Privacy notice for Butter solutions ApS

What does the Privacy Notice Cover?

Butter Solutions ApS, from here on referred to as Butter, respects your privacy and is committed to protecting your Personal Data.We want to be transparent with you about how we collect and use your Personal Data in making available our platform, mobile application and/or website(s) (“Platform”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Notice describes how Butter collects and processes your Personal Data, which may be either through your use of the Butter Platform, including any data you may provide through this Platform; or through your interaction with Butter through our website, social media and marketing activities. The Privacy Notice is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

For the purposes of the Data Protection Act 2018 and General Data Protection Regulation (EU) 2016/679 as amended from time to time (“DPA”), we may be a data controller or processor of the data we hold that may be used to identify you (“personal data”) depending on the purpose of processing.

We will post any changes to this Privacy Notice on this page.

Who we are

Butter Solutions ApS (referred to as either “Butter”, “we”, “us” or “our” in this Privacy Notice) is registered in Denmark (CVR number 41335874); at registered address Skelbækgade 2, 6th floor, 1727 Copenhagen V.

Butter is registered with the Danish FSA as a company subject to the Danish Anti Money Laundering Act.

How to contact us

You can contact us by emailing us at jmr@buttersolutions.com

Your rights relating to your Personal Data

You have certain rights under the law, such as notice to request access to your information, to manage it and to request for it to be deleted or to transfer information about you or to restrict the way it is used.

Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground.

Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Platform. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

The majority of our services to our app users is based on contractual agreements with the employer’s of those users. Depending on the service and access, Butter may be a Processor or Controller of the user personal data. Please contact your employer or Butter using the contact details shown in “Who We Are and How to Contact Us” if you have any questions. Please note, ur own contractual obligations with your employer may require us to advise your employer of the request.

Where your request relates to other processing activities, please contact us directly using the contact details shown in “Who We Are and How to Contact Us”.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights).

However, except in relation to Consent Withdrawal, we may charge a reasonable fee, or refuse to comply with the request, if it is unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity to exercise any of your rights, including those related to data protection). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Personal Data we process

We apply the data minimisation principle and only collect the minimum necessary data for the process.

Personal Data we may collect about you from you, from your employer and from third parties about you, is outlined in the table below.

Category of personal data

What this means

Identity Data

First name, surname, last name, username or similar identifier, title, and date of birth

Contact Data

Your home address, email address and telephone numbers.

Financial Data

Your registration number and account number; salary.

Transaction Data

Any details about payments to and from you and other details of subscriptions and services you have purchased from us.Data in respect of your transactions with 3rd parties.

Other Personal Data

Employment related; gender; age; income; employment status

Behavioural Data

Inferred or assumed information relating to your behaviour and interests, based on your online activity and/or in app. This is most often collated and grouped into “segments” (e.g. there may be a segment for users, living in Copenhagen, aged 20-25, who use our services twice a month)

Technical Data

Related to website visits and app usage, such as Internet Protocol (IP) address, mobile device identifier, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, download errors, response time, page interaction (such as scrolling, clicks, and mouse-overs) device type and model, operating system and platform and other technology on the devices you use to access this Platform or use our services.

Aggregated Data

We may use and share personal data as “Aggregated Data” for statistical purposes only. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We will only use your Personal Data where we have a lawful basis to do so.

We do not sell your personal information to any third parties. However we may share your personal information with third parties as follows:

- Selected other parties including: business partners, suppliers and sub-contractors for the performance of any contract we enter into with your employer and you;

- Analytics and search engine providers that assist us in the improvement and optimisation of our site and service;

-To comply with legal or regulatory obligations

We have set out below, in a table format how we use your Personal Data.

Account creation:
- Categories of personal data involved:  Identity Data Contact Data
- Why we do this:  To register you as a new user.
- Our legal basis for this use of data:  Legitimate Interest

Transfers and service Provisions:
- Categories of personal data involved:  Identity Data Contact Data Financial Data
- Why we do this:  Provide you with the Butter services and communications on behalf of your employer.
- Our legal basis for this use of data:  Performance of contract

 Making third party product available:
- Categories of personal data involved: Identity Data Contact Data
- Why we do this: Enable you to access third party products
- Our legal basis for this use of data: Consent

Fraud Prevention:
- Categories of personal data involved: Identity Data Contact Data Behavioural Data Technical Data
- Why we do this:  To keep our website, our services and associated systems operational and secure. To keep your data and identity secure.
- Our legal basis for this use of data: Performance of contract

Troubleshooting:
- Categories of personal data involved: Technical Data
- Why we do this:  To track issues that might be occurring on our systems.
- Our legal basis for this use of data: Performance of contract

Optimisation and Analytics:
- Categories of personal data involved:  Identity Data Contact Data Transactional Data Technical Data Behavioural Data
- Why we do this:  To understand and measure how users use our Platform to improve it and report relevant aggregated management information.
- Our legal basis for this use of data: Performance of contract Legitimate Interest

Marketing:
- Categories of personal data involved:  Identity Data Contact Data
- Why we do this:  To capture interest in Butter and to keep prospects and clients informed.
- Our legal basis for this use of data: Consent

Product Referrals:
- Categories of personal data involved:  Identity Data Contact Data
- Why we do this:  To allow interested employees to refer Butter to their employer.
- Our legal basis for this use of data: Legitimate Interest

Survey Invitation:
- Categories of personal data involved:  Identity Data Contact Data
- Why we do this:  Improve our service
- Our legal basis for this use of data: Legitimate Interest

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and your employer and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Platform).

In this case, we may have to stop you using our Platform, but we will notify you if this is the case at the time.

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we may also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

**

Your employer:
- publicly available: No
- Category(ies) of Personal Data involved: Identity Data Contact Data Financial Data Transaction Data
- purpose: Butter Service Provision

Who we share your Personal Data with

Your Emplyer(s):

- Categoriy(ies) of Personal Data we share: Financial Data Transaction Data
- Why we share it: Your employer(s) engaged Butter to provide the Platform and Butter services. We share your personal data with your employer(s) to provide them and you with such Platform and services.
- Location(s): Within EEA

Business partners, suppliers and subcontractors:

- Categoriy(ies) of Personal Data we share: Identity Data Contact Data Technical Data Financial Data
- Why we share it: For the performance of any contract we enter into for the uses set out in the section
- Location(s): Within EEA Within the United States

Data transfers

Where we transfer your personal data outside the European Economic Area (‘EEA’), we only do so where:

The European Commission say there is adequate data protection;
We’ve agreed standard data protection clauses.

How we keep your Personal Data secure

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
Measures we take include:
- Firewalls;
- Data encryption;
- Intrusion detection systems;
- Background checks for all emplyees accessing our physical facilities.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators.
In addition, in certain circumstances (e.g. where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
If you suspect any misuse or loss of, or unauthorised access to, your data, you should let us know immediately.

How long we store your Personal Data

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above in “How we use your Personal Data and why.”, unless a longer retention period is required by law (for example for regulatory purposes).

Generally, we will store your information for as long as you’re using Butter, and for five years after that to comply with the law. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or the law says we need to.
Information related with website visits and marketing activities are typically stored for three years.

Our Notice on children

This Platform is not intended for individuals below 16 and we do not knowingly collect data relating to such children.

Complaints

If you would like to make a complaint regarding this Privacy Notice or our practices in relation to your Personal Data, please contact us at: jmr@buttersolutions.com

We aim to respond with 24 hours to all complaints and resolve them within the shortest time possible.
Under the regulatory framework we are required to send a final response within 15 business days. If you submit a complaint, we both must first attempt to resolve the issue directly between us.
However, if you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact The Danish Data Protection Agency

Third party links

This Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data.

We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy Notice of every site you visit.