1. Introduction

At RTX A/S, Stroemmen 6, 9400 Noerresundby, Denmark, business and VAT registration number DK17002147 (“RTX", "we", us" and "our"), we understand and place a very high priority on the importance of processing personal data securely and confidentially. This Privacy Statement ("Privacy Statement") is intended for you - our website user, course or events attendant, survey participant, contact person from our corporate customer, other business partner, and/or investor - with whom we interact and describes how we process personal data about you. RTX is committed to complying with the requirements and obligations relating to the processing of personal data under applicable law, including the General Data Protection Regulation ("GDPR"). We have therefore implemented appropriate procedures to protect your personal data.

RTX is the data controller for the processing of your personal data. This Privacy Statement provides an overview of RTX's processing activities, including the purposes and legal basis of the processing.

Please note that for certain personal data processing activities, RTX is to be regarded as data processor acting on behalf of our customers, for instance if RTX administers a whistleblower scheme or provides an electronic platform, such as a data room or a tender portal. When RTX performs as data processor, RTX acts in accordance with the instructions from the data controller and on the basis of a data processing agreement between the customer and RTX governing the specific personal data processing activities. In such instances, this Privacy Statement does not apply to the processing of your personal data. If you wish to learn more about the processing of your personal data in those situations, we kindly refer to you contact the party responsible for the matter you are involved in directly.  

If you have any questions in relation to this Privacy Statement, or if you wish to exercise your rights under Chapter III of the GDPR in accordance with item 5 of this Privacy Statement, please contact RTX at info@rtx.dk.

 

2. Processing activities

2.1  Website visitors

2.1.1   What personal data do we process and for what purposes

When you visit RTX's website, www.rtx.dk ("Website"), you will be asked to consent to the use of cookies or to reject the use of some or all cookies. A cookie is a small text file sent to your browser from our Website and stored on your computer, phone or other device that you use to access the Internet.

When we process and store cookies, we will be processing personal data about you, for example to improve your user experience and the functionality of our Website, to compile statistics, to target advertisements to your needs, and to remember your preferences. We do not record any information that can identify you directly, such as your name and address. We do, however, record information about how you navigate the Website so that we may learn more about how our Website is used, and we also record your IP address along with browser information and time spend on the Website, etc., which may identify you indirectly.

For more information about our use of cookies, including how to disable cookies through your device of browser settings, please consult our Cookie Declaration. Please note that certain cookie may be essential for basic functions of the Website and we thus encourage you to accept the use of cookies to ensure optimal function and use of the Website.

 

2.1.2   Legal basis

The legal basis for the processing of your personal data, when we place cookies, is RTX’s legitimate interests, which, in RTX’s view, are not overridden by your fundamental rights and freedoms as provided in Article 6(1)(f) GDPR. The legitimate interests pursued by RTX are to make a well-functioning website available, to provide a unique user experience, and to engage in marketing activities. In some cases, the legal basis is your consent, which you will be asked to give when you visit our Website as provided in Article 6(1)(a) GDPR.

 

2.1.3   Disclosure of personal data

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes.

If RTX uses third-party cookies, we will disclose your personal data with these third-party cookie providers, including social media providers as specified in para. 4 below.

Additionally, your personal data will be processed by certain other third parties, among them the provider of the technical solution behind our Website, on RTX’s behalf and in accordance with RTX’s instructions and the obligations laid down in the data processing agreement concluded with RTX. These data processors may not process your personal data for their own purposes.

 

2.1.4   Storage of personal data

Personal data collected via cookies during visits to our Website are stored for different periods of time depending on the type and purpose of the cookie. For details, please see the table in abovementioned Cookie Declaration.

Personal data collected through the use of social media will be deleted as soon as the content in question is deleted or when you remove your reaction to our content (like, share, etc.). For details, see item 4 below.

 

2.2  Recipients of newsletters and webinar listeners

2.2.1   What personal data do we process and for what purposes

You can sign up for newsletters containing information about our business, products, services, career opportunities via our Website. This also includes brochures, invitations, information on webinars, podcasts or similar, courses, events, surveys, and other activities. If you subscribe to our newsletters or a webinar, we will process the following personal data about you: Name and surname, interest(s) and your e-mail address. The purpose of the processing is to enable us to promote our business.

 

2.2.2   Legal basis

The legal basis for our processing of personal data about you is our legitimate interests in promoting our business, products and services via newsletters and webinars, etc., see Article 6(1)(f) GDPR.

Note that you can withdraw your consent to receiving our newsletter at any time. To unsubscribe from our newsletters, please use the link included in each newsletter or contact us at info@rtx.dk. 

 

2.2.3   Disclosure of personal data

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes.

Certain third parties, among them the provider of the technical solution helping us deliver and handle newsletters and run the webinar programme, will process personal data about you on RTX’s behalf and in accordance with RTX’s instructions and the obligations laid down in the data processing agreement concluded with RTX. These data processors may not process your personal data for their own purposes.

If you sign up for a webinar on our Website, you will in connection with signing up receive more information about the processing of your personal data during the webinar including who the webinar or podcast provider is.

 

2.2.4   Storage of personal data

Personal data in relation to your newsletter profile will be stored until such time as you withdraw your (marketing) consent and no longer wish to receive newsletters from us.

Personal data from you registration to a webinar or a podcast will only be stored until the webinar or podcast has run. This only applies if you did not agree to be contacted after the end of the webinar or podcast.

 

2.3  Users of the online contact form

2.3.1   What personal data do we process and for what purposes

If you use our online contact form on the Website, we will process your first and last name, email, phone number, subject of your enquiry and content of your enquiry which normally includes the name of the company you are representing, your job position and department and your work address.

Note that certain of the text boxes in the contact form are mandatory meaning that you are required to state and submit certain personal data in order to send us your enquiry. It will appear from the relevant text box whether it is mandatory or optional. If it is mandatory, the text box is marked by an asterisk (*). Should you decide not to surrender the required information, you cannot submit your enquiry.

RTX will not process special categories of personal data (sensitive personal data) about you, e.g., health data, unless you have provided such data yourself, for example through the chat service. We kindly ask that you do not send any sensitive personal data to us as this is not necessary for us to answer your enquiry.

 

2.3.2   Legal basis

The legal basis for our processing of personal data about you is our legitimate interests in providing you with a responsive answer and in assisting you with any information you have requested about RTX, our product and services, which, in RTX’s view, are not overridden by your fundamental rights and freedoms as provided in Article 6(1)(f) GDPR.

 

2.3.3   Disclosure of personal data

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes.

In certain specific cases, e.g., in the context of disputes, including where disclosure is necessary for the establishment, enforcement, or defence of RTX's legal claims, RTX may disclose your personal data to advisors or other relevant third parties, if deemed lawful and necessary.

Additionally, your personal data will be processed by certain third parties, among them the provider of the technical solution for Website which also includes the online contact form, on RTX’s behalf and in accordance with RTX’s instructions and the obligations laid down in the data processing agreement concluded with RTX. These data processors may not process your personal data for their own purposes.

 

2.3.4   Storage of personal data

Inquiries from potential customers or other business partners will be deleted one year after the inquiry is resolved, unless a longer retention period is required for documentation purposes, e.g., to a dispute, including for the establishment, exercise, or defence of legal claims.

Inquiries from existing customers or other business partners will be deleted three years after termination of the contractual relationship, unless a longer retention period is required for documentation purposes, e.g., to a dispute, including for the establishment, exercise, or defence of legal claims.

 

2.4  Contact persons at customers and other business partners

2.4.1   What personal data do we process and for what purposes

As a contact person at one of our customers, suppliers, or other business relations, RTX will process personal data about you when you communicate with us, for example via emails in the context of RTX's contractual relationship with the company by which you are employed or in the context of the conclusion or termination of a contract.

RTX will process general personal data about you, including your name and surname, email address, telephone number, job title, etc. To the extent you place orders and carry out purchases on behalf of the company you are representing, we will also process information on the order, company bank and payment details, your signature, etc.

 

2.4.2   Legal basis

The legal basis for the processing of your personal data is RTX’s legitimate interests, which, in RTX’s view, are not overridden by your fundamental rights and freedoms as provided in Article 6(1)(f) GDPR. The legitimate interests pursued by RTX are the performance of our contractual obligations, the establishment, maintenance and strengthening of our customer relationships, the invoicing of the services provided to RTX by the company you are employed by and vice versa, and for documentation purposes where an agreement is concluded by email.

In certain cases, the processing of your personal data is necessary to comply with a legal obligation imposed on RTX, for example in connection with the storage of accounting records under the Danish Bookkeeping Act. In such cases, the legal basis is Article 6(1)(c) GDPR.

 

2.4.3   Disclosure of personal data

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes.

In certain specific cases, e.g., in the context of disputes, including where disclosure is necessary for the establishment, enforcement or defence of RTX's legal claims, RTX may disclose your personal data to advisors or other relevant third parties, if deemed lawful and necessary.

 

2.4.4   Storage of personal data

If you are a contact person of one of RTX's customers, suppliers or other business associates, RTX will process personal data about you for as long as RTX is communicating with you because you are our contact person and up to three years after termination of the contractual relationship, or until your personal data is no longer necessary for the establishment, exercise or defence of legal claims.

If your personal data are included in RTX's accounting records, e.g., in connection with invoicing, your data will be stored for five years from the end of the financial year to which the accounting records relate. This is to ensure compliance with our legal obligations under the Danish Bookkeeping Act.

 

2.5  Contests participant

2.5.1   What personal data do we process and for what purposes

If you participate in one of RTX's contests via the Website or in physical form/writing, we will process personal data about you, such as your name, contact details, and your contribution to the contest.

 

2.5.2   Legal basis

The legal basis for our processing of personal data is our legitimate interests in organising the contest, drawing, and contacting the winner, see Article 6(1)(f) GDPR. Where required, we will disclose your name and information about the prize to the tax authorities, see Article 6(1)(c) GDPR.

 

2.5.3   Disclosure of personal data

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes.

Should you win the contest, RTX will disclose your personal data to the postal distributor (if the prize is shipped to you) and, if required, to the tax authorities. Further, we may choose to publish the winners name on our Website and our social media sites.

Additionally, your personal data will be processed by certain third parties, among them the provider of the technical solution for the contest, on RTX’s behalf and in accordance with RTX’s instructions and the obligations laid down in the data processing agreement concluded with RTX. These data processors may not process your personal data for their own purposes.

 

2.5.4   Storage of personal data

RTX will retain your personal data only for as long as is necessary for the purposes for which they are processed. Your personal data will be deleted one year after the contest is completed.

If your personal data are included in RTX's accounting records, e.g. because you won the contest, your data will be stored for five years from the end of the financial year to which the accounting records relate. This is to ensure compliance with our legal obligations under the Danish Bookkeeping Act.

 

2.6  Investors

2.6.1   What personal data do we process and for what purposes

As one of your investor relations, we process certain personal data about you.

If you are a private investor or you are representing a company, where the owner is a natural person and thus comprised by the GDPR, such as a sole proprietorship, that intent to invest or already is investing in our business, we will process your identification and contact information. If you, on the other hand, are representing a company, where the owner cannot be attributed to a natural person, that intent to invest or already is investing in our business, we will process the same information on the company's beneficial owners. The purpose of the processing of personal data is to facilitate and administer investments to benefit our business including in some cases to comply with a legal obligation imposed on RTX to retain certain information. 

 

2.6.2   Legal basis

The legal basis for our processing of your personal data is based on our legitimate interests in establishing and maintaining investor relations, which, in our view, are not overridden by your fundamental rights and freedoms as provided in Article 6(1)(f) GDPR. Further, the processing is based on a legal obligation to under applicable AML and tax rules to obtain and register certain information, see Article 6(1)(c) GDPR.

If you are a private investor or you are representing a sole proprietorship or other company comprised by the GDPR, our processing is also based on a contractual relationship between RTX and you or your company, see Article 6(1)(b) GDPR..

 

2.6.3   Collection and disclosure of personal data

Apart from the personal data provided by you, we also obtain information about you from external public sources, such as the Central Business Register which is a publicly available register.

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes, such as the provider of the technical solution for the administration of investor relations.

Further, we will disclose your personal data the public authorities, such as tax authorities and the Danish Business Authority if required by law. This disclosure may include your civil security number if the disclosure is demanded by a public authority, see section 11(2)(3) Danish Data Protection Act.

 

2.6.4   Storage of personal data

RTX will retain your personal data only for as long as is necessary for the purposes for which they are processed.

If you represent a potential new investor, we will retain your personal data as long as RTX is communicating with you and for a period hereafter depending on the nature of our communication taking into account when your personal data is no longer necessary for the establishment, exercise or defence of legal claims.

If you are representing an existing investor, we will retain your personal data as long as the investor relation exists and 5 years after termination hereof. This is to ensure compliance with our legal retention obligations under applicable AML and tax legislation, including if relevant the Danish Bookkeeping Act.

 

2.7  Attendants in events and courses

2.7.1   What personal data do we process and for what purposes

If you attend courses you have signed up for or events, such as open house or employer branding events, we will process your name, email, phone number, job position and employer, and information on the type of course or event you have chosen to participate in, including the date, time and location of the course or event and payment information, if relevant.

In certain cases, the processing of your personal data is necessary to comply with a legal obligation imposed on RTX, for example in connection with the storage of accounting records under the Danish Bookkeeping Act. In such cases, the legal basis is Article 6(1)(c) GDPR.

We may choose to document the events. If we do so, we will take pictures, images, audio and/or video recordings or the like during the events. Please note that we own all rights to the images and other material without limitation and our rights remain in force regardless of when the images, etc. were taken and last used. Rest assured that all material taken and used are harmless, and we assure not to use any material that may appear offensive to you or other in any way.

 

2.7.2   Legal basis

The legal basis for our processing of personal data is our legitimate interests in carrying out the courses and events to create awareness and promote our business, which, in our view, are not overridden by your fundamental rights and freedoms as provided, see Article 6(1)(f) GDPR.

Likewise, is the legal basis for taking pictures or other material during events our legitimate interests in branding and promoting our business and products, see Article 6(1)(f) GDPR.

 

2.7.3   Disclosure of personal data

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes. 

Additionally, your personal data will be processed by other, among them the facilitators and lecturers of the courses or events including professional photographers, where relevant. 

Pictures or other branding material taken during events may be published at our Website or our social media sites.

 

2.7.4   Storage of personal data

RTX will retain your personal data only for as long as is necessary for the purposes for which they are processed. Your personal data will be deleted one year after the respective course or event has finalised.

If your personal data are included in RTX's accounting records, e.g., in connection with invoicing, your data will be stored for five years from the end of the financial year to which the accounting records relate. This is to ensure compliance with our legal obligations under the Danish Bookkeeping Act.

Pictures or other material taken during events will be deleted when they no longer serve a purpose.

 

2.8  Survey participants

2.8.1   What personal data do we process and for what purposes

If you participate in one of our satisfaction surveys, typically sent via our newsletter or available via the Website, we will - depending on the specific survey - process your first and last name, email address, phone number, job position, and your answers.

You may at any time request not to receive satisfaction surveys by contacting us in writing or by using the unsubscription link at the bottom of the survey email.

 

2.8.2   Legal basis

The legal basis for our processing of personal data is our legitimate interests in conducting the survey to develop and improve our business, products and services, which, in our view, are not overridden by your fundamental rights and freedoms as provided, see Article 6(1)(f) GDPR.

 

2.8.3   Disclosure of personal data

To the extent necessary and legitimate, RTX will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes. 

Additionally, your personal data will be processed by certain third parties, among them the provider of the technical solution for the survey, on RTX’s behalf and in accordance with RTX’s instructions and the obligations laid down in the data processing agreement concluded with RTX. These data processors may not process your personal data for their own purposes.

 

2.8.4   Storage of personal data

RTX will retain your personal data only for as long as is necessary for the purposes for which they are processed. Your personal data will be deleted or anonymised one year after the survey has finalised and the related analyses are completed.

 

2.9  Job applicants

When you apply for a vacancy at RTX via the Website, we will collect and process personal data on you as a job applicant, including store your job application, your CV, and other relevant material in case a relevant vacancy occurs in RTX in the future. Be assured that all job applications are treated strictly confidential and only shared internally with appropriate employees, such as the hiring department manager. 

We strongly recommend that you use our RTX job database when you submit your application. The job database is an external platform provided by Easycruit, a cloud provider developed by Visma. Before submitting your application or registering in the job database, you must read and agree with the privacy statement tailored the processing of job applicants' personal data during recruitment. 

RTX kindly requests that you only submit personal data about yourself in your job application, CV or other relevant material you choose to provide to us, to the extent such information is relevant for the specific position you are applying for. For this reason, please do not include information on your personal identification number - such as a civil registration number if you are a Danish citizen - in the submitted documents and consider whether there is any other personal information, such as health information, information on family relations or similar, that is not necessary for RTX's recruitment process.

If we do not have a vacant position that matches your qualifications and ambitions, you may choose to register in our job database for a period of 6 months (applies for job applicants to a job in Denmark) subject to your prior consent. You may, at any time remove your details from our job database.

 

3.  Transfer of personal data to third countries (countries outside the EU/EEA)

In certain cases, your personal data may be transferred to countries outside the EU/EEA, for example through the use of an IT solution provider located in such country. RTX will ensure that the transfer takes place in accordance with applicable data protection law. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the EU Commission's Standard Contractual Clauses. RTX will ensure the implementation of additional safeguards if deemed necessary on a case-by-case basis. You can request a copy of the legal basis for the transfer by contacting info@rtx.dk.

 

4.  Social media

Our Website features integrated plug-ins from the social media Facebook, LinkedIn, Vimeo and YouTube. When you visit any of our social media pages or our Website with integrated plug-ins, the social media providers will collect and process personal data by means of cookies, provided you have consented to the use of cookies. Such collection and processing of personal data will take place whether you have a social media profile or not.

If you access our Website, which features integrated social media plug-ins, your browser will contact the server of that social medium, load the visual presentation of the plug-in and present the content to you. While this is happening, the social media provider will receive information about your use of the Website, as well as additional personal data, such as your IP address. RTX will receive anonymous demographic and geographic statistics from the social media provider about visitors to our Website and our social media pages.

RTX is joint data controller together with the social media providers for the processing of personal data in connection with visits to our social media pages and our Website. This means, i.a., that you can contact both RTX and the social media provider if you wish to exercise your rights under the GDPR. Facebook, Instagram, LinkedIn, Twitter and YouTube have primary responsibility for ensuring compliance with the GDPR and for responding to requests to exercise data subjects' rights. If you have a social media profile, you can exercise your rights through your account settings.

We have no influence on the amount of personal data that the social media provider collects via the active plug-ins. For details, please refer to the relevant privacy Statement:

• Facebook: http://www.facebook.com/policy
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
• Vimeo: https://vimeo.com/privacy
• YouTube: https://policies.google.com/privacy?hl=en

 

5.  Your rights

Derived from our processing of personal data about you, you will have the rights described below. However, some rights apply only in certain circumstances and may be subject to certain statutory limitations. The Danish Data Protection Agency has issued guidance on the rights of data subjects. For details about your rights, please see here (in Danish).

• You have the right to request access to, and receive a copy of, the personal data that we are processing about you and, in this context, also to receive a range of additional information.
  
  
• You have a right to have incorrect personal data about yourself rectified and to have incomplete personal data completed.
  
  
• You have the right to request that personal data about you be deleted in certain circumstances, e.g., if processing is based on your consent and you choose to withdraw that consent.
  
  
• You have a right to have the processing of your personal data restricted, e.g., if the accuracy of the personal data is contested.
  
  
• Where our processing is done automatically and is based on your consent or the performance of an agreement with you, you have the right to request to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format and to request the transmission, where technically feasible, of such data to another controller.
  
  
• You may object to the processing of your personal data by us, including in particular in relation to direct marketing.
  
  
• You may request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  
  
• You may withdraw your consent to the processing of your personal data at any time. Withdrawal of your consent will not affect the processing of your personal data that took place before the date of withdrawal, however. Note that we generally do noy process your personal data on the basis of consent.
• You may file a complaint with the Danish Data Protection Agency using the contact details that are available here if you disagree with the way in which RTX processes your personal data. However, we hope that you will contact us first, using the contact details referred to below, so that we may try to come to an agreement and satisfy your wishes.

If you wish to exercise any of the above rights, or if you wish to withdraw your consent, please feel free to contact us at info@rtx.dk. Be aware that the mentioned right is personal. Accordingly, we may ask that you provide us with adequate information to process your inquiry, including your full name and your email address, so that we may identify you and respond to your inquiry. We will respond to your inquiry as soon as possible.

 

6.  Securty measures

RTX has taken a number of measures to protect your personal data and safeguard your rights. This includes implementation of appropriate procedures to protect the Website against unauthorized use, loss, or alteration of personal data under our control. We have a range of internal procedures and policies designed to ensure that we live up to our high security standards and thus comply with the requirements for adoption of suitable technical and organizational security measures. Thereby, we do our best to safeguard the quality and integrity of your personal data.

Note that RTX disclaims any liability for unauthorized use by third parties of information on or otherwise derived from this Website and for any loss arising from such unauthorized use.

Further, please note that any use of the Website and its content is subject to RTX's Disclaimer.

 

7.  Links to other websites

Our website has links to other websites or to integrated websites. RTX has no influence on and cannot be hold responsible for neither the content of nor the personal data processing activities on the websites of other companies (third-party websites).

When you visit other websites, you should always read their policies on protection of personal information and other relevant policies. If you have any question to the processing of your personal data on external websites, please contact the owners of those websites directly.

 

8.  Amendments to this Privacy Statement

This Privacy Statement is regularly updated and amended, including as required on account of changes to statutes, practices and rules and regulations on the data protection area. You are advised, therefore, to stay up to date on the contents of this Privacy Statement at all times.

 

Last changed: May 26, 2023