Data Privacy and Cookie Policy

Introduction

Clearhaus A/S is a payment institution/acquirer approved by the Danish Financial Supervisory Authority (Finanstilsynet), that provides payment solutions for online stores. Clearhaus is principal member of Visa and Mastercard. Clearhaus A/S handles the acquiring process of receiving payments from consumers​,​ who have a Visa or Mastercard credit/debit card and passes on the payments to our merchants/customers. The payments take place via the payment infrastructure of Visa and Mastercard, the sumclearing of the Central Bank and internationally via SWIFT and EBA-clearing.

This document accounts for the Data Privacy Policy of Clearhaus A/S (CVR. 33749996). The policy has been elaborated in compliance with the GDPR - Regulation (EU) ²⁰¹⁶⁄₆₇₉ of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data. In this regard, the following is useful information for our customers/merchants:

1. All processing systems are outsourced to certified vendors.
2. Clearhaus is not physically involved in data transmission and/or storage of card data.
3. Clearhaus operates from office networks and laptops.

The purpose of this Privacy Policy is to inform Clearhaus’ business partners that Clearhaus collects, stores and use personal data in compliance with the GDPR.

In connection with the GDPR, Clearhaus A/S is defined as a data controller.

Important definitions

• Personal data means any information related to an identified or identifiable natural person (data subject).
• Data controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purpose and means of the processing of personal data.

Principles related to processing, protection and erasure of personal data (GDPR Art. 5)

Clearhaus is aware of and acts according to the regulations of processing, protection and erasure of personal data. Most importantly, personal data:

• Must be processed lawfully, fairly and in a transparent manner in relation to the data subject
• Must be collected for specified and legitimate purposes and is not further processed in a manner that is incompatible with those purposes
• Collected data must be adequate, relevant and limited to what is necessary for purposes for which they were processed
• Must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate is erased or rectified without delay
• Must be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed
• Must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

In the capacity of data controller, Clearhaus A/S is responsible for and can demonstrate compliance with the above principles in the GDPR.

Right to information

In the process of collecting personal data from a potential customer/merchant (data subject) Clearhaus will, in accordance with Art. 13, inform the potential data subject that personal data is collected, and for what purpose. E.g. Clearhaus needs the personal data to handle applications, to process orders and to manage the accounts/contracts signed with us.

Data subjects also have the right to be informed about the storage of personal data. At Clearhaus, we store our customers’ data for as long as they are customers with us or until consent is withdrawn. In case an applicant does not become a customer with us, the personal data will be erased.

Additionally, Clearhaus has to provide the potential data subject with Clearhaus’ contact information, which is stated in the bottom of this document.

Further, Clearhaus A/S must, by request, provide data subjects with information and acts in regard to several additional rights, which will be summarised in the following:

Right of access (Art. 15)

The data subject has the right to obtain confirmation from Clearhaus as to whether personal data concerning him or her are being processed, and, if it is the case, also access to the personal data and the following information

• The purpose of the processing
• The personal data used for the processing

Right to rectification (Art. 16)

The data subject has the right to have any inaccurate personal data rectified by Clearhaus, and to have incomplete data completed.

Right to erasure (“Right to be forgotten”) (Art. 17)

Art. 17 stipulates that any data subject has the right to have personal data erased by the data controller without undue delay. Only under certain circumstances stipulated in the mentioned article does the data controller have the right to keep back the personal data when the situation requires it, e.g. for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Right to restriction of processing (Art. 18)

The data subject has the right to restrict the processing of personal data under certain circumstances, e.g. if the data subject contests the accuracy of the personal data or if the personal information cannot be erased due to establishment, exercise or defense of legal claims or public interest.

Right to complain (Art. 13)

In case of disputes, the data subject has the right to lodge a complaint with a supervisory authority according to Art. 13.

According to Art. 19, it is the responsibility of the data controller to communicate any rectification, erasure or restriction of processing carried out in accordance with Art. 16, 17 and 18 to the recipients to whom the personal data have been disclosed, unless it proves impossible, and the data controller shall also, by request, inform the data subject about these recipients.

Right to data portability (Art. 20)

The data subject has the right to receive the personal data handed over to the data controller and the right to thereafter transmit this information to another data controller. This right, however, must not adversely affect the rights and freedoms of others.

Right to object (Art. 21)

The data subject has the right to object to the processing of his/her personal data but only to the extent that there is a necessary legal basis for the processing. Where personal data is processed for direct marketing purposes, the data subject has the right to object to it, and when the data subject once has objected to this, the personal data shall no longer be processed for such purposes.

Automated individual decision-making, including profiling (Art. 22)

The data subject has the right not to be subject to a decision based ​solely​ on automated processing, including profiling, when has legal effect or otherwise affects the data subject considerably. This does not apply if

• It is necessary for entering into a contract between the data subject and a data controller, which in the law is called ​contractual necessity
• It is authorised by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests
• It is based on the data subject’s explicit consent.

Cookie Policy

At Clearhaus, we want to ensure that your visit to our website is smooth, reliable and as useful for you as possible. To help us do this, we use cookies and similar technologies to make our website relevant for your interests and needs.

What are cookies?

Cookies are small text files that are automatically placed on your computer or mobile device when you visit almost any website. They are stored by your Internet browser.

Cookies contain basic information about your Internet use, but they do not normally identify you personally. Your browser sends these cookies back to the site every time you revisit it, so it can recognise your computer or mobile device and personalize and improve your site experience.

What type of cookies do we use?

The cookies we use fall into 3 categories. These categories are described in the following​:

Essential cookies

These cookies are necessary to help you access and move around our site and use all its features. Without these cookies, our website would not work properly, and you would not be able to use certain important features.

Analytics and customisation cookies

At Clearhaus, we want to make your experience on our website as helpful, smooth and as enjoyable as possible. We use cookies to help us understand how our website is being used, and how we can improve your experience on it. This type of so-called “analytics” cookies can provide us with anonymous information to help us understand which parts of our website interest our visitors and if they experience any errors. We use these cookies to test different designs and features for our sites and we also use them to help us monitor how our visitors reach our sites.

Advertising cookies:

Advertising cookies help ensure that our advertisements are as relevant to you as possible. We work with third-party advertisers to give you access to interesting and exciting content on our website. These third-party cookies record information about your use of advertisements and help to improve your online experience. For example, some advertising cookies help select advertisements that are based on your interests. Others help prevent the same advertisement from continuously re-appearing for you.

Managing your cookie settings

You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies. Most advertising networks offer you a way to opt out of advertising cookies. See the ​Digital Advertising Alliance Consumer Choice​ and ​Your Online Choices​ pages for useful information on how to do this.

Please note that, if you choose to delete Clearhaus cookies, your access to some functionality and areas of our website may be degraded or restricted.

Contact information

Clearhaus A/S

P.O. Pedersens Vej 2, 8200 Aarhus N

+45 82 82 22 00

gdpr@clearhaus.com