Bluecircle
Data Privacy Policy
1. Introduction
Bluecircle Group ApS and its affiliated entities (hereinafter “Bluecircle”, “we”, “us” or “our”) operate within critical power infrastructure, data center environments and related technical services.
We recognize that protection of personal data is a fundamental right. Bluecircle is committed to ensuring lawful, fair and transparent processing of personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and applicable national legislation.
We process personal data responsibly and proportionately, with a strong focus on confidentiality, integrity and availability.
2. Purpose of this Policy
This Data Privacy Policy explains:
- Why Bluecircle processes personal data
- What categories of personal data are processed
- How personal data is collected, used, stored and protected
- The legal basis for processing
- Retention periods
- The rights of data subjects
3. Scope
This Policy applies to:
- Employees and contractors
- Customers and their representatives
- Suppliers and business partners
- Website visitors
- Event participants
The Policy covers all Bluecircle operations and digital platforms, including service systems, support systems, eCommerce environments and marketing activities.
4. Definition of Personal Data
Personal data means any information relating to an identified or identifiable natural person.
An identifiable person is one who can be identified directly or indirectly, for example by reference to:
- Name
- Identification number
- Location data
- Online identifier
Or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person
5. General Purposes of Processing
Bluecircle processes personal data for the following purposes:
Service Delivery
To deliver products, commissioning services, UPS systems, generator solutions, service agreements and related support.
Contract Management
To administer contracts, warranties, SLAs and technical documentation.
Communication
To communicate regarding projects, service tickets, invoices, technical matters or operational updates.
Legal Compliance
To comply with accounting, tax, audit and regulatory requirements.
Security
To ensure system security, prevent fraud and protect infrastructure and IT systems.
Marketing (based on consent where required)
To provide relevant technical updates, invitations, product information or industry content.
Analytics and Service Improvement
To evaluate service performance and improve technical and commercial processes.
6. Categories of Personal Data Processed
Depending on the relationship, Bluecircle may process:
- Name
- Email address
- Phone number
- Company name
- Job title
- Department
- IP address
- System login information
- Purchase or service history
- Event participation data
Bluecircle does not process personal data beyond what is necessary for the specific purpose.
7. eCommerce and Account Data
If a company representative creates an account on a Bluecircle digital platform (e.g., webshop, service portal or project portal), the following data may be processed:
- First and last name
- Email address
- Phone number
- Company affiliation
- Login timestamp
- IP address
- Order and transaction data
- Purpose
- Order processing
- delivery and logistics
- warranty handling
- invoicing
- contractual documentation
- Retention
User account data is anonymized or deleted after prolonged inactivity in accordance with internal retention policies and legal requirements (typically 2–5 years depending on legal obligations).
Financial transaction data is stored in accordance with accounting legislation.
8. Service Desk and Case Handling
When contacting Bluecircle Service Desk:
- Data Processed
- Name
- contact details
- company
- case description
- technical details relevant to resolution
- Purpose
- Incident management
- troubleshooting
- SLA compliance
- quality documentation
- knowledge base improvement
- Retention
Case data is retained for up to seven (7) years for contractual documentation and audit purposes.
9. Call Recordings
Inbound calls to Bluecircle Service Desk may be recorded for:
- Quality assurance
- Complaint handling
- Documentation
Callers are informed prior to recording and may opt out where technically possible.
Retention period: up to 90 days unless required for documentation of disputes.
10. Authorization and System Access
Bluecircle uses secure authentication mechanisms for system access.
Authentication may include:
- Email and password
- Two-factor authentication
- Customer Single Sign-On (SSO)
Personal data processed in this context:
- Name
- IP address
- Authentication logs
Authentication logs are retained according to IT security logging policies.
11. Direct Marketing
Bluecircle may send:
- Technical updates
- Invitations to events
- Product news
- Industry reports
Legal basis: Consent (Article 6(1)(a) GDPR) or legitimate interest (Article 6(1)(f) GDPR), depending on context.
Personal data used:
- Name
- Company
- Phone number
Consent can be withdrawn at any time via unsubscribe link or direct contact.
Retention: Until consent is withdrawn or relationship ends.
12. Events
When registering for Bluecircle events:
- Data Processed:
- Name
- company
- phone number
Purpose:
- Event administration
- communication
- attendance management
Retention: As specified in the event registration or until purpose is fulfilled.
13. Photos and Video Material
Photos or video recordings may be taken at Bluecircle events for marketing purposes.
Legal basis:
- Consent
- Legitimate interest
Material may be published on:
- Website
- Other professional channels
Data is stored only as long as relevant for marketing purposes.
14. Surveys
Bluecircle may conduct technical or industry surveys.
Personal data used:
- Email address
Survey responses are anonymized unless explicitly stated otherwise.
Recipients may unsubscribe at any time.
15. Cookies and Tracking
Bluecircle websites use cookies to:
- Ensure functionality
- Improve performance
- Analyze traffic
- Provide marketing functionality
Cookies are categorized as:
- Mandatory
- Functional
- Analytics
- Marketing
Users can manage preferences via the cookie banner.
16. Third-Party Access
Bluecircle may share personal data with:
- Affiliated Bluecircle entities
- IT service providers
- Hosting providers
- Accounting systems
- Marketing platforms
All third parties are bound by data processing agreements.
17. International Transfers
Personal data is primarily processed within the EU/EEA.
If data is transferred outside the EU/EEA, Bluecircle ensures appropriate safeguards, including:
- Standard Contractual Clauses
- Adequacy decisions
18. Data Security
Bluecircle implements appropriate technical and organizational measures including:
- Access control
- Encryption where applicable
- Network security controls
- Logging and monitoring
- Role-based access
19. Data Subject Rights
Under GDPR, data subjects have the right to:
- Access their personal data
- Rectify inaccurate data
- Request deletion (subject to legal obligations)
- Restrict processing
- Object to processing
- Data portability
- Withdraw consent
Requests can be directed to Bluecircle's Data Protection Officer.
Bluecircle will respond within one month unless complexity requires extension.
20. Complaints
Data subjects have the right to lodge complaints with:
Datatilsynet (Denmark)
www.datatilsynet.dk
21. Policy Updates
Bluecircle reserves the right to update this Policy when necessary.
The latest version is always available on our website.
22. Contact
For privacy-related inquiries:
Bluecircle ApS
Email: account@blue-circle.dk