cases personal data may be accessed or transferred to countries outside the EU/EEA. If this is the case the transfer mechanism is Standard Contractual Clauses as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities.

 

  1. Security

We have high standards of security, including when it comes to the protection of your personal data. We, therefore, have internal procedures and policies in place to ensure that we live up to our high standards and thereby comply with the requirements of implementing appropriate technical and organisational measures. Thus, we do our best to safeguard the quality and integrity of your personal data.

 

  1. Retention of personal data

We will retain your personal data for the period necessary to fulfil the purposes listed in Section 2. We may process and store the information for a longer period of time, if it is anonymised, or if we are legally obliged to keep it.

 

  1. Your rights

In accordance with the General Data Protection Regulation and the Danish Data Protection Act, you have certain rights.

  • You have the right to request access to and rectification or erasure of your personal data;
  • You have the right to object to the processing of your personal data and have the processing of your personal data restricted;
  • You have an unconditional right to object to the processing of your personal data for direct marketing purposes;
  • You have the right to receive the personal data that is being processed in a structured, commonly used, and machine-readable format (data portability).

Please note that there may be conditions to or limitations of these rights. It is, therefore, not certain that you e.g., always have the right of data portability - this depends on the specific circumstances of the processing activity.

You can exercise your rights by visiting the settings for your account or by contacting us (see below). If you contact us by email, we will have to verify your identity for security purposes.

If you disagree with the way, we process your personal data or the purposes we process the data for, you are welcome to contact us. You can also file a complaint with:

The Danish Data Protection Agency

Carl Jacobsens Vej 35

DK-2500 Valby

T: +45 33 19 32 00
E: dt@datatilsynet.dk


  1. Contact

Send a mail to travbanen@kirkbi.com  - with "Vision Day - GDPR" in the subject line, if you wish to exercise your rights or otherwise have any questions about this information text.