Privacy Policy - Roadpricing Sund and Bælt Holding A/S

This privacy policy explains how Sund & Bælt Holding A/S process personal data in connection with the Kilometer Tolling Scheme.

In this policy, "us" and "we" mean Sund & Bælt Holding A/S.

1. Data controller

The legal entity responsible for the processing of your personal data is:

Sund & Bælt Holding A/S

CVR number: 15 69 46 88


Vester Søgade 10

1601 Copenhagen V


(Hereinafter referred to as “Sund & Bælt”)

2. Description of processing

2.1 Test site in Roskilde

Pursuant to the Danish law on road toll, Sund & Bælt is to charge toll for driving on behalf of the Danish state as per 1 January 2025 (“The Kilometer Tolling Scheme”). Before this date, Sund & Bælt must ensure that the systems, processes, etc., work.

Therefore, our supplier, Neology UK Ltd. (10809863), will mount a camera on Roskildevej with a view to training the camera to register passing cars. The camera will be mounted on 1 February 2024.

Neology processes data on behalf of Sund & Bælt and processes personal data based on instructions from Sund & Bælt. Sund & Bælt have entered into a written data processing agreement with Neology.


Categories of personal data

We proces the following personal data on persons passing the camera on Roskildevej:

Number plate, country code, vehicle type, time and location of the driving of the vehicle as well as a picture of the vehicles.

The persons who might appear on the photo will be obscured during the subsequent process.



When you pass the mounted camera on Roskildevej we will process personal data about you in order to test and train a camera for the use of the Kilometer Tolling Scheme.

Information to be used for this purpose is gathered by you passing our supplier’s test camera which then registers the vehicle.


Legal basis for the processing

Our legal basis of processing is GDPR art. 6.1.e, as the processing is necessary to perform a task which is of public interest.

Furthermore, § 17 a, sec. 1-5, in the law of Sund & Bælt (lov om Sund & Bælt) states that Sund & Bælt can process personal data when this is deemed necessary for Sund & Bælt carrying out tasks related to the Kilometer Tolling Scheme. This entails that Sund & Bælt can test systems, etc., which are to be used once the Kilometer Tolling Scheme enters into force. 



The information registered by the test camera is deleted after 30 days.


Recipients of personal data

As a rule, the information gathered by our supplier Neology is not passed on to Sund & Bælt.

In case of Sund & Bælt receiving personal data from our supplier Sund & Bælt do not intend to pass on these personal data.


2.2 Statistics and website optimisation

Categories of personal data

We process the following categories of your personal data:

The IP address of the device used, the type of device that is using Sund & Bælt’s digital platforms (e.g. computer, tablet or mobile phone) and general digital behaviour collected through cookies or other tracking technology on Sund & Bælt's websites.


Optimisation of user experience on the website: Personal data is collected when you use our website. We use this information for statistical purposes and to optimise the user experience on our website and the services we offer. See more about this in our cookie policy.

We collect information directly from you via your browser.

Processing basis

GDPR article 6(1)(f), (necessary for the pursuit of the legitimate interests of Sund & Bælt, including statistics and optimisation of the website).


We store personal data as long as it is necessary for the purposes mentioned.

Cookies are deleted according to Sund & Bælt's cookie policy for Kilometer Tolling.

2.3 Enquiries with roadpricing

Categories of personal data

We process the following categories of personal data about you:

Name, e-mail, telephone number, registration number and other information that your enquiry may relate to, including the registration number.


When you contact Sund & Bælt, including for example via e-mail, we collect data about you for the purpose of processing your enquiry.

This information is collected directly from you.

Processing basis

GDPR article 6(1)(f), (as necessary for the pursuit of our legitimate interests, including: Answering enquiries).


Up to 13 months from the final response to the enquiry.


3. Recipients of personal data (disclosure and transfer)

Sund & Bælt do not pass on your personal data only it is a statutory requirement, or it is necessary to fulfil an Agreement that Sund & Bælt has entered into with you.

Sund & Bælt also uses suppliers to whom your personal data is transferred typically in connection with: the operation, development and hosting of, for example, communication and marketing solutions; the preparation of market analyses; and IT systems for processing business data.

These suppliers are data processors for Sund & Bælt and process personal data as instructed by Sund & Bælt. Sund & Bælt has entered into written data processor agreements with these data processors.

The data processors are subject to confidentiality agreements and may not use the personal data for purposes other than those specified in the data processor agreement.

4. Transfers to countries outside the EU/EEA

Sund & Bælt transfers personal data to both data processors and sub-processors established respectively within and outside the EU/EEA. In cases of transfer of personal data to data processors and/or sub-processors outside the EU/EEA, Sund & Bælt ensures that such transfer is made on a legal basis in accordance with the data protection legislation in force at all times. You can get further information about the basis for specific transfers by contacting Sund & Bælt.


5. The data subject's rights according to section 3 of the EU Data Protection Regulation

If Sund & Bælt processes personal data about you, you have the right to request insight, correction and deletion of your personal data, as well as the right to object to the processing of your personal data and to have the processing of the personal data restricted.

If the processing of the personal data is based on consent, you have the right to revoke the consent at any time. Revocation will not affect the legality of the processing carried out prior to the revocation of consent.

You also have the right to receive the personal data that you have submitted yourself in a structured, commonly used and machine-readable format (data portability).

Conditions or limitations to these rights may apply. It is therefore not certain that you, for example, have the right to data portability in a particular case, depending on the specific processing circumstances. Nor is it, as an example, always possible to comply with a deletion request if Sund & Bælt has a legitimate reason to store the personal data.

When Sund & Bælt processes personal data about you, you can exercise your rights by contacting, and you may at any time lodge a complaint with a data protection supervisory authority, such as The Data Protection Authority in Denmark.

Last updated: 2 February 2024

Language: English

Language: English