Privacy Policy

MFT Energy A/S, business reg. no.: 38175130, Margrethepladsen 4, 3rd floor, 8000 Aarhus C, Denmark and its subsidiaries (collectively “MFT Energy”) are committed to handling personal data responsibly and in accordance with applicable data protection legislation.

This privacy policy is intended to provide information on MFT Energy’s processing of personal data collected from users of our website, users of our profiles on social media platforms, contact persons at MFT Energy’s business partners, job applicants as well as data subjects which are part of a whistleblower reporting (i.e. the senders of notifications, the reported persons and other third parties involved).

We encourage you to read this policy to learn more about the ways we collect, use, disclose and protect your personal data.

1. If you visit our websites

The data controller of your personal data processed through MFT Energy’s website is MFT Energy A/S.

Collection of personal data
MFT Energy may collect, process and store personal data about you in the following instances:

  • When you sign up for our newsletter
  • When you communicate with MFT Energy
  • When you visit and browse our website
  • When you make use of other functions and services offered by MFT Energy

Types of personal data
MFT Energy may collect, process and store the following personal data about you:

  • Name, e-mail address, telephone number and similar identification data
  • Company name and company address
  • Branch/business area
  • Content of inquiries
  • IP address and MAC address
  • Device ID and device type
  • Operating system and version
  • Browser type and screen resolution
  • Device manufacturer and model
  • Information about your usage of our website

Cookies
We use cookies on our website. Please read more about the use of cookies in our cookie policy, which is available on MFT Energy’s website.

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Forwarding of newsletters
  • Promotional marketing in general
  • Completion of requests received from you
  • General communication
  • Providing support
  • Product and service development
  • Statistics and analysis

Legal basis
MFT Energy will mainly process your personal data based on one or more of the following legal bases:

  • Legitimate interests: In most cases, the processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our services (Article 6(1)(f) of the GDPR).
  • Consent: MFT Energy will only use your personal data in order to send you marketing material via e-mail if you have provided your prior and explicit consent hereto, unless applicable legislation allows us to contact you without such consent (Article 6(1)(a) of the GDPR).

Retention period
Your personal data will be deleted when it is no longer needed for one or more of the purposes mentioned above.
Personal data relating to statistics and analytics is deleted within 1 year.
Documentation of your marketing consent is kept for 2 years from the time you have withdrawn your consent to receive direct marketing material.
The personal data may, however, be processed and stored for a longer period of time if anonymised.

2. If you visit our profiles on social media

This section applies to MFT Energy’s processing of personal data which you leave behind and/or provide when you visit MFT Energy’s profile on LinkedIn (the “social media”). This section is a supplement to the general privacy policy issued by the social media. LinkedIn have published an addendum on the joint controllership which you may go to by clicking here (LinkedIn).

MFT Energy and the individual social media are joint data controllers in the processing of your personal data. MFT Energy complies with the guidelines of the European supervisory authorities concerning joint controllership and MFT Energy attempts to ensure that you receive information on the processing of your personal information when you visit our sites on the social medias.

Processing of your personal data through social medias
Depending on your conduct on the social media sites, MFT Energy and the social medias may retrieve the following personal data about you:

  • Your “likes” or other reactions expressed on the sites
  • Comments left by you on the sites
  • Your visits to the sites

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Development, improvement and protection of our services
  • Performance of research activities and statistics

The social medias collect statistical data on the visitors’ behavior for their own purposes through cookies and pixels on your device when you visit the sites. Each cookie contains a unique identification code which remains active for a certain period, unless it is deleted prior to expiry of such period.

You can read more about the social medias processing of personal data by visiting their privacy policies (LinkedIn) and cookie policies (LinkedIn).

Legal basis
MFT Energy will mainly process your personal data based on the following legal basis:

  • Legitimate interests: We may process your personal data on the basis of our legitimate interests in communicating with you and marketing ourselves to you on our social media profiles, as well as our legitimate interest in improving our products and services (Article 6(1)(f) of the GDPR).
  • The providers of the social media process, among other things, your personal data to enable them to improve their advertisement system and to provide MFT Energy with statistics, which the provider, for example, works out on the basis of your visit to MFT Energy’s profile or fan page on the social media in question, with a view to advertising and customising the activities on the profile or fan page. The providers of the social media process your personal data as a consequence of their legitimate interests, including their interest in providing innovative, customised, secure and profitable services (Article 6(1)(f) of the GDPR).
  • Consent: The providers of social media may also process your personal data in accordance with your consent, which you are entitled to withdraw at any point in time via the settings on the website of the social media in question (Article 6(1)(a) of the GDPR).

Sharing of your personal data
MFT Energy will at no point disclose your personal data collected via social medias to third parties.

The social medias may share your personal data internally among its subsidiaries and externally among its partners using analytical services, advertisers, other individuals, surveying partners and researchers and academics. Such transfers may include transfers to countries outside EU. For more information, please refer to the social medias’ terms and conditions and privacy policies linked to above.

Rights towards the social medias
The social medias general set-up dictate that you must contact the social media in question if you wish to exercise your rights. This is owing to the fact that only the social medias are, in pure functional terms, capable of taking the steps necessary to comply with most of your requests. If, however, you are of the opinion that MFT Energy is capable of complying with your request, please do not hesitate to contact us.

If you are a Facebook user, you may exercise your rights by changing your private settings (link) or configure your preferences (link) in order to have an influence on how your personal data will be collected and processed when you visit and use the Facebook site. If you are a LinkedIn user, click here (link) to change your settings or here (link) to exercise your rights.

Retention period
We delete private messages no later than after 2 years. However, the information can be stored for a longer period in anonymised form.

We encourage you to delete comments, likes and other interactions you have left on our profile yourself if you no longer want them shown on our pages. MFT Energy does not delete such publicly available interactions.

Please refer to the privacy policy of the provider for each of the social media platforms for information on how long they store your personal data.

3. If you are a contact person at our business partner

This section sets out the policy of MFT Energy’s processing of personal data collected from owners of sole proprietorships or contact persons at MFT Energy’s business partners who collaborate with MFT Energy.

The data controller in such relation is the MFT Energy entity with which you cooperate. If you are unsure which entity you cooperate with, feel free to contact our Compliance team at compliance@mft-energy.com.

Collection of personal data
MFT Energy may collect, process and store personal data about you in the following instances:

  • When your company or the company you are employed with enters into an agreement with MFT Energy
  • When you have shown an interest in MFT Energy’s products or services, e.g. by providing your business card to MFT Energy
  • When you make use of MFT Energy’s website
  • When you collaborate and communicate with MFT Energy
  • When you visit our physical addresses

Types of personal data
MFT Energy may collect, process and store the following personal data:

  • Name, e-mail address, telephone number and similar identification data
  • Individual data, such as preferred language
  • Organizational data, such as company name, company address, job position, business area, primary work location and country
  • Contractual data, such as invoices, contracts and other agreements between your company (or your employer) and MFT Energy, that may include e.g. your contact information
  • Financial data, such as payment terms, bank account details and credit ratings
  • IT-related data, such as logs about your usage of MFT Energy’s website
  • Information provided when you visit our physical addresses, e.g. registration of visitors or recordings from video surveillance
  • Recordings from specific trade-related phone calls
    Such information may be provided directly by you (primarily via e-mails and other correspondence) or by a third party such as your employer.

Purposes of the processing
Your personal data may be processed for the following purposes:

  • Generally, to plan, perform and manage the business relationship, including any contracts
  • Administration, such as processing payments (including collection of outstanding invoices), evaluation of credit ratings, performing accounting, auditing, billing activities, arranging shipments and deliveries as well as providing support services
  • Ensuring safety and security on our physical addresses
  • Completion of requests received from you
  • General, including promotional, communication
  • Evaluation and development of our services, including statistics and analytics
  • Compliance and regulatory purposes, such as fulfilling our legal and compliance-related obligations to prevent illegal activity
  • Documentation and verification of correctness of trades
  • Dispute handling

Legal basis
MFT Energy will mainly process your personal data based on the following legal bases:

  • Contractual obligation: The processing of your personal data will in some cases be necessary for the performance of a contract (Article 6(1)(b) of the GDPR).
  • Legitimate interests: We may process your personal data pursuant to our legitimate interest in, for instance, to manage daily operations according to lawful and fair business practices, including planning, performing and managing the business relationship or our legitimate interest in e.g. fulfilling our contractual rights and obligations with our company, conducting credit ratings, documenting and verifying correctness of trades, statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services (Article 6(1)(f) of the GDPR).
  • Legal claims: The processing may also be necessary to prevent fraud or establish, exercise or defend legal claims (Article 6(1)(f) of the GDPR).
  • Legal obligation: The processing of your personal data will in some cases be necessary to comply with legal obligations, such as our obligations to prevent illegal activity (Article 6(1)(c) of the GDPR).
  • Consent: In exceptional cases and only when no other legal basis can be applied, MFT Energy may ask separately for your consent to process your personal data (Article 6(1)(a) and 9(2)(a) of the GDPR). MFT Energy will, for instance, only use your personal data in order to send you marketing material via e-mail if you have provided your prior and explicit consent hereto, unless applicable legislation allows us to contact you without such consent.

Retention period
Your personal data will be deleted when it is no longer needed for one or more of the purposes mentioned above.

However, subject to other requirements under local law, the following retention periods apply:

  • Personal data included in accounting records is kept for 5 years from the end of the financial year to which the records relates.
  • Personal data collected in connection with business, support or other commercial activities will be stored as long as such data is relevant for the handling and monitoring of the issue in question. The retention period will typically be commensurate with the period laid down in the rules on limitation of legal claims or the duration of our business relationship.
  • Recordings from specific trade-related phone calls are deleted no more than 1 year from recordings are made.

The personal data may, however, be processed and stored for a longer period of time if anonymised or if we are obliged to do so according to law.

4. If you use our whistleblowing system

The data controller of your personal data processed through MFT Energy’s whistleblowing system is MFT Energy A/S.

Serious and sensitive concerns that may have an adverse impact on the operations and performance of MFT Energy or which may have a significant effect on a person’s life or health may be reported via our whistleblowing system, whereby MFT Energy will process personal data about data subjects which are part of a whistleblower reporting (i.e. the senders of notifications, the reported persons and other third parties involved).

Collection of personal data
MFT Energy may collect and process personal data when a reporting is made as well as during the investigation of reports.

Types of personal data
If you report a suspected misconduct, such report will remain confidential and, if desired, anonymous. You should in any case provide a contact email address, as the investigating person may need to contact you for further details on the incident to be able to handle the case properly.
We may process the following personal data about the reported person:

  • Name, job position, contact information and reported facts, including description of the alleged infringement and potential criminal offenses
    The following personal data may be processed about other third parties mentioned in the report:
  • Name, job position, contact information and reported facts

Purposes of the processing
MFT Energy may process personal data for the following purposes:

  • Establishment and administration of the whistleblower service, where suspicion of unregulated conduct and violations of applicable law or internal guidelines can be reported
  • Administration of reported incidents, including clarification of potentially criminal matters

Legal basis
MFT Energy will mainly process the personal data based on one or more of the following legal bases:

  • Legitimate interest: We may process your personal data on the basis of our legitimate interest in investigating reported incidents (Article 6(1)(f) of the GDPR).
  • Legal obligation: We process your personal data in order to fulfil our legal obligations (Article 6(1)(c) of the GDPR).

Retention period
Subject to other requirements under local law, the report and collected information will be deleted:

  • Immediately if the report is outside the scope or is manifestly unfounded, or if no internal action is made in relation to the concern.
  • Right after the closing of the case by the authorities if a report is filed with the police or other relevant authorities.
  • 2 months after the investigation has been completed if no further action is taken.
  • If disciplinary sanctions are made towards the reported employee based on the collected information or there are other reasons for it being necessary to continue storing the information, the collected information may be transferred to the employee’s personnel file. In such case the personal data will be deleted no later than 5 years after termination of employment.

5. If you apply for a job

This section sets out the policy for MFT Energy’s processing of personal data in relation to recruitment. The data controller of your personal data processed as a part of the recruitment procedure is the MFT Energy entity with which you seek employment.

Types of personal data
MFT Energy may collect, process, and store the following personal data:

  • Personal data which you have disclosed in your job application and CV as well as any attachments
  • Personal data you disclose during any job interviews
  • Information about you, including information regarding your previous jobs, activities, competencies, performance, as well as your general appearance, which is publicly available on the internet, including on social media
  • Criminal records, if relevant for the position you apply for
  • Results of personality tests
  • References from your previous and/or current employers
  • Additional information you will provide in relation to the recruitment process

Purposes of the processing
Your personal data will be processed for the purpose of assessing whether we can offer you a position at MFT Energy.

Legal basis
MFT Energy will process your personal data based on the following legal bases:

  • Legitimate interests: We may process your personal data on the basis of our legitimate interests in carrying out further assessments of whether we want to hire you, including on the basis of the information you provide in your CV, job application and any supporting documents, based on relevant information publicly available on the internet and social media, results of personality and skills tests, references you have provided in your application and other information you provide to us in the recruitment process. The processing may also be necessary for our legitimate interests in defending or enforcing legal claims (Article 6(1)(f) and 9(2)(e) of the GDPR).
  • Consent: If we wish to obtain references from previous and/or current employers that you have not provided in your application, we will only do so with your consent (Article 6(1)(a) of the GDPR).

If the position you have applied for exceptionally requires special health conditions, we will – after specific assessment – ask for your explicit consent prior to processing such personal data (Article 9(2)(a) and article 6(1)(a) of the GDPR)

Retention period
If you are offered a position with MFT Energy, your application and additional relevant personal data obtained during the recruitment procedure will be stored in your employee file.

If you are not offered a position, we will store your application and any additional personal data obtained during the recruitment procedure for a period of 3 months following our rejection, unless you have provided your consent to the storage hereof for a longer period.

If we have collected your criminal records, we will delete them immediately after we have received and reviewed them.

6. General information applicable for all individuals covered by this privacy policy

Disclosure to other data controllers and transfer to data processors
To meet the purposes mentioned above we may give third parties, who provide relevant services on basis of a contractual relationship with MFT Energy, access to your personal data, including providers of e.g. IT services, ERP systems, invoicing systems, marketing services, website analytics, IT support, IT service development as well as digital developers, e-mail operators, hosting providers and other suppliers providing systems or services to MFT Energy. Such service suppliers may only process personal data on behalf of MFT Energy and in accordance with our instructions.


Your personal data may be disclosed to accountants. Under certain circumstances it may also be necessary to disclose your personal data to lawyers, courts, public authorities, the police and potential buyers.
Personal data may also be shared within the MFT Energy group as MFT Energy A/S provides essential services to other group entities. Furthermore, subsidiaries to MFT Energy A/S may disclose personal data to MFT Energy A/S, e.g. for internal administrative purposes.


In connection with MFT Energy’s development, the company structure may change, e.g. through a full or partial sale of MFT Energy. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, as a general rule, MFT Energy’s legitimate interest in handing over parts of its assets as well as making commercial changes.
If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA which do not have an adequate level of protection, such transfers will in general be based on the EU Commission’s Standard Contractual Clauses.

Security
We have implemented numerous security measures to prevent, for example, the loss and misuse of personal data under our control. Upon receipt of your personal data, we apply all necessary procedures and safeguards to such data. Secure use of our website is ensured by the SSL (Secure Socket Layer) certificate. With an SSL certificate, the information sent between the user’s browser and MFT Energy A/S server is encrypted. Details of the certificate can be found at www.ssls.com. Accordingly, we use our best endeavors to protect the quality and integrity of your personal data.

Your rights

  • You have the right to access the personal data we process about you
  • You have a right of objection towards our collection and further processing of your personal data
  • You have the right to have your personal data rectified and deleted, with certain national statutory exceptions
  • You have the right to request us to restrict the processing of your personal data
  • Under certain circumstances you may also request to receive a copy of your personal data as well as the transmission of your personal data which you have provided us with to another data controller (data portability)
  • You may at any time withdraw the consents that you have given.

Questions or complaints
If you have any questions in relation to this privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us at compliance@mft-energy.com.
If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to the supervisory authority in your country. A list of European supervisory authorities is available here.