Personal data policy

Privacy Policy

Last updated: October 8, 2025

Contents
  • 1. Data Controller
  • 2. Parties and recipients
  • 3. Data we process
  • 4. Purpose and legal basis
  • 5. Retention
  • 6. Rights
  • 7. Changes

1. Data Controller

InCircle ApS
Stengade 7, 3000 Helsingør
CVR: 35826890
support@incircle.dk

We are the data controller for processing personal data related to delivery, customer service, warranty/DOA, portal security, and accounting for products purchased by employers through the portal for their employees.

2. Parties and recipients

Data Controllers

  • Employer: data controller for HR and employee program matters, and contracting party when purchasing.
  • Benifex: data controller for payroll deduction and program administration (support@benify.dk • Tel. +45 78 77 06 70).
  • InCircle: data controller for delivery, customer service, warranty/DOA, and accounting.

Other recipients

  • Carriers and repair partners: independent data controllers for delivery and repair.
  • Hosting / IT operations: data processors acting on our behalf.

3. Data we process

Name, address, email, phone number, order number, device ID (IMEI/serial number), delivery and support cases, and invoice/accounting data.

4. Purpose and legal basis

  • Delivery and support: Art. 6(1)(f) legitimate interest (necessary to provide and support the service).
  • Warranty/DOA: Art. 6(1)(f) and Art. 6(1)(c) (statutory rights).
  • Accounting: Art. 6(1)(c) (Bookkeeping Act).
  • Payroll/program: Art. 6(1)(b) and Art. 6(1)(c) (at Benifex/employer level).

5. Retention

  • Accounting data: 5 years from the end of the fiscal year.
  • Support and warranty cases: up to 3 years after closure.
  • Technical logs: 3–12 months.

6. Rights

You have the right to access, rectification, deletion, restriction, data portability, and objection.

Complaints can be submitted to the Danish Data Protection Agency: www.datatilsynet.dk.

7. Changes

This policy may be updated. The current version is always available in the portal.

Quick summary box

  • Data controller (delivery/support): InCircle ApS, CVR 35826890, support@incircle.dk
  • Program/payroll: Benifex, support@benify.dk • Tel. +45 78 77 06 70
  • Purpose & legal basis: delivery/support = Art. 6(1)(f); warranty/accounting = Art. 6(1)(c)
  • Retention: accounting 5 years; support up to 3 years