This privacy policy explains how your personal data is processed in connection with the provision of the www.miljoezoner.dk website, the administration of the Low Emission Zones scheme in Denmark and your use of Low Emission Zones customer service.

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

Address:

Vester Søgade 10

1601 Copenhagen V

Tel: +45 70809282

Email: info@miljoezoner.dk

(Hereinafter referred to as “Low Emission Zones”)

2. Description of processing

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

Personal data categories

We process the following categories of personal data about you:

A) General personal data – all drivers:

Video recordings and images of your vehicle and registration number, vehicle type, weight and other technical vehicle data needed to assess whether a vehicle is allowed to operate in the low emission zones, including the vehicle's location data.

B) General personal data – drivers driving illegally in a zone:

In addition to the information mentioned in point A, the following information is collected: name, address, company name and other data, including CPR and CVR information necessary to identify you as the owner/user of a vehicle and to issue an administrative fixed penalty notice and information letter. Transaction data from the payment of an administrative fixed penalty notice is also stored.

Purpose

We process your personal data in order to determine the legality of your passage through a low emission zone.

This happens as follows:

A) We verify information about your passage through the low emission zone, including information about your location and registration number. The registration number is verified against information contained in the Central Register for Motor Vehicles to determine whether your vehicle operating in the low emission zone is in compliance with the rules. If you drive a car with a foreign registration number, information will be collected from the relevant foreign authorities. If your vehicle is allowed to drive in the low emission zones, the collected data from your passage through the low emission zone will be deleted immediately. Read more about this below under storage.

B) If you are in a low emission zone with a vehicle that does not comply with the environmental requirements, your passage through the low emission zone will be forwarded to the Danish Environmental Protection Agency so that the Danish Environmental Protection Agency can issue an administrative fixed penalty notice or information letter based on your passage through the low emission zone. The obvious purpose of the data collection and processing is to enforce the low emission zone rules and to issue an administrative fixed penalty notice or information letter to the rightful owner or user of a vehicle operated illegally in a low emission zone. In this context, when necessary, we can make an entry into the Central Register for Motor Vehicles to identify you as the owner/user of a vehicle and to be able to issue administrative fixed penalty notices or send information letters via E-box. Information may also be obtained from relevant foreign authorities.  

We collect information via video recordings and pictures of your car taken by equipment, including mobile equipment, located in all five low emission zones.

In addition, we collect information from public authorities, including the Central Register for Motor Vehicles maintained by SKAT, as well as foreign vehicle registers.

Processing basis

Data protection regulation (GDPR) article 6(1)(e), (as necessary for the data controller to carry out a required task in the public interest).

Data Protection Regulation article 6(1)(f), (balancing of interests), where the legitimate interest of the low emission zones is to be able to administer and inform the individual about significant matters.

Automatic decisions

As part of the operation, automatic decisions will be made as mentioned in GDPR article 22. This means that if a vehicle that is not allowed in a low emission zone at a certain time is in the zone, the vehicle will automatically be registered with a view to passing on the registration to the Danish Environmental Protection Agency.

Storage

Personal information, including recordings and images of your registration number, is stored for as long as necessary to fulfill the purposes described above.

In practice, the retention periods are set as follows: For all registration of images and recordings of vehicles: images of your car and registration number are stored for a maximum of 60 days after the registration of the passage through a low emission zone in order to verify that your vehicle was legally present in a low emission zone. However, the majority of the images are deleted immediately after their collection. In some cases, however, it will be necessary to tag registrations for manual processing if, for example, an error is detected in the reading.

For registration of information in cases of violations of the low emission zone rules: in these instances, collected data may be stored for a longer period of time if the images are to be used as documentation in specific disputes or court cases in accordance with the rules. In such circumstances, information may be stored for up to two years or until payment has been made.

Payment transaction data is stored for the current year plus five years in accordance with the Danish Bookkeeping Act.

We may also store recordings in order to build a vehicle database containing vehicle data in order to improve the recognition of vehicles by the equipment used at zone checkpoints. The vehicle database works in such a way that information is collected on vehicles when the registration number cannot be correctly read by the automated reader. These cases are initially reviewed manually. Data from the manual processing will be saved and will over time optimise the automatic processing of repeat observations of the same vehicle, thus reducing the volume of manual processing. Information in this database can be stored for a period of up to five years from the date of collection.

Data collected in connection with the sending of information letters is deleted 180 days after the time of issue.

2.2 Statistics and website optimisation

Categories of personal data

We process the following categories of your personal data:

Cookies and IP address.

Purpose

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 low emission zones, including statistics and optimisation of the website).

Storage

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

Cookies are deleted according to the low emission zone’s cookie policy. See cookie policy.

2.3. Recording of customer service telephone conversations

Categories of personal data

We process the following categories of personal data about you:

Name, telephone number and other information related to your enquiry, including the registration number and the reference number of the respective administrative fixed penalty notice if you are enquiring about an administrative fixed penalty notice that you have been issued, and your vehicle's location data.

Purpose

We want to record your telephone enquiry with our customer service employees as part of our customer service quality control. However, we will only record and use the recording for quality checks with your consent.

Information for this purpose is collected directly from you.

Processing basis

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

Storage period

Up to 3 months from the time of recording the conversation.

2.4 Other electronic enquiries with low emission zones

Categories of personal data

We process the following categories of personal data about you:

Name, e-mail, telephone number, registration number (if you use "look-up") and other information that your enquiry may relate to, including the registration number and reference number of the administrative fixed penalty notice if you are asking about an administrative fixed penalty notice that you have been issued, as well as your vehicle's location data.

Purpose

When you contact the Low Emission Zone customer service, 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).

Storage

Up to 13 months from the final response to the enquiry. However, this does not apply to:

Information about your transactions which is kept for the current year plus five years as required by the Danish Bookkeeping Act.

The information you enter in the "look-up" function is stored for five years.

2.5 Processing your registration of exemption, dispensation and subsidy

Categories of personal data

We process the following personal data about you:

Name, e-mail, address, CPR number, CVR number, company name, vehicle data, health data, employer information, location data and annual income.

Purpose

We process your personal data in order to decide whether the vehicle is entitled to an exemption and dispensation, as well as whether the vehicle owner can receive a subsidy for the installation of a particulate filter, pursuant to the Environmental Protection Act. Name, address, vehicle data, CPR number, CVR number and company name are collected to be able to assess whether the vehicle owner is entitled to an exemption, dispensation and a subsidy for particulate filters, to identify you as the owner/user of the vehicle and to give notification to the applicant of the decision on a registration. For this, e-mail is obtained if the applicant is foreign or exempt from using MitID. Registration number information is also collected to determine whether the vehicle complies with the requirements for the respective registration.

Location data is provided by the applicant. Selection is made in the application as to which zone they want the exemption or dispensation to apply.

To ensure the owner/user of the vehicle is entitled to an exemption relating to health conditions we ask the applicant to provide or give access to health data.

Information about the employer is collected in order to assess whether the applicant is entitled to an exemption for night work.

For applications for subsidies for particulate filters, information is collected on annual income to determine whether the applicant complies with the eligibility requirements for receiving subsidies for the installation of particulate filters. We obtain the information directly from you and from Danish and foreign vehicle registers.

Basis for processing

General Data Protection Regulation (GDPR) article 6(1)(e) (As necessary for the data controller to carry out a required task in the public interest).

Storage

Exemptions for hospital and specialist doctor visits, residence in a low emission zone and night work are deleted one day after each respective exemption expires.

Exemptions for vehicles for the disabled are stored for 36 months from the time the exemption is announced.

Data related to exemptions granting six times of low emission zone access, is stored for 12 months following the date from which the respective vehicle is subject to the low emission zone rules.

Dispensations are deleted 1 day after the expiry of each respective dispensation. The applicant indicates the desired period for the dispensation to apply.

Personal data related to subsidies for the installation of a particulate filter is stored until one day after the final deadline for applying.

3. Recipients of personal data

We may share your personal data with:

The Danish Environmental Protection Agency: The agency is the public authority that administers the low emission zone scheme and thus decides, based on passage data, whether or not an administrative fixed penalty notice should be issued to an owner/user of a vehicle that has driven illegally in a low emission zone.

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 info@miljoezoner.dk, 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: 17 May 2023