Alessa (hereafter “Alessa”, “we” or “us”) aims to secure the privacy of data subjects in the handling of infringement cases. We are attentive to process personal data in a responsible matter and in accordance with current EU legislation on data protection. By processing your personal data, Alessa is considered the Data Controller. Our contact information can be found below:
c/o Copyright Agent
2200 København N
You are always welcome to contact us if you have any questions regarding the processing of your personal data. We can be contacted on mail: email@example.com
The processing of your personal data is a necessary part of the case handling of infringement cases in agreement with our clients.
We process necessary data about different kinds of data subjects:
- Opponents in a potential infringement
- In some cases; Photographers
- Persons employed by clients
- Persons appearing in photos (the photo may per se be considered personal information, but we do not process any other information about this group)
- Persons who use the contact form on our website
When a possible copyright infringement is detected on a website, Alessa will process personal data, including contact information. A case is started by collecting contact information for the website and/or the person or organization responsible for it. Contact information is processed so that Alessa is able to contact the responsible party to provide information on the possible infringement. The processing of personal data is therefore natural or necessary in order to prosecute infringement cases, in accordance with article 6 (1), litra f in the General Data Protection Regulation (hereafter “GDPR”).
The personal data that will be processed in the handling of infringement cases includes your name, address, e-mail address and phone number. This information is relevant for the infringement case and for us to be able to prosecute the infringement claims on behalf of our clients.
Additionally, we might process customer information from our clients. In cases where Alessa is informed that there might be a customer relationship between you and our clients, we will reach out to our clients to confirm such a relationship.
By using our website contact form, we are processing personal data about you. This data includes contact information in order to answer your inquiry sent to us. The processing of data through our website is limited to the use of our contact form and is therefore based on consent, in accordance with article 6(1), litra a in the GDPR.
In addition to receiving personal data from you, Alessa gathers personal data as a part of the case handling of infringement cases on behalf of our clients, including identification of the responsible party and relevant contact information. The personal data gathered by Alessa is categorized as general data. As mentioned earlier, the information included in the gathering is your name, address, email address and phone number.
In order for Alessa to get in contact with you, we obtain information that is public on the website in question, our client (if needed or requested by you) and official registers of domains and registers of organizations. Such websites include for example www.dk-hostmaster.dk and www.cvr.dk in Denmark, where domain owners and company information is public.
By using the contact form on our website, Alessa will process personal data that includes name, email address, telephone number, as well as information you provide us in your inquiry. Provided information might include photographs if such is uploaded in the contact form.
Alessa gathers personal data for the above-mentioned purpose and from the above-mentioned places in order to prosecute copyright infringements. The legal basis to process your personal data is found in GDPR article 6 (1), litra f on the processing of personal data for the purpose of legitimate interests.
The data that we collect from you is stored on external cloud servers within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA, e.g. a system provider is based in the US with servers in the US. Any such transfer of your Personal Data will be carried out in compliance with applicable laws.
In management and handling of copyright infringement cases, stored personal data is accessible to Alessa employees. This concerns, but is not limited to the legal advisors for our different clients. The information is processed by the legal advisor employed for the client for which the case is handled.
In certain cases, where confirmation on customer relationships is necessary to decide the case, our clients will get access to personal data, including your name and website information.
Personal data is stored as long as the processing is necessary for the case handling and as long as a dispute exists.
We will retain your Personal Data until 5 years after the end of the year in which a case or dispute with you is closed in order to comply with our legal obligations pursuant to the Danish Bookkeeping Act or for the establishment, exercise or defence of legal claims.
According to the GDPR article 14 (2), litra c, the data subject has some rights in regard to the processing of personal data. The data subject has the right to access the data Alessa is processing, including information regarding the purpose of the processing and the categories of data concerned.
You have the right to object to our processing of personal data based on legitimate interest. Such objection may – or may not – lead to stop of processing after we have balanced your interests against our interests (”the balancing test”).
You will also have the right to rectification in case Alessa is processing inaccurate personal data about you. The data subject also has the right to complete incomplete personal data, if such is processed by Alessa. In certain situations, you will also have the right to erasure from our systems before the general erasing limitation of your personal data, as well as the right to restrict Alessa’s processing of your personal data.
Some cases may be initiated based on machine learning and thus not subject to human review before being sent to Opponents.
We are continuously updating and developing security measures to protect your personal data in our own and on external (cloud) systems. These measures aim to make sure that your data is protected from unauthorized access.
You can read more about the rules on processing of personal data and GDPR at the Danish Data Protection Agency website www.datatilsynet.dk. If you believe that Alessa is processing or storing your personal data contrary to the legislation, you have the right to file a complaint to the Danish Data Protection Agency. You can find more guidance on complaints on their website.
If you have any questions or complaints regarding the processing of your personal data, you are welcome to contact us over email. Our email address is firstname.lastname@example.org.