/ Privacy and Cookie Policy for Websites

Privacy and Cookie Policy for Websites

This policy applies to the North-East Family Office Group, which includes North-East Family Office Holding ApS (Danish business registration (CVR) no. 35 24 43 28), North-East Family Office Holding 2 ApS (Danish business registration (CVR) no. 37 25 68 70) and each of their respective subsidiaries, (”North-East”, ”we”, ”our” or ”us”).

At North-East, confidentiality and data protection are high priorities. This privacy policy (“Privacy Policy”) explains how we process (“Process/Processing/Processed”) your personal data (“Personal Data”) when visiting our website, contact us with an enquiry etc. 

In this Privacy Policy, the defined term “North-East” shall both refer to North-East Family Office Group taken together as well as any member of the North-East Family Office Group individually, including, but not limited to, North-East Family Office ApS (“North-East ApS”) and North-East Family Office Asset Management (full legal name: North-East Family Office Fondsmæglerselskab A/S) (“North-East AM”).

Changes may occur to this Privacy Policy from time to time and will be made available here.  


1. Processing of Personal Data 

We collect information you provide us with directly, e.g. if you contact us with an enquiry. This applies if you call us, e-mail us, communicate with us through a third party, or otherwise interact with us. 

We may collect the following categories of Personal Data about you: 

  1. your name;
  2. your address;
  3. your phone number and e-mail address; 
  4. professional information about you (e.g. the company you represent, your title etc.); and 
  5. any other Personal Data you choose to give us.  

We may Process the above Personal Data based on our legitimate interest in responding to your enquiry if we have not entered into a contract in accordance with Article 6(1)(f) of the General Data Protection Regulation (the “GDPR”).

If your enquiry is made with a view to entering into or fulfilling a contract between North-East and you, or the company you represent, we may Process the above categories of Personal Data about you based on your enquiry, cf. Article 6(1)(b) or Article 6(1)(f) of the GDPR.

We may also collect data about you (i.e. Personal Data), or the company you represent, from other public sources, including social media and/or public records (e.g. CVR.dk) and combine that information with the data you have provided.


2. Storage and deletion

We will delete your Personal Data when we no longer need to Process these for one or more of the purposes set out above. However, the Personal Data may be Processed and stored for a longer period in anonymized form.


3. Disclosure of Personal Data

As a general rule, your Personal Data will not be disclosed to third parties without your permission. However, under certain circumstances it may be necessary to disclose Personal Data to public authorities, including if required pursuant to applicable law. 

Should North-East require legal advice or other counselling, we may also disclose your Personal Data to our external legal advisors or economic and financial advisors, provided that we have a legitimate interest in establishing, defending or exercising a legal claim, cf. Article 6(1)(f) of the GDPR.

Your Personal Data may, under certain circumstances, also be disclosed to North-East’s Business Partners (Data Processors) who provide services on behalf of North-East, e.g. server/cloud hosting, IT service providers etc. These Business Partners will only Process the Personal Data in accordance with North-East’s instructions. 


4. Transfers to third parties, transfers to third countries

Your Personal Data may be shared with other entities within the North-East Group.

To the extent your Personal Data is transferred to data controllers or data processors in countries outside the EU/EEA, including group entities, that do not ensure an adequate level of data protection, such transfer will be based on the EU Commission’s standard contractual clauses.


5. Security

We have implemented security measures to protect your Personal Data in the best possible way. This includes the use of encryption and pseudonymization (where possible), access restriction, etc.


6. Cookies

Cookies are used on almost all websites today and are in many cases necessary to provide services on websites.

A cookie is a small script placed on the user’s computer or mobile device (e.g. PC, tablet, smartphone etc.). Cookies can, among other things, be used to compile statistics on user behaviour on the website and to optimize the content. A cookie is a passive file that cannot carry computer viruses or install malware. Some cookies are placed by parties other than the one in the address bar (URL) of the browser (so-called third parties). Such cookies may be cookies performing basic website features, enabling the different functions of the website, others may be placed for the purpose of gathering data through analytical tools. This means, that cookies developed and/or installed by parties other than the owner of the website are stored on the website. 

Some cookies are only stored on the user’s device when the user has his/her browser open (session cookies). Other cookies are stored for a longer period (persistent cookies). When the user returns to the website, the session cookies will be placed again, while the persistent cookies are automatically renewed.

North-East’s cookie declaration in force at any time can be found in the cookie pop-up on the website.

How do you delete or disable cookies?

The procedure for deleting or disabling cookies on your device depends on the browser you are using.

If you are using a PC, you can delete cookies by using the keyboard shortcut in your browser: [CTRL]+[SHIFT]+[Delete].

If this procedure is not successful, or if you are using an Apple computer, please click one of the below links depending on the browser you are using:

Processing of Personal Data through cookies

When you use our website, information regarding your behaviour and your IP address may be collected through cookies. This is i.e. done through media-plugins provided by Google. With respect to such data Processing, North-East is Data Controller.

We Process your Personal Data in connection with your visits to (and use of) the website as described in this Privacy and Cookie Policy and on the following legal bases: 

  • Article 6(1)(f) of the GDPR (legitimate interest). Our legitimate interest is to offer you an interesting website that works in the best possible way and for statistical purposes. 
  • Article 6(1)(b) of the GDPR (contract). Our legitimate interest is for the website to function properly by using the necessary functional cookies.

7. Links to other websites etc.

Our website may contain links to other websites or integrated websites. We are not responsible for the content of websites of other companies or their collection of Personal Data. When you visit other websites, please refer to the owner’s privacy policy and other relevant policies. 


8. Data Controller and your Rights

North-East ApS is website owner and data controller with regard to the Processing of your Personal Data and the placement of cookies.

Furthermore, if you interact with North-East ApS in accordance with Section 1 above, this entity is data controller for the Processing of your Personal Data for the said activities.

The contact details of North-East ApS are stated below:

North-East Family Office ApS
Danish business registration (CVR) no. 36 98 90 41
Vestagervej 17
2900 Hellerup

If you interact with North-East AM in accordance with Section 1 above, this North-East AM is data controller for the Processing of your Personal Data for the said activities.

The contact details of North-East AM are stated below:

North-East Family Office Fondsmæglerselskab A/S
Danish business registration (CVR) no. 36 44 93 81
Vestagervej 17
2900 Hellerup

Subject to certain statutory exceptions, you have the right to obtain information on and gain access to the Personal Data we Process about you. You also have the right to object to the collection and further Processing of your Personal Data. Furthermore, you have the right to request limitation of the Processing of your Personal Data, rectification of your Personal Data and, in some cases, deletion of your Personal Data. In certain circumstances you can also request to have a copy of your Personal Data provided in a structured, commonly used and machine-readable format and ask us to transfer such Personal Data to another Data Controller. 

If you wish to exercise any of the above rights, have any questions regarding the Processing of your Personal Data or wish to make a complaint regarding the Processing of your data, you are welcome to contact us at legal(at)nefo.com. You are also entitled to file a complaint with the Danish Data Protection Agency (in Danish: Datatilsynet); Carl Jacobsens Vej 35, 2500 Valby, e-mail: dt(at)datatilsynet.dk.