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Privacy Policy

Keystone Investment Management A/S is the data controller with regard to any personal information we gather about you, and we make sure that your information is processed in compliance with the law.

As data controller we also have a duty to provide you with information about what personal information we process, why and how we process it, for how long we retain it, as well as how you can contact us about it and exercise your rights.

This privacy policy covers that duty in several sets of circumstances. If your situation is not covered in this policy, such as if you are employed with us, we have separate documents available to you with all necessary information.

Contact information

If you wish to get in touch with us about our processing of your personal information, you can get hold of us at:

Keystone Investment Management A/S
CVR: 32318827
Havnegade 25, 2nd floor
DK-1058 Copenhagen K
JG@keystoneim.dk

Processing of Personal Data

It is our responsibility to protect all personal information in our possession from being accidentally or unlawfully deleted, publicised, lost, corrupted, leaked, or misused. To do that we have taken a number of technical and organisational measures. We also ensure that processing only takes place when we can adhere to all our duties in data protection.

We keep your information up to date

As our services depend on our information about you being accurate, we ask that you keep us informed about relevant changes. You can always make use of the contact details above to let us know about any changes. We will update your information accordingly. If we find out on our own that our information about you is incorrect, e.g. spelling errors in your name or address, we will update it without further ado.

How did we get your information?

We gather personal information about you in a variety of ways, e.g. by receiving information from you, by way of questionnaires, contact forms or phone.

Below, you can see our purposes for processing personal information. For every type of processing, you can also see our legal basis for the processing. The legal basis means we can point to a law, which allows our processing. You will also be able to see our retention periods for the information we process. We have sorted our processing activities into headlines, to make it easier for you to find the information that pertains to your specific situation. 

When we are the data processor

We provide services to other companies by administering and managing their properties. In connection with these services, we process personal data on behalf of those companies and therefore act as a data processor. It is always the data controller that must provide information about purpose and legal basis. Thus, if we process your personal information as data processor for another company, we cannot inform you as to any specifics. You should reach out to the data controller for further information. If you reach out to us, we cannot respond to your request but are instead required to pass it on to the relevant data controller in accordance with the data processing agreement governing our business relationship.

Investors, costumers, and business partners (later named “Stakeholders”)

For you, as a contact person or another physical person of interest, working as a representative, at one of our Stakeholders, it is necessary for us to process your personal data. This includes your general personal data, cf. GDPR article 6, and in some cases, we will process your confidential personal data, including your social security number.

We process your personal data on the purpose of administrating your relation to us and to fulfil our contractual obligations. If we process your social security number, we do this on the purpose of complying with our obligations within national money laundering acts.

We process your personal data on the legal basis of performance of our contractual obligations, cf. GDPR art. 6(1)(b), and for pursuing our legitimate interest, cf. GDPR art. 6(1)(f), which necessitated by our interest in administrating your relation to us. When processing your social security number, we do this on the legal basis of Databeskyttelseslovens §11 (2).

We store the data in the period established by legislation and deletes the data when they are no longer relevant. The period depends on the character of the data and the reason for the processing. Typically, data regarding clients will be deleted at the end of the agreement.

Data processed to comply with the Accounting Act (Danish, LBK. 648 af 15/06/2006), is being stored (processed) within a 5-year period, after the post has been recorded.

Job applicants

When we receive your application, it will be read and processed by the following procedures:

The application with attachments is shared between the relevant employees in the recruiting process. We only process the data given in your application and in other attachments given by you.

Personal data that appears in the recruiting process will be processed as follows:

We gather the data about you based on our legitimate interest, cf. GDPR article 6(1)(f)), which is to find the most qualified candidate. This necessitates the processing of these personal data, and the company assures that meeting this legitimate interest will not hurt the data subjects’ rights.

If we collect references, from former employers, we use the legal basis of consent cf. GDPR article 6 (1)(a), from the former employer.

We store your application with attachments until we find the right candidate for the job, and the recruiting process has ended. Then your application with attachments gets deleted.

We store unsolicited applications with attachments in 6 months whereafter they get deleted.

If we want to store your application with attachments in more than 6 months, we will contact you to get you consent. Your consent is voluntary, and you can withdraw it at any time by contacting us using the contact information above.

Website Visitors

We do not use cookies on our website and do not place cookies or similar technologies on your device.

Our Social Media

When you follow, like, or otherwise interact with our company page on social media, we get access to the following information about you:

  • Your name, your likes, and your comments – including the contents of your comments
  • Any backend statistics for our page, aggregated from user interactions. We only have access to this information after it has been pseudonymised, and only the Social Media platform could identify you. More info on this and how your personal information is used to aggregate statistics will be available to you on the social media platform in question.


Our purpose with this processing is to reach and potentially interact with followers and other interested parties on social media regarding marketing of vacant leaseholds.

Our legal basis for the processing is:

  • Our legitimate interest in marketing our business/products (GDPR art. 6(1)(f))

 

LinkedIn
We have joint controllership with LinkedIn regarding the information collected about you, when you interact with our company profile. This means that we cooperate with LinkedIn, when it comes to establishing and delegating responsibilities for our compliance regarding the processing of your personal information.

We have an agreement regulating this joint controllership, which you can find here: https://legal.linkedin.com/pages-joint-controller-addendum

If you do not have a personal LinkedIn-profile, LinkedIn collects information about the device you use, when accessing LinkedIn, your location/geodata, and information about your activity on LinkedIn. Any information your cookie settings allow to be tracked as regards your visits to other websites, will also be collected.

If you do have a personal LinkedIn profile, LinkedIn collects the same information as above. In addition to this, LinkedIn also collects any information, you have consented to, through creating your user profile, ie. Your reactions, comments, shares and any other activities on LinkedIn connected to your profile.

Of all the information gathered by LinkedIn, we only receive that which you give us through direct interactions, e.g.: messages, likes/reactions, or comments. Beyond that, LinkedIn Page Analytics gives us access to anonymised statistics based on the information LinkedIn collects as described previously.

If you wish to delete the information LinkedIn has about you, you can delete your user profile. If you choose to do that, all of your posts, pictures and information will be deleted. If you have any questions regarding the inner workings of LinkedIn Page Analytics, please contact LinkedIn directly.

Facebook & Instagram (Meta platforms)
We have joint controllership with Meta regarding the information collected about you, when you interact with our company profiles (KeyLetting) on Facebook or Instagram. This means that we cooperate with Meta, when it comes to establishing and delegating responsibilities for our compliance regarding the processing of your personal information.

We have an agreement regulating this joint controllership, which you can find here: https://www.facebook.com/legal/controller_addendum

Meta uses Insights on their platforms to collect and aggregate statistical data about user activities, these include age, gender, relationship status, work, lifestyle, interests, purchase information, and geodata. For this purpose, Meta places a cookie on your device, when you visit one of their platforms. Every cookie contains a unique identifier, which remains active for 2 years unless deleted before the end of that period. Meta collects your personal information by using these cookies, and they store and process your information for the mentioned statistics. We receive these statistics, but not the raw data, they are built on. You can read more about Meta’s use of cookies on Facebook here and on Instagram and Threads here.

We do not pass along any information about you that we receive from Meta. Meta may do so, however, and we encourage you to read more about their information exchange with third parties in their Privacy Policy.

If you wish to delete Meta’s cookies from your devices/browsers, you can see how in our cookie banner or you can contact Meta for further information.

Meta will process information about you even if you do not have an account on one of their platforms. You can read more about this in Meta’s policy here.

Data minimisation

We only process the information necessary for the fulfilment of our stated purposes. Beyond those, we may be required by law to collect and retain certain information about you. We only retain personal information for the necessary retention period or as required by law. The personal information is deleted or anonymized when it is no longer necessary for us to process it.

We keep data up-to-date

As our services depend on your personal information being correct and updated, we request that you inform us of any relevant changes in your personal information. As tenant you can inform us of changes to your personal information via the relevant property manager of the property in which you are a tenant (please include lease number). Otherwise, you can use Udlejning@keystonim.dk or the contact point noted above to inform us of the changes. We will then make sure to update your information in our databases. If it comes to our attention that our information about you is incorrect, we will update it and notify you of this.

Transmission of your information

We use a number of third parties to store and process information, among them IT-solutions. They only process your information on our behalf and are not permitted to use the information for their own purposes. When relevant, your information may be disclosed to banks, public authorities etc.

We prioritize data processors from within the EU and from third countries approved by the European Commission with regards to an adequate level of protection of personal data, cf. GDPR art. 45.

Transmission of information to third countries

We make use of some data processors/suppliers in unsafe third countries. When legislation in those countries does not offer the same level of protection as we have here in the EU, we have stricter obligations to protect your personal information.

When we transfer personal information to recipients in e.g. the USA, we do so based on The European Commissions standard contractual clauses (GDPR art. 46(2)(c)) or Data Privacy Framework (GDPR art. 45(9). If you wish to know more about whether your personal information is transferred and the steps we have taken to protect it, you can reach out to us to learn more. You can also request our documentation for appropriate safeguards.

If you would like to know more about the transfer mechanisms that apply to your information, you can contact us by the above information.

Your rights

By contacting us at the contact point at the top, you may:

  • achieve access to the personal information we have on you
  • rectify any faulty personal information
  • have your personal information erased
  • receive a copy of your personal information (data portability) for the purpose of moving it to another data controller
  • object to the processing
  • have the processing of your personal information restricted

 

When you contact us, requesting to exercise your abovementioned rights, we will respond within a month. If we cannot honour your request, you will receive an explanation.

In order to exercise your rights, or if you have questions about our processing of your information, you can always contact us. Our contact information is at the top.

If, after having been in touch, you are dissatisfied with how we process your information, you have the right to file a complaint with
Datatilsynet.

Copenhagen, 15-06-2026

Keystone Investment Management A/S
Havnegade 25, 2. sal, DK-1058 København K
Tel. (+45) 76 250 270
CVR: 32318827

Keystone Investment
Management A/S
Havnegade 25, 2. sal,
DK-1058 København K
Tel. (+45) 76 250 270

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