This privacy policy describes how Sund & Bælt Holding A/S processes personal data in connection to the road toll scheme.
"Us" and "we" in this policy refers to Sund & Bælt Holding A/S.
The legal entity responsible for processing your personal data is:
Sund & Bælt Holding A/S
CVR number: 15 69 46 88
Address:
Vester Søgade 10
1601 Copenhagen V
E-mail: persondata@vejafgifter.dk
Tlf.: + 45 70 80 43 10
(Hereafter referred to as “Sund & Bælt”)
In accordance with the Road Tolls Act, Sund & Bælt shall, from 1 January 2025, collect road tolls on behalf of the government from lorries driving on tolled road sections (“the Road Toll Scheme”). Before this date, Sund & Bælt shall ensure that all relevant systems, processes, etc. are fully functional.
Sund & Bælt will set up roadside equipment on some Danish roads, including cameras and radio communication antennas for reading DSRC units (bizz units). The cameras are trained to detect passing cars. The roadside equipment will be installed on an ongoing basis.
Purpose
When you pass the roadside equipment, we process your data to test and train the equipment for use in the Road Toll Scheme and for integration into Sund & Bælt’s systems, which are deployed to process identified offenders.
Categories of personal data
We process the following personal data about you when you pass the roadside equipment:
Individuals who may appear in the image will be blurred in a subsequent process.
If a car passing our roadside equipment also has vehicle equipment with a built-in DSRC antenna, the vehicle equipment will be identified and the equipment number will be recorded.
Sources
We collect your data when you pass the roadside equipment, which then registers the vehicle.
Processing basis
The legal basis for our data processing is the General Data Protection Regulation (GDPR) Article 6, section 1, paragraph e as the processing is necessary for the performance of a task carried out in the public interest.
Pursuant to § 17 a, section 2, in the Act on Sund & Bælt, Sund & Bælt can also collect and process personal data when necessary for the performance of Sund & Bælt’s tasks in connection with the Road Toll Scheme. This means that Sund & Bælt can test systems, etc. to be used when the Road Toll Scheme comes into force.
Retention
The data recorded by the roadside equipment will be deleted after the test has been carried out and no later than one year after the test has been completed.
Recipients of personal data
The roadside equipment is installed by our supplier who also helps us to train it. Once the supplier has collected the data, it isprovided to Sund & Bælt to test its integration into Sund & Bælt’s IT systems.
Sund & Bælt uses IT suppliers to whom your personal data can be entrusted in connection with the operation, development and hosting of IT systems, including file management and e-mail services as well as the provision of road toll and collection solutions that enable public and private customers to effectively operate and administer ANPR-based free-flow systems.
Our suppliers are based in the UK, Ireland and Sweden.
Our suppliers, with whom we have signed data processing agreements, are data processors for Sund & Bælt and process personal data under instructions from Sund & Bælt.
The data processors are subject to confidentiality and may not use personal data for purposes other than those specified in the data processing agreement.
Purpose
Sund & Bælt processes your personal data to improve our website (www.vejafgifter.dk), remember your settings, adapt our content and analyse our traffic.
You can read more about how we use cookies in our cookie policy: www.vejafgifter.dk/cookiepolitik
Categories of personal data
We process the following types of personal data when you visit our website (www.vejafgifter.dk):
Sources
We collect data from you via your browser.
Basis for processing
Sund & Bælt’s collection of personal data through technically necessary cookies takes place on the basis of GDPR Article 6, section 1, paragraph f (legitimate interest). Our legitimate interest is to offer you an optimally functioning and efficient website.
All other data processing takes place on the basis of your consent, cf. GDPR Article 6, section 1, paragraph a (consent). You can withdraw your consent at any time by clicking on “Change of consent” in our cookie policy, which can be found here: www.vejafgifter.dk/cookiepolitik
Retention
Sund & Bælt retains your personal data in accordance with Sund & Bælt’s cookie policy. You can read the retention period for each cookie here: www.vejafgifter.dk/cookiepolitik
Recipients
Sund & Bælt uses IT and cookie suppliers to whom your personal data can be entrusted. We do so in connection to the operation, development and hosting of our IT systems and marketing solutions, including file management, e-mail services and provision of cookie banners, cookie consent and cookie declarations.
Our suppliers are based in Ireland and Denmark. We have entered data processing agreements with our suppliers and they are therefore not allowed to use the data for purposes other than those specified in the data processing agreement.
Purpose
When you contact Sund & Bælt, we collect information about you in order to answer and manage your enquiry.
Sund & Bælt uses AI solutions to support efficient case handling.
Your enquiry can also be used to test Sund & Bælt’s AI solutions to the extent that it is deemed necessary and proportionate. See more information in section 2.5.
Categories of personal data
We process the following categories of personal data when you contact us with questions about the Road Toll scheme via e-mail, telephone or chat:
Sources
Sund & Bælt collects data directly from you.
Basis for processing
When you contact us, we process your personal data according to GDPR Article 6, section 1, paragraph f (legitimate interest). Our legitimate interest is to respond to, and communicate with, individuals who contact us.
We also use AI solutions to provide efficient and targeted processing of customer enquiries. When Sund & Bælt monitors and retrains AI solutions, the legal basis for this is GDPR Article 6, section 1, paragraph f, where our legitimate interest is to ensure that the solution works optimally and delivers the correct output.
For more information on the development and testing of Sund & Bælt’s AI solutions, see section 2.5.
See section 2.4. for information on the recording of telephone conversations, which is relevant if you contact Sund & Bælt about the Road Toll scheme.
Retention
Sund & Bælt retains your personal data for up to 13 months after the most recent enquiry.
Recipients
Sund & Bælt uses IT suppliers to whom your personal data can be entrusted. We do so in connection with the operation and hosting of our IT systems, including file management and e-mail services as well as the provision of our CX platform.
Our suppliers are based in Ireland and Norway. We have entered data processing agreements with our suppliers and they are therefore not allowed to use the data for purposes other than those specified in the data processing agreement.
We may also disclose your personal data to public authorities, including SKAT, as we are legally obliged to report certain information. In the same way, we can disclose your personal data to the police and any other third parties should this be necessary.
Purpose
Sund & Bælt processes data to document the telephone conversation you have had with our employees. We also use the conversation to train our employees and for quality assurance in general.
Categories of personal data
If you contact Sund & Bælt by telephone with questions about the road toll scheme and consent to the recording of the telephone call, Sund & Bælt can process the following personal data about you:
Sources
The data is collected directly from you.
Legal basis
Sund & Bælt processes your personal data on the basis of GDPR Article 6, section 1, paragraph a (consent). You can withdraw your consent at any time by contacting Sund & Bælt’s Customer Service Department. You can find our contact details at the top of this policy.
Retention
Sund & Bælt retains telephone recordings for a maximum of three months after the conversation took place.
Recipients
Sund & Bælt uses IT suppliers to whom your personal data can be entrusted. We do so in connection with the operation, development and hosting of our IT systems, including file management and e-mail services as well as the provision of our CX platform.
Our suppliers are based in Ireland and Norway.
Data processing agreements with our suppliers ensure they may not use data for purposes other than those specified in the data processing agreement.
Sund & Bælt develops AI solutions (work processes driven by artificial intelligence) to process customer enquiries in an efficient and targeted manner.
Purpose
Data is processed to develop AI solutions that support the efficient processing enquiries from the general public.
Categories of personal data
Data used to develop and test AI solutions is sourced from electronic enquiries from the general public. If you have previously contacted Sund & Bælt electronically regarding the road toll scheme, your enquiry can be used for AI training.
In section 2.3, you can find a list of data that may be recorded when we respond to enquiries and that can be used to test AI solutions. This includes contact data and the content of the enquiry itself.
Not all previous enquiries will be used to test AI solutions.
Sources
Data is collected directly from you.
Legal basis
We process your personal data on the basis of GDPR Article 6, section 1, paragraph f (legitimate interest) where Sund & Bælt’s legitimate interest is to develop a technical solution that, in the long-term, enables a more efficient and faster response to enquiries.
Retention period
Personal data used to develop the AI solution will be retained for 28 days after the enquiry was used in the training of the AI solution. However, the data will be deleted immediately after the test period has ended, regardless of whether this period is before the 28 days.
Recipients of personal data
When developing and testing Sund & Bælt’s AI solutions, Sund & Bælt entrusts personal data to a supplier who offers IT solutions to optimise operations. This supplier is based in Denmark.
Sund & Bælt also uses an IT supplier to whom your personal data can be entrusted in connection with the operation, development and hosting of IT systems, including file management and e-mail services. This supplier is based in Ireland.
These suppliers are data processors for Sund & Bælt and only process personal data on Sund & Bælt’s instructions. We have entered into written data processing agreements with these suppliers.
Sund & Bælt’s data processors are subject to confidentiality and may not use personal data for purposes other than those specified in the data processing agreements.
As a rule, Sund & Bælt will not transfer personal data to countries outside the EU/EEA. If we transfer your personal data to countries outside the EU/EEA, we ensure that appropriate safeguards are in place. Safeguards may involve the use of Standard Contractual Clauses approved by the EU Commission pursuant to GDPR article 46.
Some of our IT systems can transfer personal data to the U.S. and other countries where our IT suppliers or their sub-suppliers are based.
If such transfers take place to a third country and/or an international organisation where the EU Commission has assessed that the country or organisation ensures an adequate level of protection, the transfer will take place on the basis of GDPR article 45. This also applies to transfers to companies in the U.S. that are certified under the EU-U.S. Data Privacy Framework as these also ensure an adequate level of protection.
If the transfers from our IT suppliers are to a third country and/or international organisation not deemed by the EU Commission to have appropriate safeguards in place, these transfers will be subject to appropriate safeguards in accordance with GDPR Article 46.
A copy of the agreement on these safeguards is available from persondata@vejafgifter.dk.
Pursuant to GDPR, you have the following rights:
In addition, you have the right to object to the processing of your data when our processing of your data is based on GDPR Article 6, section 1, paragraph e (processing in the public interest or the exercise of official authority) or paragraph f (legitimate interest). Please see our legal basis for each processing purpose above.
If you choose to object, we will reassess the necessity of our processing your personal data, and we may only continue the processing if it can still be deemed necessary after your objection.
If the processing of your personal data is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal will not affect the legality of the processing carried out prior to the withdrawal of consent. Please see above how your consent can be withdrawn.
There may be conditions or limitations to these rights. It is not certain, for example, that you have the right to deletion in a specific case. This depends on the specific circumstances of the processing activities.
You can make use of your rights by contacting persondata@vejafgifter.dk.
You also have the right to complain to the Danish Data Protection Agency about our processing of your personal data. See more at www.datatilsynet.dk.