Zenegy Trust Center
The personal data policy describes how Zenegy Danmark ApS ("Zenegy"), to the extent that Zenegy is data responsible, processes your personal information obtained via the cloud-based software system called ZENEGY, which can be used for payroll administration, HR administration, financial administration, etc. ("The Application"), which is available to users via Zenegy's website and or Zenegy's apps, as well as any optional modules that may be made available to the user.
When Zenegy processes your personal information in connection with the Application, it basically takes place as a data processor for the companies that have entered into a subscription agreement with Zenegy (the "Customers"), and only on the instructions of the data controller. For more information about the processing of personal data carried out on behalf of the Customers, please refer to the Customers' privacy policies. This will usually be your employer.
Zenegy is data responsible for the processing of personal data, which takes place for Zenegy's own purposes, including in regards to Zenegy entrance into special data storage agreements, see 2.4.
Zenegy has the following contact information:
Zenegy Danmark ApS
Tlf. 70 22 22 16
The personal data that is normally processed by Zenegy as a data controller is listed in the attached Appendix 1. This is general information such as name and address, CPR numbers and sensitive information about e.g. health and trade union affiliation.
The Application is a cloud-based subscription-based self-service solution, where customers and / or their employees essentially load the data that is necessary for use of the Application.
The Application may exchange information with, for example, social media such as Facebook, Instagram and LinkedIn, provided that users choose to use their profile on such media as identification when accessing the Application. In addition, users may choose to integrate data from third-party software systems with the Application.
Zenegy processes your personal information for the following purposes:
Zenegy processes general information such as username, password, contact information and bank account of the Customers as well as contact persons at the Customers, as the processing is necessary for the fulfilment of a contract, in reference to Article 6 (1). 1, letter b in the GDPR, see § 6, para. 1 of the Data Protection Act, and since Zenegy has a legitimate interest in being able to get in touch with Customers and invoice, see Article 6, para. 1, letter f in the GDPR, see § 6, para. 1 of the Data Protection Act.
If the Customer you are associated with, e.g. your employer, terminates the subscription agreement with Zenegy or decides to delete your personal information in the Application, Zenegy will offer you to continue to store your personal information in the Application and possibly pass on the personal information to a new data controller appointed by you. Retention of your data requires that you enter into a Data Retention Agreement with Zenegy through your profile, and that you are 15 years of age or older.
If the Customer decides to delete your personal information in the Application, Zenegy will offer you that you can continue to store your personal information in the Application and possibly pass on the personal information to a new data controller appointed by you. Retention of your data requires that you enter into a Data Retention Agreement with Zenegy through your profile, and that you are 15 years of age or older.
Our legal basis for carrying out this treatment is Article 6 (1). 1, letter b in the Data Protection Regulation ("GDPR"), see section 6, subsection 1 of the Data Protection Act, regarding processing necessary for the fulfilment of a contract with you.
If the processing includes sensitive information or your CPR number, we will obtain your consent in accordance with Article 9 (1). 1, letters a and 6, para. 1, letter a of the GDPR, see §§ 6, para. 1 and 7, para. 1 of the Data Protection Act, as well as section 11, subsection 2 of the Data Protection Act.
You must be aware that withdrawal or failure to give consent to our processing of your personal data may affect or make impossible the use of the Application, as the processing of certain personal data is necessary for the use of the Application.
If the data processing includes contact information on secondary persons, including spouses / registered partners or children, our legal basis is the balancing of interests rule in Article 6 (1). 1, letter f, see § 6, para. 1 of the Data Protection Act, as we have a legitimate interest in processing this information through your use of the Application.
Personal information about children is only processed to the extent that the Customer or you have entered information about children in the Application.
The anonymization of your personal data is based on Zenegy's legitimate interest in using anonymised data for statistical purposes pursuant to Article 6 (1). 1, letter f in the GDPR, see § 6, para. 1 of the Data Protection Act.
Zenegy collects, processes and stores only personal data that is relevant, sufficient and necessary for the purposes described above or that are otherwise required by the law under Article 6 (1). 1, letter c in the GDPR, see § 6, para. 1 of the Data Protection Act.
In regards with your use of the Application, Zenegy passes on or leaves your personal information to the following recipients:
Zenegy only stores your personal information for as long as necessary to fulfil its purpose, unless otherwise required by law, including in particular the rules of the Accounting Act on the storage of accounting material for 5 years.
Upon termination of a Customer's subscription with Zenegy or the Customer's decision to delete your data in the Application, you will - if you are over 15 years old - be offered to continue to store your data with Zenegy, in exchange for entering into a separate "Data Retention Agreement". The processing of personal data under a Data Retention Agreement continues until the agreement terminates.
In certain situations related to the processing of personal data, Zenegy will transfer your personal data to recipients outside the EU and the EEA ("third countries"). This will typically be the case when we use a data processor in a third country.
The transfers therefore take place on one of the following transfer bases:
More information about these warranties can be found at https://zenegy.com/3-parts-software/
According to the GDPR, you have a number of rights in relation to Zenegy's processing of information about you. If you wish to make use of these rights, which are described in more detail below, you must contact us through the contact information listed at the top of the personal data policy.
Zenegy will process and respond to your inquiry as soon as possible and no later than one month after we receive your inquiry, unless the complexity and scope of the request means that we are unable to respond within one month. In that case, the deadline for reply may be up to 3 months in total, in accordance with Article 12 of the GDPR.
Upon request, you can gain insight into what personal data Zenegy processes about you and what processing takes place, in accordance with Article 15 of the GDPR.
It includes among other things how long Zenegy stores personal information, and who receives data about you to the extent that Zenegy discloses personal information, in accordance to 2.3 and 2.5.
However, your access to information about it may be restricted for the sake of other people's privacy to trade secrets and for the sake of protecting intellectual property rights.
You can contact Zenegy or make use of this right by self-service in the Application, where with your personal login you can extract an overview of what information Zenegy is in possession of in the Application.
You can also receive a digital copy of the personal information that is processed.
You have the option of downloading electronic copies and / or making physical transcripts of the documents generated via or stored in the Application, for example pay slips, employment contracts, etc. However, given that the access here up til acts in accordance with the requirements in part 2.4, unless you have agreed to a Data storage agreement with Zenegy.
You have the right to have incorrect personal information about yourself corrected, in accordance with Article 16 of the GDPR.
You can contact Zenegy and find out what the inaccuracies are and what they need to be corrected.
You have the right to have personal information about yourself deleted in accordance with Article 17 of the GDPR, provided that:
However, the removal may be limited in some cases. In particular, removal may not take place if Zenegy is legally obliged to retain all or part of the personal data or it is necessary to keep the personal data in order for a legal claim to be established, asserted or defended. In that case, we will only store the information to which we are legally obliged or entitled and will delete other personal information.
To the extent that Zenegy's processing of your personal data is based on a consent given by you, you have the right to withdraw your consent to Zenegy's processing of all your personal data or in parts at any time, in accordance with Article 7 of the GDPR.
If you withdraw your consent, Zenegy will cease to process the personal data to which you have revoked your consent. In practice, this will result in all your information being deleted.
Your withdrawal of your consent does not affect the lawfulness of the processing that Zenegy has conducted until your withdrawal.
You have the right at any time to object to Zenegy's processing of your personal data for reasons relating to your particular situation, provided that the processing is based on Article 6 (1). 1, letter f on balancing of interests, in accordance to GDPR Article 21.
In that case, we may no longer process the personal data unless we demonstrate compelling legitimate reasons for the processing that take precedence over your interests, rights and freedoms, or the processing is necessary for legal claims to be established, asserted or defended.
You have the right to have Zenegy's processing of your personal data restricted in the following cases, in accordance with Article 18 of the GDPR:
When our processing of your personal data is based on consent or a contract, and our processing is carried out automatically, you have the right to data portability.
The right to data portability means that you have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, which you have the right to transfer to another service provider, in accordance with Article 20 of the GDPR.
If you wish to complain about the processing of your personal data, you have the right to submit a complaint to the Danish Data Protection Agency, which has the following contact information:
The Data Inspectorate
Adresse: Borgergade 28, 5, 1300 København K
This overview contains the categories of information that will normally be transferred to and processed and stored by Zenegy as the data controller in the Application and by others' visits to the website.