NTG Polar Road Sp. Z o.o. as part of NTG Nordic Transport Group A/S is committed to respect your rights to privacy and personal data protection. This Privacy Notice aims to provide you with information regarding our processing of your personal data, your rights, and how to exercise them. We have either received your personal data from you or from others, collected it when you have visited our websites or in connection with your purchase of NTG services or our delivery to you.
1 About us
NTG Nordic Transport Group A/S is a leading transport group headquartered in Denmark and comprising more than 60 companies worldwide. Our Group offers freight forwarding services by road, air and sea, as well as specialty and complex freight and shipping solutions.
NTG Nordic Transport Group A/S services all NTG companies with regards to IT platforms and other internal services that are managed and secured by NTG Nordic Transport Group A/S in Denmark. Thus, NTG Nordic Transport Group A/S, acts as a data processor towards NTG Group companies but as a data controller with regards to its own data.
This means that NTG Nordic Transport Group A/S retain responsibility for the protection of your personal data when we have collected it (e.g. when signing a contract with you), and you can contact NTG Nordic Transport Group A/S directly if you prefer.
Our contact details are:
NTG Nordic Transport Group A/S
CBR no. 12546106
+45 7634 0900
2 Why do we collect information about you?
We process your personal data for different reasons. You can read about the different purposes and the legal basis for our processing of your personal data in the following.
2.1 NTG services
When you are a client of our company or when you ask us for information about NTG services, we process your personal data. We do so to ensure that we can make you an offer for freight forwarding and shipping solutions you request from us, plan and deliver these services to you in accordance with our contract together, communicate effectively with you throughout the shipment process, and maintain a client relationship with you between shipments.
We also process your personal data you when your employer is a client of our company, and that your employer has designated you or appointed you with responsibilities for receiving on your employer’s behalf offers, planning or delivery of solutions by us.
When you contact us for information on our freight forwarding and shipping solutions, we collect your contact details (name, email address, telephone number, the company you work for and eventually business address) and we keep a record of our correspondence with you. We do so as this information may form the basis of a contract with you or your employer later on.
When you request us to deliver a service for you or your employer, we will collect additional information necessary for the purposes of executing this contract and complying with our legal obligations (for instance, we are obliged under local laws and regulations to keep a record of all of our transactions for a number of years).
In some situations, we may be contacted by another transport company to execute a shipment or parts of it on their behalf. In these situations, that other transport company might give us non-sensitive personal data about you, that is relevant for executing the contract between you or your employer and that company.
We process your personal data based on Article 6(1)(b) in the General Data Protection Regulation (“GDPR”) as our processing is necessary for the performance of a contract with you. Further, we process your personal data based on Article 6(1)(f) in the GDPR, as we have a legitimate interest in communicating effectively with you throughout the shipment process and maintaining a client relationship with you between shipments.
2.2 Our websites
When you visit our websites, we collect information about your device and your IP-address, as well as the pages you visit on our websites. We do that to make our websites work better and deliver content that is useful to our prospective clients.
We process your personal data based on Article 6(1)(f) in the GDPR, as we have a legitimate interest in offering you an interesting web site that works optimally. Further, we process your personal data based on Article 6(1)(a) in the GDPR about consent.
2.3 Job positions
If you apply for a job with us, we will process personal data about you that we have either received by you or by others you have agreed we can contact. We do so to review your application and assess your suitability for a position with us.
We collect your contact information (name, email, telephone number, address) as well as other information you provide us on your prior employment history, which is contained in your CV, resume or in the correspondence you sent us, or provided to us by the professional references you have indicated in your application.
We process your personal data based on Article 6(1)(a) in the GDPR about consent. Further we process your personal data based on Article 6(1)(f) in the GDPR as we have a legitimate interest in reviewing your application and assessing your suitability for a position with us.
If you are successful and become an employee, we will use some of this information further to comply with our legal obligations as your employer, and with our contract together. In this case, you can read more about our processing of your personal data in our internal personal data policy.
When you participate in our virtual annual shareholders meeting, we process personal data about you. This personal data may comprise your name, location, contact information, IP-number, etc. We process your personal data based on Article 6(1)(f) in the GDPR as we have a legitimate interest in collecting information on the participants in the annual general meeting.
2.5 Whistleblower hotline
We offer a whistleblower hotline where employees, customers, stakeholders or other persons which have a relation with our company can make a report on serious misconducts or a suspicion hereof within NTG, such as financial crimes, breach of the occupational safety, etc.
You can submit your report anonymously without entering any personal data, but you can also choose to submit your name, contact details and any other information that you find relevant. If you choose the latter, we will process your personal data for the purpose of investigating your report. This means that we will only collect your personal data that you have submitted voluntarily.
If you are the person being reported via our whistleblower hotline, we will also process your personal data relating to criminal offences or suspicion hereof and other information submitted in the report in order to investigate the report, and in some cases we will notify public authorities about the report. Further, we can collect information about you from employees, customers, stakeholders and other persons which have a relation with our company.
For the administration of our whistleblower hotline, we process your personal data based on section 8(3) in the Danish Data Protection Act and article 6(1)(f) in the GDPR , as our processing is necessary to discover and investigate serious misconducts or suspicion hereof within NTG and rectify the matters.
3 How do we use information about you?
3.1 NTG services
In general, we only use information about our current, prospective or past clients to get in touch with them when it is necessary for the execution of a contract we have with them, or to contact them with new offers unless they have objected to this. We also store information about our clients to keep track of client history and keep our records as required by law. We delete information about client contacts or prospective client contacts five years after our last contact with them, except when we are required by law to retain it for longer (for example, some of our transaction and payment records).
3.2 Our websites
We use information about visitors on our website in an aggregate form (as statistics) to assess how well our website is working. . We store logs on website use and periodically delete them, at least one time per year.
3.3 Job positions
We use information about job applicants to assess their suitability for a position at our company, and in case they are successful, we will use some of the information as a basis for the applicant’s employee file. We delete information about unsuccessful applicants within six months of having received their information, except when we are required by law to retain it for longer. With regards to employees, we delete information based on individual subjective assessments, but unless certain criteria are fulfilled, the retention period is five years following your termination date.
We use information about participants for statistic purposes and in order to ensure compliance with the business rules that we must adhere to according to Danish law. We delete information about participants in the annual general meeting within five years from the date of the meeting.
3.5 Whistleblower hotline
We use the information which we have collected via our whistleblower hotline to handle and investigate the reports received. We will store the information in the period where our investigation takes place. If the report turns out to be unfounded, the information will be deleted within six months. If we notify a public authority about a report, we will store the information in the period where the public authority investigates the case. Finally, we store the information from the reports in a period of five years after termination of employment if we choose to impose disciplinary sanctions on our employees as a result of such reports.
We respect your rights to privacy and data protection and therefore we will always endeavor to protect your information by all technical and organizational means reasonably available to us.
Information we receive about people are stored securely and confidentially. Technically we make sure to always use data controllers who has the same level of security about your information as we have and internally organizationally within our company, we have focus on educating and teaching our employees in securing a high data security. When it is expediently, we make sure to encrypt, pseudonymize or anonymize your information. We will always make sure that vi follow the existing privacy laws.
5 Who receives information about you from us?
In principle, we do not disclose or transfer information about you to others, with the exception of other companies within our group, NTG, and the vendors and contractors we use to deliver services to us. Furthermore, we may disclose your information to public authorities.
For instance, we may disclose your personal data to IT vendors and public authorities, such as the police, as part of the administration of our whistle blower hotline.
We may disclose information about you to companies or persons that provide us with some technical or infrastructure solutions, such as IT-suppliers. In the European Economic Area we only use suppliers located in EEA for such purposes, and we always ensure that our suppliers only use the data under our instruction and offer sufficient guarantees regarding the protection of confidentiality and security of the personal information they access.
In some situations, we may disclose some information about you to a subcontractor to fulfill a contract with you or your employer. In such cases we only provide them with the information necessary to deliver the service you have requested, and we always ensure that they only use the data under our instruction and offer sufficient guarantees regarding the protection of confidentiality and security of the personal information they access.
We transfer personal data amongst companies within the NTG Group as we primarily offer services in an international context. This enables us to offer the best service to our clients by using the full range of skills, capabilities and expertise present in our group. While most NTG companies are located within the European Economic Area (EEA), some NTG companies are located outside of the EEA.
In order to provide appropriate safeguards regarding the protection of personal data that is transferred to NTG companies outside the EEA, NTG applies a group-wide Data Transfer Agreement, which is a legally binding contract applying to all NTG companies. This agreement provides that all NTG companies located outside the EEA will abide by data protection rules similar to those that apply by law in the EEA, and gives enforceable rights to individuals against NTG’s use of their data outside the EEA. In particular, our Data Transfer Agreement prevents NTG companies located outside the EEA from disclosing further the personal information they have received, unless a similar agreement is in place. Furthermore, persons who wish to exercise their rights against an NTG company located outside the EEA may always do so by contacting our main establishment, NTG Nordic Transport Group A/S in Denmark.
Our group-wide Data Transfer Agreement is based on the Standard Contractual Clauses adopted by the European Commission, and you can obtain a copy of the Agreement and more details about your rights and how to execute them by contacting our main establishment, NTG Nordic Transport Group A/S (see contact details at the top of this notice).
6 Your rights
According to the General Data Protection Regulation chapter III you have several rights in relation to our processing of your personal data.
You have the right to request access to the information we hold about you, obtain a copy of it, correct incorrect or incomplete information, and delete information that we no longer need or use without good reasons. Further, you have a right to object to our processing of your personal data, a right to restriction of processing and a right to data portability.
However, if you are reported through our whistleblower hotline, you are not entitled to be informed about the identity of the person who has reported you, but you can obtain access to the report that has been filed against you.
When you ask us to correct or delete your information, you can also ask us to stop using the information about you while we assess your request.
You always have a right to demand that we stop sending marketing communications to you.
In cases where we have asked you for your consent to use your personal information, you can withdraw your consent at any time by contacting us using by e-mail firstname.lastname@example.org. In such cases, we will stop using your personal information immediately, unless we have a legal obligation to do so. Your withdrawal does not affect the lawfulness of the uses we have made of your personal information before the withdrawal.
You can exercise your rights by contacting us directly, or by contacting our main establishment NTG Nordic Transport Group A/S, by using the details provided at the top of this notice.
If you want to complain about our processing of your personal data, you can contact Data Protection Authority of Denmark (“Datatilsynet”) or of your country of residence. You can also contact the Data Protection Authority of Denmark (“Datatilsynet”) when your complaint concerns our main establishment, NTG Nordic Transport Group A/S. You find the Data Protection Authority of Denmark at Carl Jacobsens Vej 35, 2500 Valby, Denmark or by e-mail email@example.com.
If you have any questions to our processing of your personal data, please contact us by e-mail: firstname.lastname@example.org.