1. DEFINITIONS
Data Controller: The entity that determines the purposes and means of processing personal data.
Data Processor: The entity that processes personal data on behalf of the Controller.
Personal Data: Any information relating to an identified or identifiable natural person.
2. B2X AS DATA CONTROLLER VS. DATA PROCESSOR
2.1 B2X as Data Controller: We are the Data Controller for the personal data we collect directly from our Clients, leads, and website visitors (e.g., contact information, billing details, and communication history).
2.2 B2X as Data Processor: When we provide hosting, web development, or bot management services, we act as a Data Processor for the data managed by our Clients. Our Clients remain the Data Controllers for their own end-users' data.
3. DATA PROCESSING AGREEMENT (DPA)
3.1 In accordance with Article 28 of the GDPR, the Agency and the Client must enter into a written Data Processing Agreement (DPA) whenever the Agency processes personal data on behalf of the Client.
3.2 This DPA outlines the duration, nature, and purpose of the processing, the types of personal data, and the categories of data subjects.
4. DATA WE COLLECT
We may collect and process the following categories of personal data:
Contact Information: Name, email address, phone number, and physical address.
Business Information: Job title, company name, VAT/CVR number, and billing details.
Technical Data: IP addresses, browser type, device information, and usage data via cookies.
Project Data: Login credentials for third-party platforms (e.g., Steam, Discord, Hetzner) provided by the Client.
5. LEGAL BASIS FOR PROCESSING
We process data based on the following legal grounds:
Contractual Necessity (Art. 6(1)(b)): To perform our obligations under a Service Agreement.
Legal Obligation (Art. 6(1)(c)): To comply with tax, accounting (Bogføringsloven), and regulatory requirements.
Legitimate Interest (Art. 6(1)(f)): To improve our services, maintain security, and conduct B2B marketing.
Consent (Art. 6(1)(a)): Where you have explicitly provided consent (e.g., cookie acceptance).
6. DATA RETENTION
6.1 Financial Records: In accordance with the Danish Bookkeeping Act (Bogføringsloven), we retain billing and transaction data for a minimum of five (5) years.
6.2 General Data: We retain other personal data only as long as necessary to fulfill the purposes outlined in this policy.
7. DISCLOSURE TO THIRD PARTIES
We do not sell your data. We share data only with trusted providers necessary for operations:
Infrastructure: Hetzner, Cloudflare.
Operations: Slack, Google Workspace.
Legal/Financial: Accountants, legal counsel, or Datatilsynet if required.
8. INTERNATIONAL DATA TRANSFERS
If data is transferred outside the EU/EEA, we utilize EU Standard Contractual Clauses (SCCs) or rely on adequacy decisions by the European Commission to ensure a high level of data protection.
9. YOUR RIGHTS UNDER GDPR
You have the following rights regarding your personal data:
Access & Rectification: View and correct your data.
Erasure ("Right to be Forgotten"): Request deletion of data where legal retention periods have expired.
Portability: Request your data in a machine-readable format.
Objection: Object to processing based on legitimate interest or for direct marketing.
To exercise these rights, contact us at
[email protected].
10. COMPLAINTS TO SUPERVISORY AUTHORITY
If you believe our processing of your personal data violates the GDPR, you have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet):
Address: Carl Jacobsens Vej 35, 2500 Valby, Denmark.
Website: www.datatilsynet.dk
11. COOKIES AND TRACKING
11.1 Our website uses cookies to enhance functionality. In compliance with the Danish Cookie Order (Cookiebekendtgørelsen), we obtain your consent before setting any non-essential cookies.
11.2 You may withdraw or change your cookie consent at any time via our cookie banner.
12. DATA OWNERSHIP & INTELLECTUAL PROPERTY
12.1 Agency Ownership: The Agency retains exclusive ownership of all technical meta-data, server logs, and anonymized performance metrics.
12.2 Client Responsibility: The Client is responsible for the legality of the data they ask the Agency to host or process.
13. AI, AUTOMATED PROCESSING & UGC
13.1 AI Tools: AI models used are provided "as-is." We are not liable for errors generated by third-party AI models.
13.2 User-Generated Content (UGC): The Client is responsible for moderating content uploaded by their users to platforms hosted by the Agency.
14. CHILDREN’S PRIVACY
14.1 B2B Focus: Our services are for business entities. We do not knowingly collect data from children under 13 via business channels.
14.2 Client Duty: For Esport platforms, the Client (Data Controller) must implement age verification and parental consent mechanisms.
15. CONTACT INFORMATION
B2X ApS
CVR: Busines is under construction
Email:
[email protected]