VOLA privacy policy (GDPR)

At VOLA A/S ("VOLA”) we give high priority to confidentiality and data security. This privacy policy applies to our processing of personal data and establishes guidelines for the way VOLA processes your personal data and provides you with the information that you are entitled to receive under applicable data protection laws. You should read the privacy policy before you hand over your personal data to VOLA.

The data controller of your personal data is: 

VOLA A/S

Address: Lunavej 2, 8700 Horsens

CVR-no.: 17531328

E-mail: GDPR@VOLA.com

Phone number: + 45 70 23 55 00

VOLA uses cookies on the website and in this connection processes your personal data. Cookies are small text files sent to your browser from a web server and stored on your computer hard disk. We use cookies in order to be able to optimise the websites and the services available. VOLA may collect the following personal data about you, when you visit our website:

• IP address

• MAC address

• Browsing History

• Information about your use of our website, including click-behaviour, the version and language settings, date and time of the visit, browser type used.

We use cookies to collect the above-mentioned personal data. Cookies facilitate your efficient and easy use of our websites.

Your personal data may be processed for the following purposes:

• Marketing in general

• Product and service development

• Statistics and analysis

VOLA processes your personal data on the following basis:

• Legitimate interests: We base the processing of your personal data on our legitimate interests in, for example, conducting statistics, analyses, providing support, as well as improving and developing our products and services (Article 6(1)(f) of the General Data Protection Regulation)

When you visit our website, we ask for your informed consent to place cookies that are not functional cookies according to the cookie rules. You have the right to withdraw your consent at any time at the following link.

Cookies are deleted in accordance with our cookie banner.

However, the information may be stored for a longer period in anonymised form.

When you use and receive VOLA’s services, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems for the operation and functionality of VOLA's cookies and cookie banner, including VOLA’s website

• Data processors that provide IT systems to support marketing, statistics, and analysis

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

When using our contact forms on the website, contact customer service or otherwise communicate with us, VOLA collects, processes, and stores the following types of your personal data:

• Name, e-mail address, phone number, country, postal code

• What your enquiry is about, including information about your order

• Date of your enquiry

• Other information you provide in connection with your enquiry

• We encourage you not to provide sensitive personal data to us unless it is strictly necessary for the processing of your enquiry. In this context, the information should only be sent in a highly encrypted form if you send the information by e-mail

Your personal data will be processed for the following purposes:

• Handling of your enquiry

• General communication

• Statistics and analysis

VOLA processes your personal data on one or more of the following bases. The basis depends on the nature of your enquiry. 

• Legitimate interests: We may process your personal data on the basis of our legitimate interests in handling your enquiry, communicating with you, and developing our products and services (Article 6(1)(f) of the General Data Protection Regulation)

• Contractual obligations: If your enquiry concerns a (potential) formation of contract, we process your data to implement measures before the formation of contract (Article 6(1)(b) of the General Data Protection Regulation)

Your personal data will be deleted when we no longer need to process the data to fulfil one or more of the purposes mentioned above. 

General enquiries will be stored as long as such data is relevant for the handling and monitoring of the issue in question. The retention period depends on the content of the enquiry.

The retention period will typically be commensurate with the period laid down in the rules on limitation of legal claims.

VOLA is entitled to process your personal data for a longer period of time in anonymised form in which case we are no longer able to use the data to determine your identity.

If you are a customer or an employee of one of our suppliers, commercial (B2B) customers, or other business partners, we refer to the section below.

When you use and receive VOLA’s services, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems to support and manage customer service, including e-mail systems

• Data processors that provide IT systems for the preparation of statistics and analysis

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

VOLA collects, processes and stores your personal data for marketing purposes when you sign up for our newsletter. VOLA may collect, process and store the following types of your personal data:

• Name and e-mail address

• Your consent

• Your click-behaviour in relation to published material

• Your address

• Your postal code

• Your city

• Your country

• Your job title

Your personal data may be processed for the following purposes:

• Marketing

• Analysis and statistics

VOLA processes your personal data on one or more of the following bases:

• Consent: VOLA will only use your personal data for direct marketing, including for sending out newsletters and product information, if you have given your prior and explicit consent to this (Article 6(1)(a) of the General Data Protection Regulation)

• Legitimate interests: The processing of your personal data will, in connection with analysis and statistics, be based on our legitimate interests in being able to improve and develop our service (Article 6(1)(f) of the General Data Protection Regulation)

Your personal data will be stored as long as your consent to receive newsletters is active. 

You can always withdraw your consent by clicking on the unsubscribe link at the bottom of each e-mail or by contacting us as described below. We will then cease processing your personal data, unless we are entitled or obliged to continue our processing or storage of your personal data on another basis, including pursuant to the law. However, withdrawing your consent does not affect the legality of the processing that preceded the withdrawal. 

We will keep documentation of your consent to receiving direct marketing material. We will keep the documentation based on our legitimate interest in being able to demonstrate that we have sent direct marketing in compliance with applicable legislation (Article 6(1)( f) of the General Data Protection Regulation).

When you use and receive VOLA’s services, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems for the operation and functionality of Vola's platforms

• Data processors that provide IT systems to support marketing, statistics and analysis, including IT systems for customer relationship management

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

4. If you use the app [VOLA]

When you use the app [VOLA], VOLA collect, process and store the following types of your personal data:

• User behaviour/consumption pattern

• IP address

• Digital footprints

• Your faucet's serial number

• Date and time of using the app

• Information about the device you use to access the app

Your personal data will be processed for the following purposes:

• To make the app's features available to you

• Statistics and analysis

VOLA processes your personal data on the following basis. 

• Legitimate interests: We process your personal data based on our legitimate interest in developing and improving our products and services and making the app's features available to you (Article 6(1)(f) of the General Data Protection Regulation)

Your personal data will be stored for [insert retention period]. However, the information can be stored longer in anonymised form.

When you use and receive VOLA’s services, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems to support statistics and analysis

• Data processors that provide IT systems for the operation and functionality of VOLA's platforms, including the app

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

This section sets out the policy for VOLA processing of personal data in relation to recruitment. 

We recommend that your application does not contain sensitive or otherwise confidential personal data, such as personal data revealing racial or ethnic background, religion, trade union membership, sexuality, health information or social security number. 

VOLA may collect, process and store the following personal data:

• Contact information such as name, e-mail address and phone number

• Personal data which you have disclosed in your job application and CV as well as any attachments

• Personal data you disclose during any job interviews

• Information about you, including information regarding your previous jobs, activities, competencies, performance, as well as your general appearance, which is publicly available on the internet, including on social media

• Results of personality tests etc. (only if the job in question requires you to complete one)

• Criminal records (depending on the job in question you may be requested to submit a copy to us)

• References from your previous and/or current employers

• Health information if the position you have applied for places special demands on health conditions, or if, by virtue of your loyal duty of disclosure, you inform us of special health conditions that may affect your work performance or for which we must otherwise take special regard

• Additional information you will provide in relation to the recruitment process.

Your personal data will be processed for the purpose of assessing whether we can offer you a position at VOLA.

VOLA will mainly process your personal data based on the following bases:

• Legitimate interests: We may process your personal data based on our legitimate interest in assessing whether we wish to offer you employment, including based on the information you provide in your CV, application, and any attachments, based on relevant information that is publicly available on the internet and social media, results of personality tests, references from referees you have listed in your application, and other information you provide to us in connection with the recruitment process. The processing may also be necessary for our legitimate interest in defending or asserting legal claims (Article 6(1)(f) of the General Data Protection Regulation)

• Consent: If we cannot offer you an employment, we will in some cases offer you to save your application for later use, provided that you give your consent to this storage (Article 6(1)(a) of the General Data Protection Regulation). 

If, in exceptional circumstances, the position you have applied for imposes special requirements on health conditions that we must know about on a case-by-case basis before we can offer you employment, we will ask for your explicit consent prior to the processing of such data (Article 6(1)(a) and (b) and Article 9(2)(a) of the General Data Protection Regulation)

If you are offered a position with VOLA, your application and additional relevant personal data obtained during the recruitment procedure will be stored in your employee file.

If you are not offered a position, we will store your application and any additional personal data obtained during the recruitment procedure for a period of 6 months following our rejection, unless you have provided your consent to the storage hereof for a longer period. In the course of the first 5 months, you will be asked whether you wish to consent to us storing your application for a longer period of time. If you have applied for a job with our company in the Netherlands, your application will, however, be deleted after 4 weeks, unless you have provided your consent to storage for a longer period.

If you have completed a personality test or like, the results will be deleted as soon as the evaluation has been completed unless you are hired.

If we have collected your criminal records, we will delete them immediately after we have received and reviewed them.

You may at all times withdraw any consent you may have given as part of our recruitment procedure. Withdrawing your consent will affect the future processing of your personal data, but it will not affect the legitimacy of the processing that took place based on your consent given prior to such withdrawal. If you wish to withdraw your consent, please contact us, using the details below.

In connection with the administration and management of the recruitment process, VOLA may share your information with:

• Data processors that offer HR solutions to support recruitment, including providers of personality tests and recruitment systems

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

This section contains the policy for VOLA's processing of personal data of sole proprietorship owners or contacts of suppliers, commercial (B2B) customers and other business partners working with VOLA.

VOLA may collect, process, and store your personal data in the following cases:

• When your company or the company you work at enters into an agreement with VOLA

• When you have shown interest in VOLA's products and services, e.g., by providing VOLA with your business card

• When collaborating and communicating with VOLA

VOLA may collect, process and store the following types of personal data about you:

• Name, e-mail address, phone number, and corresponding contact information, correspondence

• Individual information, e.g., preferred languages

• Organisational information such as the name and address of the company, job title, employment area, primarily place and country of work

• Contractual information such as orders, invoices, contracts and other agreements between your company (or your employer) and VOLA that may contain e.g., your contact information

We may receive such information directly from you (primarily through e-mails and other correspondence with you) or from a third party such as your employer.

Your personal data may be processed for the following purposes:

• General planning, fulfilment and the management of collaborations, including contracts

• Administration such as the processing of payments, rating evaluations, accounting, auditing, as well as providing support

• General communication

VOLA processes your personal data on one or more of the following bases:

• Contractual obligations: In certain cases, the processing of your personal data is necessary to fulfil a contract (Article 6(1)(b) of the General Data Protection Regulation)

• Legitimate interests: We may process your personal data on the basis of our legitimate interests in, for example, managing day-to-day operations in accordance with legitimate and fair business practices, including planning, execution and management of the cooperation or our legitimate interest in, for example, performing  The processing may also be necessary for our legitimate interest in preventing fraud or establishing, defending, or asserting legal claims (Article 6(1)(f) of the General Data Protection Regulation)

• Legal obligation: The processing of your personal data will in some cases be necessary for compliance with legal obligations, such as our obligation to prevent illegal activities (Article 6(1)(c) of the General Data Protection Regulation)

Your personal data will be deleted when we no longer need to process the data to fulfil one or more of the purposes mentioned above. 

General enquiries will be stored as long as such data is relevant for the handling and monitoring of the issue in question. The retention period depends on the content of the enquiry.

The retention period will typically be commensurate with the period laid down in the rules on limitation of legal claims or the duration of our business relationship with you or your business.

VOLA is entitled to process your personal data for a longer period of time in anonymised form in which case we are no longer able to use the data to determine your identity.

When you use and receive VOLA’s services, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems to support communication

• Data processors that provide IT systems to support the administration of contract and collaboration relationships

• Data processors that provide IT systems to support marketing, statistics and analysis

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

This section contains the policy for VOLA's processing of personal data of customers who place orders for our products. This section also applies when we do business with, for example, sole traders or render support services to end-users.

When you make a purchase in one of our stores, VOLA may collect, process and store the following types of personal data about you:

• Your purchases

• Payment information

• Your contact information 

• Photo and video material related to video surveillance

The purposes of the processing

Your personal data may be processed for the following purposes:

• Completing your purchases

• To deliver the proper products and services to you and your business

• For legal claims to be established, invoked or defended

• Crime prevention (video surveillance) 

VOLA processes your personal data on one or more of the following bases:

• Contractual obligations: When the processing of your personal data is necessary to fulfil a contract and to deliver the proper products and services to you and your business (Article 6(1)(b) of the General Data Protection Regulation)

• Legitimate interests: In most cases, we base the processing of your personal data on our legitimate interests in being able to establish, defend or assert legal claims (Article 6(1)(f) of the General Data Protection Regulation). For example, this applies for the processing in relation to complaints. Information about offences collected through video surveillance is also processed in the light of VOLA's legitimate interest in solving criminal offences (Section 8(3) of the General Data Protection Act)

• Legal obligation: The processing of information about your payment information and purchases is necessary for compliance with applicable accounting legislation, VAT legislation, and marketing legislation (Article 6(1)(c) of the General Data Protection Act)

Information relating to accounting documents shall be kept for a period of five years from the end of the financial year to which the information relates.

Recordings from video surveillance conducted for the purposes of preventing and resolving crime will be deleted or anonymised no later than 30 days after the recording took place, unless it is necessary for VOLA to keep the recordings for the purpose of dealing with a specific incident.

However, the information can be stored for a longer period in anonymised form.

When you use and receive VOLA’s services, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems that support the sale of our products 

• Data processors that provide IT systems for the operation and functionality of VOLA's POS-system

• Data processors that provide IT systems to support marketing, statistics and analysis

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

VOLA may disclose your name and payment information with payment providers in connection with your purchases of our products and services. We may also disclose your contact information with delivery partners in connection with your delivery of your purchases.

When you visit our physical premises, for example, our factory or our showrooms or if you participate in functions and events organised by VOLA or in which VOLA participates, VOLA process your personal data. In several of our physical premises, we have installed video surveillance for crime prevention purposes. In the event of such surveillance, signs will always be displayed. VOLA may collect, process and store the following types of personal data about you:

• Your contact information

• Photo and video material related to video surveillance

The purposes of the processing

Your personal data will be processed for the following purposes:

• To be able to host exclusive functions and events

• Crime prevention (video surveillance) 

VOLA processes your personal data on the following basis: 

• Legitimate interests: We base the processing of your personal data on our legitimate interests in being able to give you access to our facilities, as well as in protecting our physical locations (Article 6(1)(f) of the General Data Protection Regulation). We also base our processing on our legitimate interest in being able to contact you again and document your presence or with a view to execute an agreement with you. Information about offences collected through video surveillance is also processed in the light of VOLA 's legitimate interest in solving criminal offences (Section 8(3) of the General Data Protection Act)

Recordings from video surveillance conducted for the purposes of preventing and resolving crime will be deleted or anonymised no later than 30 days after the recording took place, unless it is necessary for VOLA to keep the recordings for the purpose of dealing with a specific incident. 

However, the information can be stored for a longer period in anonymised form.

When you use and receive VOLA’s services, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems that support security solutions

• Data processors that provide IT systems to support marketing, statistics and analysis as well as the administration of customer service

• Data processors that provide IT systems for the administration and coordination of events

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

In the event of criminal acts or suspicion thereof, the recordings from our video surveillance may be disclosed to the police. VOLA's surveillance cameras are registered in the police's camera register. Disclosure may also occur if required by law.

This section contains the policy for VOLA’s processing of personal data collected through VOLA’s profiles or social media pages. 

VOLA has profiles or pages on the following social media platforms:

Facebook (Meta Platforms Ireland Ltd.)

• Facebook’s privacy policy is available here

• You can customise your privacy settings at Facebook here

YouTube (Google Ireland Ltd.)

• Google’s privacy policy is available here

• You can customise your privacy settings at YouTube here

LinkedIn Ireland Unlimited Company

• LinkedIn’s privacy policy is available here

• You can customise your privacy settings at LinkedIn here

Instagram (Meta Platforms Ireland Ltd.)

• Instagram’s privacy policy is available here

• You can customise your privacy settings at Instagram here

Pinterest (Pinterest Europe Ltd.)

• Pinterest’s privacy policy is available here

• You can customise your privacy settings at Pinterest here

For LinkedIn, Facebook, Instagram and Pinterest, VOLA together with the social media providers are joint data controllers for the processing of personal data collected in connection with your interactions with the profiles, including the profiles' postings. 

VOLA and the providers of LinkedIn, Instagram, Facebook and Pinterest have entered into an agreement on the allocation of the data protection tasks. According to these agreements, VOLA and social media providers are each responsible for the tasks associated with the processing we each undertake. However, it has been agreed between VOLA and the provider of Facebook and Instagram that the provider is responsible for enabling you to exercise your rights as described in the 'Your rights' section below in relation to the use of Facebook and Instagram, and that it is VOLA that is responsible for providing you with the information described below. In addition, it is agreed between VOLA and LinkedIn that LinkedIn is responsible for responding to requests from you regarding the rights described in the 'Your Rights' section below.

VOLA also uses the provider of YouTube as a data processor in connection with these entities' use of YouTube and in this connection also shares certain information about your interactions, interests, etc. with YouTube. This sharing takes place on the basis of our and Google’s legitimate interest in optimising marketing and the service, including our videos, on YouTube (Article 6(1)(f) of the General Data Protection Regulation).

When you visit or interact with our social media profiles, VOLA and the social media provider may collect, process, and store the following types of personal data about you:

• Information available on your profile, including your name, gender, civil status, workplace, interests, image, age and your city

• Whether you “like” or have applied other reactions to our profile

• Comments you leave on our posts

• That you have visited our profile

• Your IP address

VOLA processes your personal data for the following purposes:

• Improving our products and services, including our social media profiles and pages

• Statistics and analysis

• To be able to communicate with you if you comment on a post, make a review, or send us a message

• Marketing in general

Social media providers process your personal data for the following purposes:

• Improving their ad system

• To provide VOLA with statistics which the social media providers produce based on your visit to our profiles and pages

• Advertising and customising the activities on the page. 

The processing of your personal data is based on the following basis: 

• Legitimate interests: VOLA bases the processing of your personal data on our legitimate interests in being able to communicate with and market us to you on our social media profiles, as well as our legitimate interest in improving our products and services (Article 6(1)(f) of the General Data Protection Regulation)

Retention period

We keep your enquiries, which are not publicly posted, as long as such data is relevant for the handling and monitoring of the issue in question. However, the information can be stored for a longer period in anonymised form.

We encourage you to delete comments, likes, and other interactions you have left on our profile yourself if you no longer want them shown on our pages. VOLA does not delete such publicly available interactions.

Please see the privacy policy of each social media provider for information on how long they store your personal data.

When you use and receive VOLA's services, including visiting our social media, we may share your information with the following categories of data processors in connection with the delivery of these services:

• Data processors that provide IT systems to support and manage customer service and marketing

• Data processors that provide IT systems for the preparation of statistics and analysis

VOLA's data processors process your personal data on behalf of VOLA and solely in accordance with documented instructions issued by VOLA. Our data processors only have access to the information necessary to perform their specific tasks.

Who do social media providers share your personal data with?

Social media providers may, among other things, share your personal data with the following categories of recipients:

• Other entities in group of which the social media provider is a part of

• External partners providing analysis and survey services

• Advertisers

• Other individuals visiting our social media profile or page (to the extent that your information is publicly available)

• Researchers and other academics

You can find more information about who the social media providers share your personal data with, in each provider’s privacy policy. 

The social media providers may transfer their personal data to recipients outside the EU/EEA in accordance with applicable data protection legislation. You can read more in each provider’s privacy policy.

You can read more about who VOLA shares your personal data with, in the Section below.

Under each section above, you can read about the categories of recipients with whom we may share your personal data. The following applies in addition to the recipients we have specified for each section above. 

Changes in the corporate structure.

In the context of VOLA's development, the corporate structure may change, e.g., by the total or partial sale of the company. In the case of a partial transfer of assets containing personal data, the processing basis for the related transfer of personal data is, as a rule, Article 6(1)(f) of the General Data Protection Regulation, since VOLA has an interest in transferring parts of its assets and making commercial/structural changes.

Transmissions.

In addition to what is described above, your personal data is generally not disclosed to a third party without your consent. However, in certain circumstances e.g., if a commercial need exists for such disclosure, for example, being required to handle an order or your enquiry to us and under the law, it may be necessary to disclose your personal data to e.g. police, lawyers, auditors, courts, and other public authorities.

If your personal data are transferred to data processors or data controllers established in countries outside the EU/EEA that do not have an adequate level of protection, such a transfer will only take place once a transfer basis is secured. In addition, the transfer will be based on the EU Commission's standard contracts and/or EU-U.S. Data Privacy Framework. If you have any questions about the basis for transfers to countries outside the EU/EEA or want to request a copy of our transfer basis, please contact us at GDPR@VOLA.com.

• You have the right to access the personal data we process about you

• You have the right to object to our collection and further processing of your personal data

• You have the right to rectification and deletion of your personal data, however there are certain statutory exceptions, including the Danish Bookkeeping Act

• You have the right to ask us to restrict the processing of your personal data

• In certain circumstances, you may also request to receive a copy of your personal data and to transmit the personal data you have provided to us to another data controller (data portability)

• You can withdraw any consents you may have given at any time. We will then delete your personal data unless we may continue the processing on another basis. You can cancel our newsletter by clicking on the link at the bottom of the newsletter

If you have any questions about this privacy policy or if you wish to complain about the way we process your personal data, please feel free to contact us, VOLA A/S, Lunavej 2, 8700 Horsens, phone number: + 45 70 23 55 00, e-mail: GDPR@VOLA.com

If your complaint is not resolved by us and you want to proceed with the case, you can complain to the Danish Data Protection Agency, Carl Jacobsens Vej 35 2500 Valby, phone number: 33 19 32 00, e-mail: dt@datatilsynet.dk