Privacy policy

Last modified: 1. November 2018

Data liability

At DEAS, we process personal data on behalf of our customers, for whom we are data processors. We have therefore adopted this privacy policy, which briefly tells you how we process your personal data and ensures you fair and transparent processing.

In some cases, DEAS itself is the data controller. This applies when the purpose of and the means by which the personal data is to be processed is determined by us.

Concerning all of our data processing, we only process personal data for specific purposes and based on justified (legitimate) interests. We only process personal data that is relevant and necessary to fulfil the specified purposes, and we delete your data when it is no longer needed.

  • Contact details for the data controller

    The data controller is usually your landlord or your association. Based on our role as a data processor for the landlord/association, we ensure that our processing of your personal data takes place in accordance with legislation.

    If you need to find information about data processing from the data controller, please contact your landlord/association.

    If you have any questions about the processing of personal data by DEAS, you are very welcome to contact:

    DEAS A/S
    Dirch Passers Allé 76
    2000 Frederiksberg
    CVR: 20 28 34 16
    Phone.: +45 70 30 20 20 
    Email: persondata@deas.dk

  • Processing of personal data

    At DEAS we process the following personal data:

    Information about tenants or sub-tenants:

    • Ordinary personal data:
      - Registration and contact details such as name, address, telephone number, email address, IP address, lease number
      - Anti-money laundering documentation, including photo identification
      - Title, occupation and educational background
      - Family circumstances and household details, including information about separation, divorce and the end of a cohabiting relationship
      - Payment details, including bank account, any payment default, insolvency or bankruptcy declarations and the attachment of deposits
      - Details of and correspondence relating to letting or sub-letting, including tenancy agreement, layout of the leased premises, consumption accounts, notification letters, laundry cards, access keys and cards, appeals, housing benefit
      - Registration numbers of cars, when renting a parking space
      - Reason for vacation, including death or moving to a nursing home
    • Personal data subject to a higher degree of protection:
      - CPR number

    Details of members or residents of an owner-occupied, cooperatively-owned or property-owner association:

    • Ordinary personal data:
      - Registration and contact details such as name, address, telephone number, email address, IP address, customer number
      - Anti-money laundering documentation, including photo identification
      - Title, occupation and educational background
      - Family circumstances and household details
      - Photos, pictures or video recordings
      - Payment details, including bank account, any payment default, insolvency or bankruptcy declarations, and attachment
      - Details of and correspondence relating to the membership of the association, including the value and layout of the cooperatively-owned unit or flat, as well as consumption accounts, laundry cards, access keys and cards, and appeals
      - Information recorded in the title register, such as easements, entitlements and debt
      - Reason for sale, including death, divorce, end of a cohabiting relationship or moving to a nursing home
      - Registration number of cars, for administration of parking spaces
    • Personal data subject to a higher degree of protection:
      - CPR number

    Information concerning applicants at findbolig.nu:

    • Ordinary personal data:
      - Contact details such as name, address, telephone number, email address
      - Information concerning the data subjects’ special affiliation and priority position, according to the landlord’s applicable allocation rules (member no., etc.)
      - Correspondence concerning the allocation of homes, including flat preferences, family circumstances and household
    • Personal data subject to a higher degree of protection:
      - CPR number

    Details of employees:

    • Ordinary personal data:
      - Registration and contact details such as name, address, telephone number, email address, IP address
      - Title, occupation and educational background
      - Family circumstances and contact details of next-of-kin
      - Photos, pictures or video recordings
      - Information for employment and payroll administration, including salary details, account details, tax card, training, length of service, secondary employment, working hours and tasks, access keys and cards, holiday planning, sick leave, maternity leave, employee benefits, social security, pension, criminal record, warnings, reprimands, dismissal and termination
    • Personal data subject to a higher degree of protection:
      - CPR number
      - Any trade union membership
      - Any misuse of alcohol or narcotics

    Details of contact persons at suppliers and business partners:

    • Ordinary personal data:
      - Registration and contact details such as name, address, telephone number, email address, IP address
      - Title, occupation, position and educational background

    Details of customers, the customer's beneficial owners and board members:

    • Ordinary personal data:
      - Registration and contact details such as name, address, telephone number, email address, IP address
      - Title, occupation, position, including board and executive board positions, educational background
      - Details of ownership of companies or properties that are included in the customer relationship, as well as related matters such as insurance, bank details, accounting and tax information, subscription rights and powers of attorney
      - Proof of identity for anti-money laundering purposes, including photo identification of the customer's beneficial owners and board members
    • Personal data subject to a higher degree of protection:
      - CPR number

    Information concerning secondary persons, such as relatives of tenants or employees:

    • Ordinary personal data:
      - Registration and contact details such as name, address, telephone number, email address, IP address
      - Title, occupation and educational background
      - Family circumstances

    In principle, DEAS does not process particularly sensitive information or information concerning criminal offences.

    However, there may exceptionally be cases under tenancy law whereby DEAS will process sensitive personal data in order to safeguard the customer's rights under other legislation if, for example, DEAS has a need to register a criminal offence in, or in connection with, the customer's properties, including to safeguard the customer's legal position on any claim for compensation or grounds for termination.

    Finally, in exceptional cases, DEAS may process sensitive personal data in connection with the handling of personnel matters for the customer's employees associated with the customer's properties, either to safeguard the customer's claims for reimbursement or compensation for public legal or insurance cover, or to safeguard the customer’s legal position in the event of any compensation claim, or as the notifier of any criminal offence.

  • Collection of information

    We will normally receive the information from you. In some cases, this may be from other sources, typically:

    • Public authorities, such as the tax information necessary for payment of salaries
    • Real estate agents
    • Landlord
    • Previous property administrator of the landlord/association
    • Other residents of the property
  • Purpose of processing your personal data

    We process your personal data for specific purposes when we or our customers, for whom we are data processors, have a lawful reason.

    Lawful reasons for processing are usually:

    • Necessary in order to fulfil a contract/agreement basis with you
    • Processing according to legal requirements, including the Danish Tenancy Act, Housing Regulation law, Bookkeeping Act and Anti-Money Laundering Act
    • Our own or our customers’ justified (legitimate) interests in processing your data (the balancing of interests rule)
    • Processing with consent

    Purposes:

    Purpose of processing information concerning tenants and sub-tenants:

    • Handling of letting or sub-letting conditions, including the collection of rent and the payment of deposits and similar payments
    • Fulfilment of statutory requirements
    • Administration of your relationship with us or with our customers

    Purpose of the processing of data concerning members or residents of an owner-occupied, cooperatively-owned or property-owner association:

    • Handling of the association’s operations and handling of members, including the collection of ownership and housing charges, as well as the planning, execution and follow-up of projects
    • Fulfilment of statutory requirements
    • Administration of your relationship with us or with our customers

    Purpose of processing information concerning applicants at findbolig.nu:

    • Handling of the waiting list, including collection of fees
    • Administration of your relationship with us or with our customers

    Purpose of processing data concerning employees:

    • Handling of employment conditions
    • Fulfilment of statutory requirements
    • Payment of salaries, allowances, reimbursements and similar

    Purpose of processing details of contact persons at suppliers and business partners:

    • Handling of supplier or cooperation agreement
    • Fulfilment of statutory requirements
    • Administration of your relationship with us or with our customers

    Purpose of the processing of details of customers and the customer's beneficial owners and board members:

    • Handling of administration agreement
    • Fulfilment of statutory requirements (Anti-Money Laundering Act)
    • Administration of your relationship with us or with our customers

    Purpose of the processing of information concerning secondary persons, such as relatives of e.g. tenants or employees:

    • Handling of agreement with the ‘principal party’
    • Handling on the basis of the wishes of the persons concerned
    • Fulfilment of statutory requirements
    • Administration of your relationship with us or with our customers
  • Processing of personal data on the basis of legitimate interests

    To the extent that we process your personal data on the basis of the balancing of interests rule, this processing will solely be motivated by justified (legitimate) interests. The following processing may typically occur:

    • We retain your ordinary personal data for a period of time after the expiry of your tenancy, after withdrawal from the association or after the expiry of your supplier agreement, or your customer relationship, etc. This takes place in accordance with applicable legislation (e.g. the Anti-Money Laundering Act or the Bookkeeping Act), which obliges us to retain information for a given period. In addition, information is retained for practical and administrative reasons and in respect of the limitation rules.
    • We forward your ordinary personal data to the customer, accountant, craftsmen, rent board, attorney, estate agents, or potential buyers of the property, to the relevant and necessary extent in conjunction with the operation and administration of the property.
    • For use as a comparative lease, your tenancy agreement, notices of rent increase and overviews of rental debt collections may be disclosed to the landlord's attorney, rent board or other landlords, as well as their representatives, with an interest in documentation of the value of the lease.
    • Both retention and disclosure will take account of the landlord’s interest in being able to document the basis for determining the rent for the property or in a particular lease, and the landlord’s obligation and interest in maintaining good conduct and order in the property.
  • Consent

    Our processing of your personal data will usually be based on a legal basis other than consent. We therefore only obtain your consent when, in rare cases, this is necessary in order to process your personal data for the purposes described above.

    If we obtain your consent, such consent will be voluntary, and you may withdraw it at any time by notifying us thereof.

  • Disclosure of your personal data

    In connection with the operation and management of our customers’ properties, information is disclosed to business partners and suppliers, including accountants, attorneys and real estate agents, and to dispute resolution bodies, such as rent boards and courts.

    Processing by third parties takes place solely for specific purposes. If information is disclosed to (sub)data processors, a data processing agreement will oblige them to process your personal data confidentially and to take appropriate technical and organisational security measures to prevent the accidental or unlawful destruction, loss or impairment of the information, or that it is disclosed to unauthorised persons, misused or otherwise processed in conflict with data processing legislation.

    If properties are to be sold, relevant information concerning the property, including residential and rental conditions, will be disclosed to potential buyers. If the property is subject to the rules concerning the obligation to make an offer, the information will also be disclosed to the property’s other residents.

    For use as a comparative lease, tenancy agreements may be disclosed to the landlord's attorney, rent board or other landlords, as well as their representatives, with an interest in documentation of the value of the lease.

    If representation of the residents of a property has been established, in accordance with tenancy legislation, relevant information concerning tenants will be disclosed to the resident representatives.

    Your personal data will not be transferred to other countries outside the EU/EEA and countries that do not have laws providing special protection of personal data, to safeguard processing.

    We do not disclose personal data to companies for marketing purposes without your consent.

  • Retention and erasure of your personal data

    Processing purposes and retention periods may apply, depending on whether we process your personal data as a tenant or sub-tenant, as a member of the association, as a resident of an owner-occupied, cooperatively-owned or property-owner association, as an applicant on Findbolig.nu, as an employee of the property, as a contact person of a supplier or business partner, as a customer or the customer's beneficial owner or board member, or as a secondary person.

    Tenant or sub-tenant:

    We will retain your personal data for a period of time from the expiry of your letting or sub-letting agreement, and in accordance with the following criteria:

    • For practical and administrative reasons, and for the purposes of the Bookkeeping Act, the Anti-Money Laundering Act and the limitation rules, we retain your data for up to 5 years after the end of the financial year in which your activity ceased.

    Members of an owner-occupied, cooperatively-owned or property-owner association:

    We will retain your personal data for a period of time after the expiry of your membership, and in accordance with the following criteria:

    • For practical and administrative reasons, and for the purposes of the Bookkeeping Act, the Anti-Money Laundering Act and the limitation rules, we retain your data for up to 5 years after the end of the financial year in which you withdrew from the association.

    Applicants at findbolig.nu:

    We will retain your personal data for a period of time from the expiry of your membership of the waiting list, and in accordance with the following criteria:

    • For practical and administrative reasons, and for the purposes of the limitation rules, we retain your data for up to 5 years after the end of the financial year in which your membership expired.

    Property employees:

    We will retain your personal data for a period of time from the end of your employment, and in accordance with the following criteria:

    • For practical and administrative reasons, and for the purposes of the Bookkeeping Act and the limitation rules, we retain your data for up to 5 years after the end of the financial year in which your employment ended.

    Contact persons at suppliers and business partners:

    We will retain your personal data for a period of time from the expiry of the supplier or cooperation agreement, and in accordance with the following criteria:

    • For practical and administrative reasons, and for the purposes of the Bookkeeping Act and the limitation rules, we retain your data for up to 5 years after the end of the financial year with the last delivery, or in which the cooperation ended.

    Customers, the customer's beneficial owners and board members:

    We will retain your personal data for a period of time from the end of the customer relationship, and in accordance with the following criteria:

    • For practical and administrative reasons, and for the purposes of the Bookkeeping Act, the Anti-Money Laundering Act and the limitation rules, we retain your data for 5 years after the end of the financial year in which the customer relationship ended.

    Secondary persons who are relatives of e.g. tenants or employees Beneficial owners and board members of customers:

    • For practical and administrative reasons, we retain your information for up to 5 years after the end of the financial year in which the principal relationship ends.

    We retain information that is relevant as documentation of the rent fixing or other important aspects of the property, such as tenancy agreements, rent notifications, rent board decisions and rulings, for as long as they may be necessary.

  • Security

    We have implemented both technical and organisational security measures intended to protect your data from accidental or unlawful destruction, and from the loss or impairment of the data, or from it being disclosed to unauthorised persons, misused or otherwise processed in contravention of legislation concerning the processing of personal data. In order to ensure this, IT security regulations and processing rules have been established, as a consequence of our ISO-certified quality management system.

  • Use of cookies

    On our website, we use ‘cookies’. A cookie is a small text file that is saved in the web browser of your computer, smartphone, iPad, or whichever device you use when you visit the website. Cookies make it possible to recognise your computer, etc. and to gather information about your online behaviour, including which pages and features are visited with your browser, and to ensure its technical functioning. In some cases, cookies are the only way to make a website function as intended. A cookie is a passive file that cannot collect information on your computer, or spread computer virus or other malware. It is anonymous and does not contain any personal data. Cookies are used by virtually all websites.

    Read more about our cookie policy here: www.deasgroup.com/about-deas/cookie-policy.

  • Your rights

    You have a number of special rights under the General Data Protection Regulation, when we process personal data about you:

    • Right to be informed about the processing of data
    • Right of access to your own personal data
    • Right of rectification
    • Right of erasure
    • Right to restriction of processing
    • Right to data portability (issue of data in a generally used format)
    • Right of objection

    You may exercise your rights, including objecting to our processing, by contacting us. You can find our contact details at the top of the page.

    If you, for example, request to have your personal data rectified or erased, we will investigate whether the conditions are fulfilled and, if so, rectify or erase the data as soon as possible.

    You have the opportunity to complain about the processing of information and data relating to you. Complaints may be submitted to the Danish Data Protection Agency, Borgergade 28, DK-1300 Copenhagen K.

  • Email newsletters: Processing of your data

    Once you have signed up for one of our newsletters, we will register your name and email address. This data is used to email newsletters and invitations to events.

    In connection with your registration, in some cases you can give us additional information about yourself, such as your address or type of housing. This information is used to provide you with better service and content.

    You can always unsubscribe from our email newsletters via the unsubscribe link at the bottom of each email, thereby withdrawing your consent.

    We use MailChimp to email our newsletters. MailChimp is a certified supplier outside the EU, and you can read MailChimp’s privacy policy on their website

Revision of the privacy policy

We reserve the right to make changes to this privacy policy from time to time. When any changes are made, the date at the top of the privacy policy will be changed. The privacy policy applicable at any time will be available on our website. You will be notified of any material changes.

3rd edition, November 2018.