This privacy policy explains how Sund & Bælt Holding A/S processes your personal data in connection with the provision of the website www.miljoezoner.dk, the management of the low emission zone regulation in Denmark, and your use of low emission zones customer service.

"We" and "us" in this policy refer to Sund & Bælt Holding A/S.

1. Data controller

The legal entity responsible for processing your personal data is:

Sund & Bælt Holding A/S

CVR No.: 15 69 46 88

 

Address:

Vester Søgade 10

DK-1601 Copenhagen V

 

Phone: +45 70809282

E-mail: info@miljoezoner.dk

(Hereafter referred to as “Miljøzoner”)

 

2. Description of processing

2.1 Handling your passage in a low emission zone (Copenhagen, Frederiksberg, Odense, Aarhus or Aalborg).

Categories of personal data

We process the following categories of personal data:

A) General personal data – all drivers:

Video recordings and pictures of your vehicle and license plate, vehicle type, weight of your vehicle and other technical vehicle data necessary in assessing whether a vehicle is allowed in the low emission zone, including the vehicle's location data.

B) General personal data – drivers whose driving in the zone illegal:

In addition to the information mentioned in section A, we also collect the following information: Name, address, company name and other information, including CPR number and CVR information necessary to identify you as the owner/user of a vehicle and issue a fixed penalty and an orientation letter. Transaction details related to the payment of a fixed penalty are also stored.

Purpose

We process your personal data to verify whether your passage in a low emission zone is legal.

This is done as follows:

A) We verify information from your passage, including your location and license plate. The registration number is verified against information contained in the Danish Vehicle Register to determine whether your vehicle is allowed to drive in the low emission zone according to the rules. If you drive a vehicle with a non-Danish registration number, information will be collected from the relevant foreign authorities. If your vehicle is allowed to drive in the low emission zones, your passage data will be deleted immediately. Read more about this under storage.

B) If you are in a low emission zone with a vehicle that does not comply with the low emission requirements, your passage information will be forwarded to the Danish Environmental Protection Agency so that the agency can issue a fixed-penalty or an orientation letter based on your passage. The purpose of the processing is to enforce the low emission zone regulations and to issue a fixed-penalty or orientation letter to the correct owner or user of a vehicle, who has been in a low emission zone illegally. We may, if necessary, make a check in the Danish Vehicle Register to identify you as the owner/user of a vehicle and to send fixed-penalties or orientation letters via e-Boks. Information may also be obtained from relevant foreign authorities.  

We collect information via video recordings and photos of your vehicle taken by equipment placed in all five low emission zones, including mobile equipment.

Additionally, we collect information from public authorities, including the Danish Vehicle Register managed by SKAT, and foreign vehicle registers.

Legal basis

General Data Protection Regulation article 6(1)(e) (exercise of public authority), as the processing is necessary for the performance of a task carried out in public interest, which has been assigned to the data controller.

General Data Protection Regulation article 6(1)(f) (legitimate interests), where the legitimate interest of Miljøzoner is to manage and inform citizens about significant matters.

Automated decisions

As part of the operation of the scheme, automatic decisions will be made as mentioned in General Data Protection Regulation article 22. This means that if a vehicle that is not allowed to be in a low emission zone at a certain time is in the zone, the vehicle will automatically be registered for forwarding to the Danish Environmental Protection Agency.

Storage

Personal data, including recordings and photos of your license plate, are stored as long as necessary to fulfill the purposes described above.

In practice, storage periods are set as follows:
For all registrations of photos and recordings of vehicles: Photos of your vehicle and license plate are stored for a maximum of 60 days after the registration of the passage to verify that your vehicle was in an low emission zone legally. However, most photos are deleted immediately after passage. In some cases, it may be necessary to select recordings for manual processing if, for example, an error in reading is detected.

For registrations of information where there has been a violation of the low emission zone rules:
Storing can occur for a longer period of time if the photos are to be used as evidence in a specific dispute or legal case in accordance with the rules. Information may be stored for up to two years or until payment is made.

Payment transaction information is stored for the current year plus five years in accordance with the requirements of the Danish Accounting Act.

We may also store recordings to build a vehicle database containing vehicle data to improve the recognition of vehicles by the equipment used at control points. The vehicle database works by collecting information about vehicles whose license plates cannot be correctly read automatically. These cases are initially reviewed manually. Data from manual processing will be stored and over time will optimize the automatic processing of new observations of the same vehicle, thereby reducing the number of manual processes. Information in this database can be stored for up to five years from collection.

Information collected in connection with the issuance of orientation letters is deleted 180 days after the issuance date.

2.2 Statistics and website optimization

Categories of personal data

We process the following categories of personal data about you:

Cookies and IP address.

Purpose

Optimizing the user experience on the website: Personal data is collected though your use of our website. We use this information for statistical purposes and to optimize the user experience on our website and the services we offer. See more in our cookie policy.

We collect information directly from you through your browser.

Legal basis

General Data Protection Regulation article 6(1)(f) (legitimate interests), where the legitimate interest of Miljøzone is to generate statistics and optimize the website.

Storage

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

Cookies are deleted according to Miljøzoner’s cookie policy. See cookie policy.

2.3. Recording of customer service calls

Categories of personal data

We process the following categories of personal data about you:

Name, phone number, and other information related to your inquiry, including license plate and the reference number of the fixed-penalty if your inquire is about a fixed-penalty that you have received, and your vehicle's location data.

Purpose

In connection with the quality assurance of our customer service representatives, we would like to record your phone call to our customer service. However, we will only record and use the recording for quality checks if you consent to this.

Information for this purpose is collected directly from you.

Legal basis

General Data Protection Regulation 6(1)(a) (consent). The customer can withdraw consent to the processing at any time.

Storage period

Up to three months from the time of recording the call.

2.4 Other electronic inquiries to Miljøzoner

Categories of personal data

We process the following categories of personal data about you:

Name, e-mail, phone number, registration number (if you use the "lookup" function on the website), and other information related to your inquiry, including license plate and the reference number of the fixed-penalty if you inquire about a fixed-penalty you have received, and your vehicle's location data.

Purpose

When you contact the Miljøzoner's customer service, including, for example via e-mail, we collect information about you to handle the inquiry.

This information is collected directly from you.

Legal basis

General Data Protection Regulation article 6(1)(f) (legitime interests), where the legitimate interest of Miljøzoner is to respond to the customer's inquiry.

Storage

As a rule, we store your information for up to 13 months from the final response to the inquiry. However, this does not apply to:

Information about your transactions is stored for the current year plus five years in accordance with the requirements of the Danish Accounting Act.

Information you may enter in the "look-up" function is stored for five years.

2.5 Handling your registration of exemption and dispensation

Categories of personal data

We may process the following personal data about you when you register your exemption or apply for a dispensation:

• Contact information such as name, e-mail, phone number and address
• CPR number if you have MitID
• CVR number and company name
• Information about employer
• Vehicle data
• Location data, as you choose which low emission zone you want the exemption or dispensation to apply to
• Other content you may provide in your dispensation application

If you wish to register an exemption, it may be necessary to upload a picture of your parking card for the disabled or submit documentation for granted support for the purchase of the handicap vehicle under § 114 of the Social Services Act.

Purpose

We process your personal data to register vehicles eligible for an exemption and to assist the Danish Environmental Protection Agency when making decisions on whether a vehicle is eligible for a dispensation. This is done under the Environmental Protection Act.

Name, address, vehicle data, including license plate, CPR number, CVR number, and company name are collected to identify you as the owner/user of the vehicle and to assess whether the vehicle owner/user is eligible for an exemption. These details are also collected to send you a receipt for registering an exemptions or applying for a dispensation.

Furthermore, e-mail is collected if the applicant is foreign or exempt from using MitID. Employer information is collected to assess whether the applicant is eligible for a night-time work exemption.

Sources
As a rule, we collect the above information directly from you when you register an exemption or apply for a dispensation.

We may also collect information about whether a vehicle is registered as a handicap vehicle in the Danish Vehicle Register if this is relevant to handling your exemption registration.

Legal basis for processing
We process your personal data based on article 6 (1)(e) of the General Data Protection Regulation, as the processing is necessary for the performance of a task carried out in public interest, which has been assigned to the data controller.

Sund & Bælt's tasks are outlined in the Environmental Protection Act, § 15 e, paragraph 1, and § 15 e, paragraph 5, where it states that Sund & Bælt handles tasks related to the control of vehicles in low emission zones and tasks related to nationwide communication.

Additionally, it is stated in § 20, paragraph 2, and § 26, paragraph 5 of Executive Order No. 1066 of August 3, 2023, that Sund & Bælt registers information regarding exemptions and dispensations.

When we process your CPR number, this is done based on § 11, paragraph 2, no. 4 of the Danish Data Protection Act, cf. § 7, paragraph 1, cf. article 9 (2)(f) of the General Data Protection Regulation, pursuant to article 87 of the General Data Protection Regulation. This is because the processing of your CPR number is necessary for us to notify you of your registration for an exemption (necessary for the establishment, exercise, or defense of legal claims).

Storage

Exemptions for visiting a hospital or a medical specialist, residence in a low emission zone, and night-time work are deleted one day after the exemption expires.

Exemptions for handicap vehicles are stored for 60 months from the time the exemption is granted.

Exemptions where six accesses to a low emission zone are granted are stored until 12 months after the vehicle becomes subject to the low emission zone regulations.

Exemptions are deleted one day after the exemption expires.

3. Recipients of personal data

We may disclose your personal data to the Danish Environmental Protection Agency when necessary for the agency’s issuance of fixed-penalties and for their decision on dispensations.

We also use IT providers, to whom your personal data may be entrusted, typically in connection with the operation, development, and hosting of IT systems.

These providers are our data processors, and they process your personal data under our instructions. Sund & Bælt has entered into data processing agreements with all the data processors.

Our data processors are subject to confidentiality and may not use personal data for purposes other than those specified in our data processing agreement.

4. Transfers to countries outside the EU/EEA

We transfer personal data to both data processors and sub-processors established inside and outside the EU/EEA. In cases where personal data is transferred to data processors and/or sub-processors outside the EU/EEA, we ensure a lawful transfer basis in accordance with the applicable data protection legislation at any time. You can obtain further information about the specific transfer basis by contacting info@miljoezoner.dk.

5. Your rights

When Sund & Bælt processes personal data about you, you have the right to request access, rectification, 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 your personal data restricted.

If the processing of personal data is based on consent, you have the right to withdraw consent at any time. Withdrawal will not affect the legality of the processing carried out before the withdrawal of consent.

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

There may be conditions or limitations to these rights. Therefore, it is not certain that you, for example, have the right to data portability in a particular case – this depends on the specific circumstances of the processing activities. For instance, it is also not always possible to comply with a request for deletion if we have a legitimate reason to store the personal data.

When we process your personal data, you can exercise your rights by contacting info@miljoezoner.dk. Additionally, you can always file a complaint with a data protection supervisory authority, for example, the Danish Data Protection Agency.

Last updated: 7 June 2024