1. INTRODUCTION

At Mighty Admins we understand that your privacy is important and we therefore respect and protect your right to privacy. At Mighty Admins we process your Personal Data in accordance with the GDPR. This Privacy Policy (“Policy”) set out what Personal Data we collect, how it is collected and how it is used. The Policy also sets out the rights the Customer and/or Data Subject have in relation to the Personal Data.

2. DATA CONTROLLER

2.1. Mighty Admins is the data controller for the processing of your personal data. Our legal information is the following:

Mighty Admins ApS
CVR no. 44279606
Læderstræde 14, 1.
1201 Copenhagen K
Denmark

2.2. If you have any questions regarding the processing of personal data, please contact Mighty Admins at info@mightyadmins.com.

3. WHAT PERSONAL DATA DO WE COLLECT?

3.1. Mighty Admins collect and processes the following data:

• Personal identification information (such as name, personal identification no., job function, telephone number, e-mail address, IP)
• General demographic information (such as gender, date of birth, nationality,  address, etc.)
• Personal identification documentation (such as passport numbers, tax identification number, utility bills)
• Financial information (such as bank account numbers, transaction information, source of funds, source of wealth)
• Information on shareholdings and assets legally or beneficially owned by a Data Subject
• Information on individuals and organizations which can or may be connected to a Data Subject.

3.2 The above list is not exhaustive and Mighty Admins may also collect and process Personal Data to the extend this is useful or necessary for the provision of our services in accordance with the Service Agreement. 

3.3. Mighty Admins does not process sensitive Personal Data as defined in Article 9 GDPR. To the extent you make such Personal Data available to Mighty Admins, you consent to Mighty Admins processing such Personal Data in accordance with this Policy.

4. HOW DO WE COLLECT YOUR PERSONAL DATA? 

4.1. Personal Data is processed and obtained in different ways. We obtain and process Personal Data received directly from the Customer or prospective customer, business partners and other intermediaries for the purpose of meeting certain legal requirements and/or entering into a Service Agreement. We also obtain and process Personal Data collected from e.g. Authorities, websites, social networks & advertising, cookies, forms or screening tools. We may also receive Personal Data from third parties as part of the services provided or in connection with legal requirements applicable to us.  

4.2. We continuously check that your personal data is not incorrect or misleading to the extent possible. In this regard, we ask you to inform us of relevant changes in your Personal Data if not approached by Mighty Admins in advance.   

5. HOW DO WE USE YOUR PERSONAL DATA? 

5.1. Mighty Admins collects and process your Personal Data so that we can perform the services set out in the Service Agreement, in order to comply with our legal and regulatory obligations, such as the obligations set out in the AML legislation, and to provide targeted marketing, if you have consented to this. 

5.2 We may further process your Personal Data for the purposes of legitimate business interests pursued by Mighty Admins. This includes general research and development and administration of our business and systems. This also includes administration etc. to develop and improve our services towards you. In this connection we may provide you with communication regarding our service offering which we think is value creating for you or directly requested by the Data Subject.  

5.3. When Mighty Admins process your Personal Data for legitimate business interests, we will consider and balance any potential impact on your rights under applicable and relevant law. Whenever we process your Personal Data for these purposes, you will have the right to object to this way of processing.  

6. TRANSFER AND DISCLOSURE OF PERSONAL DATA 

6.1. Mighty Admins may transfer or disclose Personal Data to subcontractors, intermediaries, IT systems and/or external advisors for the purpose of delivering the services set out in the Service Agreement. We may furthermore transfer or disclose Personal Data with the prior written or explicit consent to do so by the Customer and/or Data Subject.   

6.2. Mighty Admins can be obliged to transfer or disclose Personal Data to a competent authority in order to comply with our legal obligations.  

6.3. Beside as described in this section, Mighty Admins will not transfer, disclose or sell your Personal Data to any third party unless we have received a written or explicit consent to do so.  

7. STORAGE OF DATA 

7.1. Personal Data collected and processed by Mighty Admins are either stored physically in the Nordics or stored on our servers and/or a cloud-based database management system engaged by Mighty Admins with Data Processing Agreements in accordance with GDPR or similar regulation.

8. THE CUSTOMER’S AND/OR DATA SUBJECTS RIGHTS

8.1. Right of access 
The Customer and/or Data Subject can obtain, on request, information on what Personal Data and the category of Personal Data Mighty Admins process about the Customer and/or Data Subject and the purpose of the processing if the Customer and/or Data Subject has not already been informed. The Customer and/or Data Subject can also gain insight into the duration of the storage of the Customer’s and/or Data Subject’s Personal Data and who has access to the Personal Data. 

8.2. Right of opposition 
The Customer and/or Data Subject may object to the processing of its personal data at any time and withdraw a previously issued consent for the processing of its Personal Data. However, please be aware that there will be certain Personal Data that we will be able to process without your consent if we have a legitimate interest and if the protection of your interests does not exceed that interest. 

8.3. Right of rectification 
If the Customer and/or Data Subject believes that the Personal Data, we process about you is inaccurate or misleading, you have the right to have it corrected. In this regard, you must contact Mighty Admins.  

8.4. Right to have personal data limited or erased 
As long as you are a Customer of Mighty Admins ApS and up to 5 year of the customer relationship, we will retain your Personal Data for the purpose of fulfilling public obligations and for the purpose of any legal disputes. 

However, in some cases, we will have an obligation to delete your personal data earlier. This applies, for example, if you withdraw consent or if the retention of your Personal Data is no longer necessary for the specified purposes. Note that records of given email marketing consent must be stored for GDPR purposes. 

If you request that your Personal Data be corrected or deleted, we will check if the conditions are met and in that case we will make the necessary changes or deletions as soon as possible. 

8.5. Right to data portability  
If you request information about the personal data Mighty Admins ApS processes about you and the conditions are present, you are entitled to that we hand this over to you in a structured, commonly used and machine-readable format, and we cannot and will not prevent you from transmitting this information to third parties.  If you request it and it is technically possible, we will make sure to transmit the requested personal data directly from Mighty Admins ApS to a third party. 

8.6. Right to complain 
If you believe that your personal data is processed in violation of applicable law or other legal obligations, you have the right to lodge a complaint with the Danish Data Protection Agency. (dt@datatilsynet.dk).
 

9. COOKIES 

9.1. When using our website, cookies may collect information about; user behaviour, browser type, device category, information about preferred settings and IP address.  

9.2. Processing for marketing purposes takes place on the basis of Article 6(1)(a) GDPR.  

9.3. Processing for other purposes, e.g. statistics on website visits, optimization of functionality and similar, takes place on the basis of Article 6(1)(f) GDPR, where the legitimate interest of Mighty Admins is to develop and maintain a relevant website that functions optimally. 

10. LINKS TO OTHER WEBSITES 

10.1. Our website may contain links to other websites. Mighty Admins is not responsible for the content on other websites or their way of collecting Personal Data. You should always read the websites policies regarding protection of Personal Data. 
 

11. AMENDMENTS AND MODIFICATIONS  

11.1. Any amendments and/or modifications to this Policy shall be published on the website of Mighty Admins. Any amendments and/or modifications shall not reduce or otherwise limit the rights of the Customer and/or Data Subject.