Activity

Types of personal data we collect

(for illustration purposes)

Purpose(s)

Legal basis

Do we sell and/or disclose for business purposes

General business operations

Name, contact details, identifiers (e.g. real name, postal address, unique identifiers, online identifier, IP address and email address) and other information necessary for conducting business with you or your organisation.

As part of general VELUX business operations, we collect personal data about individuals, customers, suppliers (including third-party service providers) and other stakeholders. We may also use your data for testing systems.

Based on general business operations being a legitimate interest and necessary in ensuring business handling throughout VELUX, within what is reasonably expected by you.

Do we disclose for business purposes? YES

Do we sell? No

Assisting with enquiries

Name, email address, phone numbers, conversations, other contact details, photos, floor plans of your house when you provide this to VELUX.

You may choose to provide us with personal data, such as contact details when you contact us by phone, email, post, our chatbot or by using our digital platforms available.

This personal data enables us to respond to requests for information on such matters as VELUX products, to arrange a measure and quote for installation of VELUX products, or to arrange for a window to be serviced, or to present claims under the VELUX guarantee.

The information may be disclosed to VELUX A/S or other VELUX sales companies within the Group, relevant independent installers or dealers in order for us to assist customers with their enquiry or arrange for services or a quote.

We record calls for training purposes. We may also ask you to provide your feedback through surveys after the interaction.

Based on our assistance with enquiries and contact being a legitimate interest and necessary in ensuring communication with you and throughout the organization, within what is reasonably expected by you.

Do we disclose for business purposes? YES

Do we sell? No

Sales (including web sales) and order fulfilment.

Name, contact details, payment and credit card details, credit information, credit check and customer records (paper and electronic customer records containing personal

information, such as name, address, telephone number, credit card number and debit

card number) etc.

We may collect personal data of customers and prospective customers in order to conduct business with you or your organisation. We use your data to analyse shopping trends through your web shop activity and purchase history to provide you a personalised browsing experience. Furthermore, we use the data for processing and fulfilling web shop orders by facilitating the delivery of product orders and providing relevant customer service, including processing your returns.

We may disclose the information to dealers or independent installers and logistic partners to process a customer’s order, including arranging delivery of VELUX products to the customer or assisting with enquiries such as arranging consultation between you and our product advisors. We also share your information with third parties for credit check purposes.

Necessary for the performance of a contract to which you or the organisation you work for is a party.

Do we disclose for business purposes? YES

Do we sell? No

Campaigns

Name, contact details, commercial information (products

or services purchased, obtained, or considered) etc.

Execution of various campaigns (e.g., reward programs, cashback campaigns, sweepstakes). Acceptance of terms and conditions is collected before entry to the activity.

Necessary for the performance of a contract to which you or the organisation you work for is a party.

Do we disclose for business purposes? YES

Do we sell? Yes

Product claims

Name, contact details, etc.

Facilitate service of VELUX products under the VELUX guarantee or by paid service, i.e., we solve claims by call, email, and visits to building sites. In this connection, we may share your personal data with VELUX partners to assist you with a service.

We may ask you to provide your feedback through surveys after the interaction.

Necessary for the performance of a contract to which you or the organisation you work for is a party.

Do we disclose for business purposes? YES

Do we sell? No

Business development and VELUX apps

Personal data, which is collected at our digital platforms and in VELUX apps including audio/visual data (audio, electronic, thermal, visual information, such as photos and videos).

The personal data you provide to us, and personal data collected at our digital platforms will be used to enhance our consumer insights and drive relevant communication and offers across all touch points you may have with VELUX. Personal data will also be used for product and service development.

Based on our business development being a legitimate interest and necessary ensuring the improved effectiveness of our business operations, within what is reasonably expected by you

Do we disclose for business purposes? YES

Do we sell? No

Marketing

Contact information, browsing history, sales and subscription service information, such as name, address, email, phone number, purchase history, unique identifiers such as cookie IDs or device IDs, tracked browsing history based on these IDs, etc.

Please be aware that this list is not exhaustive as we may process any personal information collected in connection with your interactions with our parent company, VELUX A/S, our websites, mobile applications, products, and services.

Based on your consent or legitimate interest, when applicable, we process your personal data for the purpose of informing you of VELUX business operations, products, and services.

For the above purposes, we create marketing, tailored to your preferences and profile, e.g.:

- To optimise and tailor the content and delivery of our marketing communications when you want to receive them, and

- To give you tailored marketing based on your preferences and profile, both when engaging with us on our own channels as well as via third party channels (e.g., social media, search sites, marketplaces).

If you do not wish to receive any further information, you can easily and free of charge unsubscribe from our marketing communication anytime. You will find ways to unsubscribe in connection with subscribing to or receiving marketing communication from us. You can also contact us by email or post to unsubscribe, see Section 8.

For some marketing activities we act as joint controller with other VELUX companies and have entered into joint controller agreements dividing the roles and responsibilities between the VELUX companies.

Based on your informed consent when legally required for sending you newsletters, or based on this being a legitimate interest necessary in sending you newsletters, within what is reasonably expected by you.

The personalisation of the marketing will be based on a legitimate interest in profiling being necessary when improving marketing impact, within what is reasonably expected by you.

Do we disclose for business purposes? YES

Do we sell? Yes

Your participation in photos, video, testimonial and campaigns

If you have agreed to it and sent a photo to us or if your photo is taken by a photographer hired by us.

We will use the photo, testimonials etc. as described in the contract signed by you.

Necessary for the performance of a contract with compensation to which you are a party.

For our internal marketing this will be based on our marketing being a legitimate interest and necessary in using the photos etc. in internal marketing purposes, within what is reasonably expected by you.

Do we disclose for business purposes? YES

Do we sell? YES

Website visitors, customer surveys and market research

Personal data from digital platforms or customers as part of surveys including usage data (internet or other electronic network activity information, including, but not

limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement).

To improve the products and services we offer, we may collect personal data from digital platform visitors or customers as part of surveys.

We will contact you with a survey and process personal data as part of surveys through either consent or legitimate interests.

Surveys processing personal data for marketing purposes will be used only with your consent.

Based on our surveys and market research being a legitimate interest and necessary when improving products and services, within what is reasonably expected by you.

Do we disclose for business purposes? YES

Do we sell? No

Recruitment and employment contracts

Name, contact details, working history, educational diplomas, relevant record checks, information about professional interests, etc.

When a person applies for a job or enters into an employment contract with us, we may collect certain information such as name, contact details, information about working history, educational diplomas, relevant record checks and information about professional interests.

This may be collected from the person directly, from a recruitment consultant including references and publicly available sources.

This information is used to inform or assist us in the decision as to make the person an offer of employment or engage the person under a contract.

For further information please read our VELUX Recruitment Notice in WorkDay.

Based on our recruiting being a legitimate interest and necessary in improving a successful match between our company and you as a candidate, within what is reasonably expected by you.

Do we disclose for business purposes? YES

Do we sell? No

Compliance including anti-corruption, Whistleblower hotline and sanctions check

All types of personal information.

We may collect personal data to comply with the law, a court or authority’s decision and/or to disclose information to relevant public authorities as required or permitted by law.

Necessary for the compliance with a legal obligation to which we are subject.

Do we disclose for business purposes? YES

Do we sell? No

Right to Opt-Out

As a U.S. resident you have the right to opt-out of our sale of your personal information. Online opt-out rights can be exercised by visiting our Cookie Policy for global privacy control options or by going directly to our Cookie Settings page and deleting or preventing cookies from being used.

Right to Opt-In

We do not sell personal information about residents who we know are younger than 16 years old without verifiable parental consent.

Right of deletion

As a U.S. resident you have the right to request deletion of your personal information that we have collected about you, subject to certain exemptions, and to have such personal information deleted.

Right to know: Right to a copy

As a U.S. resident you have the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.

Right to know: Information

As a U.S. resident you have the right to request that we provide certain information about how we have handled your personal information in the prior 12 months, including the:

· categories of personal information collected;

· categories of sources of personal information;

· business and/or commercial purposes for collecting and selling their personal information;

· categories of third parties/with whom we have disclosed or shared your personal information;

· categories of personal information that we have disclosed or shared with a third party for a business purpose;

· categories of personal information collected; and

· categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party.

Right to non-discrimination

We will not discriminate against residents who exercise their rights under U.S. privacy laws. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices or rates or impose penalties on residents who exercise their privacy rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.