Area(s) of use:
With regard to personal data registered by e-Boks in the course of provision of services to you, e-Boks is the Data Controller and with regard to the content of your digital mailbox and your archive system, you are the Data Controller and e-Boks is the Data Processor.
e-Boks as the Data Controller
e-Boks gathers personal data such as a) names, social security number, identification and contact details (address, telephone number, e-mail, date of birth), b) login details, c) details on you that you have entered yourself, e.g. credit card and payment details, d) details of your communications with e-Boks, e) details of your activities in your digital mailbox, f) details on the operating system used by your computer, mobile device and browser used, and g) IP address.
e-Boks processes your personal data as part of its business, including a) to be able to provide services to you, b) to be able to send you newsletters and promote our products and services, c) for anonymized statistics and analyses, d) for product development and improvement of our service, and e) for internal and administrative purposes. Certain data are processed because it is required by law.
When necessary, e-Boks can share your data with a) group companies, b) IT suppliers and third parties who process your data on our behalf, c) authorities and businesses with whom you have registered, d) businesses to whom you have given consent for sharing, and e) e-Boks’ associates when necessary to be able to provide a service you have chosen. Disclosure will always be in compliance with relevant law, and – when required – with your prior consent. e-Boks will not disclose your data to countries outside the EU/EEA.
Social security numbers:
Your social security number will only be processed in three situations: a) to ensure that you are the correct recipient of messages b) to identify you when a sender with whom you are not yet registered wants to send messages to you in e-Boks, to which you can respond by registering, and c) for electronic disclosure, including when you are redirected to someone else’s website by clicking on a link, and automatically logged on.
e-Boks processes your personal data either a) on the basis of your prior consent, b) to fulfill an agreement with you, or c) in certain circumstances in pursuance of a legitimate interest. A legitimate interest can be improvement of our services, responding to an inquiry from you or anything similar.
You have the right to a) request access to your personal data, b) correct, delete or limit the use of your personal data, c) object to the processing of your personal data and d) transfer data (data portability) under certain circumstances. That means that you can ask for the details you have given to e-Boks to be provided in a legible format. If technically possible, you can also have such data transferred to a third party.
Requests according to this section must be submitted via e-Boks User Support at e-boks.dk.
If e-Boks processes your personal data on the basis of your consent (including consent to direct marketing), you can withdraw that consent at any time. This will not affect the legality of the processing based on your consent before you withdrew it.
Confidentiality and storage:
Your personal data will always be processed confidentially, regardless of whether you have actively given your personal data, or they have been gathered by e-Boks in some other manner. e-Boks will only store your personal data for as long as necessary to fulfill our obligations.
If you have any questions concerning your personal data and our processing of it, or you want to complain, you can use the User Support function on the e-Boks website: https://brugersupport.e-boks.dk/hc/en-us. If your complaint is not dealt with satisfactorily by e-Boks, and you want to pursue the matter further, you can contact the Danish Data Protection Authority, Borgergade 28, 5, 1300 Copenhagen K, firstname.lastname@example.org.
Our data protection adviser:
Because our core business is the sending of electronic mail between a sender and an end-user that can contain personal data, e-Boks has appointed a data protection adviser.
General questions concerning personal data compliance and data protection law can be addressed to the e-Boks Data Protection Adviser at the following address: DPOemail@example.com.
e-Boks as the Data Processor
The following constitute the rights and undertakings applicable to you as the Data Controller and e-Boks as the Data Processor.
Scope and purpose:
e-Boks only processes personal data for the purposes necessary for your digital mail and other content to be placed and stored in your digital mailbox and in your archive system.
The processing of personal data by e-Boks in the course of provision of services includes gathering, registering, storing, deleting, updating and disclosure.
Categories of personal data:
The content of messages and documents transferred to e-Boks, either by a sender to be placed in your digital mailbox or by yourself for storing in your archive system at e-Boks, is determined by the sender or you. Messages and documents therefore contain body text that is not determined by e-Boks, and that can contain general and sensitive data to some extent.
Categories of data subjects:
The categories of data subjects on which e-Boks processes personal data are determined by the sender and yourself. In addition to yourself, the data subjects can include children, spouses or others who may be named in the content of documents and messages (body text).
e-Boks only processes the personal data referred to on the basis of your instructions, unless such processing is required according to EU law and the laws of member states, in which case e-Boks will inform you of such legal requirements before processing, unless the law in question forbids such information with regard to important social interests.
If e-Boks believes a specific instruction to contravene applicable data protection law, we will notify you accordingly.
Relevant data protection law:
e-Boks is obliged to comply with relevant data protection law in force at any time.
Technical and organizational security precautions:
e-Boks shall take the necessary technical and organizational measures needed (including any additional measures necessary) to prevent personal data being accidentally or illegally destroyed, lost or degraded, and to them being disclosed to any unauthorized third parties, abused, or in general processed in breach of data protection law.
Identification of the necessary technical and organizational security measures takes into account the
- current technical level,
- costs of implementation, and
- nature, scope, context and purpose of processing, along with the risks of varying probability and severity to the rights and liberties of natural persons.
e-Boks ensures that those employees involved in the processing of personal data are subject to a duty of confidentiality and to a mandatory bond of secrecy.
Processing security, breach of security etc.:
e-Boks assists with observance of the undertakings in General Data Protection Regulation articles 32-36 with regard to the nature of processing and the information available to the Data Processor.
Provision of documentation and audits
Objections to processing etc.
e-Boks assists with observance of its undertakings in General Data Protection Regulation chapter III on exercising the rights of data subject in General Data Protection Regulation chapter III.
Transfer of personal data:
e-Boks uses suppliers to run its systems and therefore transfers your personal data to them. Suppliers to e-Boks will be listed below:
- KMD A/S, Lautrupparken 40, 2750 Ballerup, CBR number: 26911745
e-Boks will inform you if we plan to make changes in the use of the above suppliers. In the event of continued use of e-Boks’ services after such notification, you must accept the change.
e-Boks only processes personal data within the borders of the EU.
Prior to the transfer of personal data to a supplier or sub-data processor, e-Boks enters into a written Data Processor Contract that fulfills the requirements of the General Data Protection Regulation. If the sub-data processor fails to fulfill its data protection undertakings, e-Boks is fully liable to you for fulfillment of such undertakings.
Liability for compensation:
This aspect is regulated by the general compensation rules of Danish law, although e-Boks cannot be held liable for indirect loss and consequential loss.
e-Boks' Group, Hans Bekkevolds Allé 7, 2900 Hellerup, CBR: 25674154
Version 1.1. – 2020/01