hearttune

Privacy Policy

Privacy Policy

This privacy policy applies to hearttune, CVR 35331492, with registered office address at Højeloft Vænge 79, 3500 Værløse, Denmark.

The controller on personal data is hearttune. hearttune is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative, and physical security measures.

You are in general under no obligation to provide hearttune with any information, however, if you do not provide the required information regarding certain use cases set out in this privacy notice, hearttune may not be able to offer our services, process your corresponding request or get in contact with you, etc.

The privacy notice below explains what information hearttune gathers about you, what hearttune uses it for and who hearttune's shares it with. It also sets out your rights and who you can contact for more information or queries.

hearttune may also process information you provide to us in connection with an application for a job vacancy, for the assessment of your application and potential negotiation, preparation, conclusion and performance of an employment or service contract with you or management of your profile (Art. 6 para. 1 lit. b GDPR).

“Data Protection Legislation” means the EU General Data Protection Regulation 2016/679 ("GDPR"); together with all other applicable legislation relating to privacy or data protection and including any statute or statutory provision which amends, extends, consolidates, or replaces the same.

“Processing” means any operation performed on information about you, including to collect, disclose, record, organise, structure, store, alter, use, transfer, destroy or otherwise make available.

This privacy notice is updated October 2024.

What data does hearttune process?

hearttune may process information about you that: (i) you provide to hearttune, (ii) that hearttune obtains from third parties or (iii) that is publicly available. This information may include your name, age, gender, date of birth and contact details. It may also include ‘sensitive’ or ‘special categories’ of personal data, such as dietary requirements or mobility information.

How will hearttune use your data?

hearttune collects and process information about you and/or your business to enable hearttune to:

  • provide hearttune’s services to you or hearttune’s clients;
  • to enable us to provide you with information that hearttune thinks may be of interest to you; and
  • to meet hearttune’s legal or regulatory obligations.

When hearttune sends you information hearttune thinks you might be interested in, you have the right to unsubscribe at any time by contacting hearttune or by following the unsubscribe instructions in our communications.

hearttune may share information about you with third parties. hearttune may transfer some information about you to countries outside the European Union that have less stringent data protection laws. When hearttune do this, hearttune will make sure your information remains adequately protected.

What are your rights?

Your rights under Data Protection Legislation include the right to:

  1. request copies of your data; 
  2. request correction of your data; 
  3. request erasure of your data; 
  4. object to hearttune processing your data; and 
  5. ask hearttune to restrict the processing.

If you have any questions or comments about privacy issues, or wish to exercise any of the rights set out above, please write to hearttune’s Data Protection Officer, hearttune, Højeloft Vænge 79, 3500 Værløse, Denmark or email heidi@hearttune.dk

Who does this privacy policy apply to and what does it cover?

This privacy policy applies to hearttune. hearttune is committed to protecting your privacy and handling your information openly and transparently. This privacy policy explains how hearttune will collect, handle, store and protect information about you when:

  • providing services to you or hearttune’s clients;
  • you use hearttune’s website; or
  • performing any other activities that form part of the operation of hearttune’s business.

This privacy policy also contains information about when hearttune shares your personal data with other third parties – for example, our service providers.

In this privacy policy, your information is sometimes called “personal data”. hearttune may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.

What personal data does hearttune collect?

hearttune may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this notice.

When hearttune provides services to you or hearttune’s clients and perform due diligence checks in connection with hearttune’s services, or discuss possible services hearttune might provide, hearttune will process personal data about you. hearttune may also collect personal data from you when you use this website.

hearttune may process your data because:

  • you give it to hearttune – for example, in a form on our website;
  • other people give it to hearttune – for example, your employer or adviser, or third-party service providers that hearttune uses to help operate hearttune’s business; or
  • it is publicly available.

hearttune may also collect personal information if you register for the website using a third-party social network account, e.g., LinkedIn, Facebook, Instagram, and Twitter.

The information hearttune collects may depend on the privacy settings you have with the social network site, so please review the privacy notice or policy of the applicable social network site. When you access the website through your social network account, you are authorising hearttune to collect and use your information in accordance with this privacy notice.

hearttune may process personal data from you because hearttune observe or infer that data about you from the way you interact with hearttune or others. For example, to improve your experience of this website and to make sure that it is working effectively. For example, hearttune, or hearttune’s service providers, may use cookies on the hearttune website to ensure a user-friendly website visitor experience, e.g. session cookies, based on hearttune’s legitimate interest (Art. 6 para. 1 lit. f GDPR). Enhanced web analysis using cookies is, within the scope of applicability of the GDPR, based on your consent (Art. 6 para. 1 lit. a GDPR).

The personal data hearttune processes may include your:

  • name, gender, age and date of birth;
  • contact information, such as address, email, and mobile phone number;
  • country of residence;
  • employment and education details, for example, the organisation you work for, your job title and your education details;
  • postings or messages on any blogs, forums, platforms, wikis or social media applications and services that hearttune provides, including with third parties;
  •  IP address, browser type and language, your access times;
  • information in any complaints you make;
  • details of how you use hearttune’s products and services;
  • details of how you like to interact with hearttune, and other similar information relevant to our relationship.

If you choose not to provide, or object to hearttune processing, the information hearttune collects, hearttune may not be able to process your instructions or continue to provide some or all of hearttune’s services to you or hearttune’s client.

Personal data provided by or about third parties

If you share with hearttune information regarding any other individual, e.g. your employees, colleagues, ultimate beneficial owners, relatives, etc., you warrant, and shall procure that any member of your group/affiliates warrants, that the personal data to be transferred has been collected and processed in accordance with the requirements of the Data Protection Legislation and that the further processing and transfer of personal data by hearttune as set forth in this privacy notice is admissible by the Data Protection Legislation. Particularly you warrant that prior to any transfer of this personal data you have provided any necessary notice and collected any necessary permission from affected individuals, verified technical and organisational measures and do all such other things as are required under the Data Protection Legislation in order to disclose personal data to hearttune, and let hearttune process and transfer this personal data outside the European Union for the services.

How hearttune uses your personal data

hearttune processes information about you and/or your business to enable hearttune to provide hearttune’s services to you or hearttune’s clients, and to meet hearttune’s legal or regulatory obligations.

Some of your personal data may be used for other business purposes. Below are some examples.

How hearttune uses personal data to provide services to hearttune’s clients:

hearttune will use your personal data to provide you or hearttune’s clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:

  • you;
  • other third parties
  • hearttune’s service providers; or
  • competent authorities.

How hearttune uses personal data for other activities that form part of the operation of hearttune’s business:

hearttune may also use your personal data in connection with:

  • legal or regulatory requirements;
  • requests and communications from competent authorities;
  • client account opening and other administrative tasks;
  • relationship management, which may involve:
    • (a) sending you details of hearttune’s products and services;
    • (b) contacting you for feedback on services;
    • (c) sending you event invitations; and
    • (d) other marketing or research purposes;
  • recruitment and business development, which may involve:
    • (a) the use of testimonials from a client’s employees as part of hearttune’s recruitment and business development materials (with that employee’s permission); and
    • (b) the use of third-party data sources to help hearttune verify and improve the information hearttune holds about key business relationships with individuals;
  • protecting hearttune’s rights and those of hearttune’s clients.

How hearttune uses personal data collected via hearttune’s website:

In addition to the above, hearttune may also use your personal data collected via hearttune’s website:

  • to manage and improve hearttune’s website;
  • to tailor the content of hearttune’s website to give you a more personalised experience;
  • to draw your attention to information about hearttune’s products and services that may be of interest to you; or
  • to manage and respond to any request you submit through hearttune’s website.

The processing regarding website use is based on hearttune’s legitimate interest to operate and secure hearttune’s website and hearttune’s services, in particular for security reasons to ensure the stability and integrity of hearttune’s systems (Art. 6 para. 1 lit. f GDPR). In addition, hearttune may perform basic web analysis based on hearttune’s legitimate interest (Art. 6 para. 1 lit. f GDPR) to optimize the website regarding usability and to gain insights about the use of hearttune’s website and services. The collected data will not be merged with other personal data or disclosed to third parties. Enhanced web analysis using cookies is, within the scope of applicability of the GDPR, based on your consent (Art. 6 para. 1 lit. a GDPR).

Legal grounds for processing personal data

hearttune is required by law to set out in this privacy notice the legal grounds on which we rely in order to process your personal data. hearttune rely on one or more of the following lawful grounds:

  • you have explicitly agreed to hearttune processing your information for a specific reason;
  • the processing is necessary to perform the agreement hearttune has with you or to take steps to enter into an agreement with you;
  • the processing is necessary for compliance with a legal obligation hearttune has such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
  • the processing is necessary for the purposes of a legitimate interest pursued by hearttune or a third party, which might be:
  • (a) to provide hearttune’s services to you or hearttune’s clients and other third parties and ensure that hearttune’s client engagements are well-managed;
  • (b) to prevent fraud;
  • (c) to protect hearttune’s business interests;
  • (d) to ensure that complaints are investigated;
  • (e) to evaluate, develop or improve hearttune’s services or products; or
  • (f) to keep you or hearttune’s clients informed about relevant products and services and provide you with information unless you have indicated at any time that you do not wish hearttune to do so.

To the extent that hearttune processes any special categories of data relating to you for any of the purposes outlined above, hearttune will do so because:

  • you have given hearttune your explicit consent to process that data;
  • hearttune is required by law to process that data in order to ensure hearttune meet our ‘know your client’ and ‘anti-money laundering’ obligations , or other legal obligations imposed on hearttune;
  • the processing is necessary to carry out hearttune’s obligations under employment, social security or social protection law;
  • the processing is necessary for the establishment, exercise or defence of legal claims; or
  • you have made the data manifestly public.

Please note that in certain circumstances it may be still lawful for hearttune to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

Sharing your personal data

In connection with any of the purposes outlined in the “How hearttune uses your personal data” section above, hearttune may disclose details about you to:

  • competent authorities if hearttune is legally obliged or entitled to such disclosure or if it appears necessary to protect hearttune’s interests;
  • anyone to whom hearttune may transfer our rights and/or obligations under the Terms of Use;
  • credit reference agencies or other organisations that help hearttune make credit decisions and reduce the incidence of fraud;
  • service providers, e.g. IT service providers, business information providers, newsletter service providers, marketing and event management service providers, etc.;
  • legal and professional advisors, including accountants and auditors;
  • other third parties that reasonably require access to personal data relating to you.

hearttune’s website may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected, and used by other users of the application. hearttune has little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy notice.

Transferring your personal data

Information hearttune holds about you may be transferred outside Denmark, to the countries that offer adequate data protection pursuant to the Data Protection Legislation, e.g. to the EU, and under certain circumstances, hearttune may also transfer data to the countries which do not offer adequate data protection if necessary for the respective processing purpose, e.g.:

  • where hearttune do business;
  • which are linked to your engagement with hearttune;
  • from where you regularly receive or transmit information; or
  • where hearttune’s subprocessors or third parties conduct their activities.

These countries may have less stringent privacy laws than hearttune does, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, and other purposes.

When hearttune, or hearttune’s permitted third parties, transfer your personal data, hearttune will assure the transfer is secured by appropriate safeguards such as the EU Standard Contractual Clauses, or based on a statutory exemption, e.g. if you have given your consent to the transfer, and hearttune will impose contractual obligations on the recipients of that data to protect your personal data to the standard required by the Data Protection Legislation.

If hearttune transfers your personal data outside Denmark and the EU in other circumstances, for example, because hearttune has to by law, hearttune will make sure it remains adequately protected.

hearttune may share non-personal, anonymised and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.

How hearttune protects your personal data

hearttune uses a range of measures to ensure hearttune keeps your personal data secure, accurate and up to date. These include:

  • education and training to relevant employees to ensure they are aware of our privacy obligations when handling personal data;
  • administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
  • technological security measures, including fire walls, encryption and anti-virus software; and
  • physical security measures to access our premises.

The transmission of data over the internet (including by email) is never completely secure. So although hearttune uses appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.

For how long will hearttune keep your personal data?

hearttune seeks to ensure that hearttune only keeps your personal data for the longest of:

  • the period necessary for the relevant activity or services;
  • any retention period that is required by law; or
  • the period in which litigation or investigations might arise in respect of the services.

What are your rights?

You have various rights in relation to your personal data. In particular, you have a right to:

  • obtain confirmation that hearttune are processing your personal data and request a copy of the personal data hearttune holds about you;
  • be informed about the processing of your personal data, i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third-party sources from where it was obtained, confirmation of whether hearttune undertakes automated decision-making, including profiling, and the logic, significance and envisaged consequences;
  • ask that hearttune updates the personal data hearttune holds about you, or correct such personal data that you think is incorrect or incomplete;
  • ask that hearttune deletes personal data that hearttune holds about you, or restrict the way in which hearttune uses such personal data; withdraw consent to hearttune’s processing of your personal data (to the extent such processing is based on previously obtained consent);
  • receive a copy of the personal data concerning you, which you have provided to hearttune, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
  • ask hearttune to stop or start sending you marketing messages at any time by using the contact details in the section “Contact” below; and
  • object to our processing of your personal data.

If you would like to access or see a copy of your personal data, you must ask hearttune in writing. hearttune will endeavour to respond within a reasonable period, and in any event within one month in line with the Data Protection Legislation. hearttune will comply with hearttune’s legal obligations as regards your rights as a data subject.

To help hearttune ensure that your information is up to date, let us know if any of your personal details change using the contact details set out in the section “Contact” below.

You may also use the contact details in the section “Contact” below if you wish to make a complaint relating to your privacy.

Marketing

hearttune may process marketing data for marketing purposes and relationship management, for example to send personalized advertising for hearttune’s services and products, e.g. in the form of newsletters or other regular contacts either in person, via email or other electronic form, by phone or any other communication channel for which hearttune have contact information from you and by any other marketing means, e.g. through events, fairs, etc. hearttune does so based on hearttune’s legitimate interest to keep you informed about hearttune’s products and services (Art. 6 para. 1 lit. f GDPR), to the extent permitted by applicable marketing regulations, or, where required, based upon your consent in this regard (Art. 6 para. 1 lit. a GDPR).

You may, at any time, ask hearttune not to send marketing information to you by following the unsubscribe instructions in communications from hearttune, or contacting hearttune in the way described in the “Contact” section below.

Contact

If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about privacy issues, or you wish to raise a complaint about how hearttune is using your information, you can contact hearttune in the following ways:

  • write to hearttune’s Data Protection Officer, hearttune, Højeloft Vænge 79, 3500 Værløse, Denmark, or
  • send an email to heidi@hearttune.dk

If you believe that hearttune’s processing of your data contradicts the applicable data protection laws, you have the possibility to lodge a complaint with the appropriate data protection authority. The data protection authority in Denmark is Datatilsynet, Carl Jacobsens Vej 35, 2500 Valby, Denmark, www.datatilsynet.dk.

Changes to this privacy policy notice

This privacy policy notice does not form part of any contract with you and hearttune may amend it at any time. The version published on hearttune’s website is the version that currently applies. hearttune encourages you to review this privacy policy notice periodically to remain informed about how hearttune is protecting your information.