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twoday Freelance – privacy policy

Processing of Freelancers’ Personal Data

The purpose of this content is to inform you about which personal data twoday A/S, CVR no. 29973334 ("twoday", "we", "our") is processing about you, including how such personal data is processed, and what rights you have in this context pursuant to the General Data Protection Regulation1.

1. The data controller
1.1

As data controller, twoday is responsible for all personal data processed about you as a freelancer, regardless of whether twoday processes the information itself or whether twoday uses any data processor to process the information.
1.2

twoday can be contacted by e-mail: DK-kontrakt-Freelance@twoday.com and by letter addressed to Gærtorvet 1-5, 1799 København V.

2. When do we process your personal data?
2.1

We process your personal data when:

  • You as a freelancer enter into an agreement with twoday.
  • We have a legal obligation to do so.
  • It is necessary to pursue our legitimate interest.
  • You have consented to our use of your personal data for a specific purpose.

3. Which personal data do we process?
3.1

The personal data twoday process about you, includes (but is not limited to):

  • Name, address, telephone number, photo, contact information, geographical location, and CVR number.
  • Financial information such as invoices and bank information.
  • Information about your education and diplomas, previous and current employments (CV), and references.
3.2

twoday determines which types of information that is necessary and sufficient to fulfil the purpose specified under section 4 below, in relation to processing your information in our freelancer database.

4. The purpose of processing your personal data
4.1

twoday processes personal data about you in our systems for various reasons. These reasons include the following:

  • Assessing your competencies and offering it to relevant customers and companies within the twoday Group.
  • Handling of payment for your freelance services.
4.2

twoday processes your personal data if we have a legitimate interest that supersedes your interest in not having your personal data processed by twoday. This may be the case in the following instances:

  • We process personal data obtained from publicly available sources to assess the adequacy and relevance of your competencies concerning project descriptions received from our customers and companies.
  • We deem it essential to safeguard our reputation and brand integrity, whereby the processing of your personal data is deemed necessary to fulfil this objective.
  • During the course of any unsettled legal dispute in which both twoday and you are a part, we have the legitimate interest in processing your personal data, regardless of the origin of the dispute or the roles assumed in the dispute.

5. Lawful bias
5.1

Your personal data is processed in accordance with Article 6(1)(a), (b), and (f) of the General Data Protection Regulation as well as section 7 of the Danish Data Protection Act and section 6(1) of the Danish Data Protection Act.

6. Collection of your personal data
6.1

The personal data twoday processes about you, is collected from: 

  • Yourself as a freelancer
  • Your potential references and previous employers
  • Websites, LinkedIn and other publicly available social media accounts, etc.

7. Transfer of your personal data
7.1

twoday only transfers your personal data in cases where it is relevant for the reasons stipulated in section 4 and when there is a lawful basis for the processing as stipulated in section 5.
7.2

Your personal data may be transferred to the following:

  • twoday’s customers
  • Companies within the twoday Group
  • twoday’s Entry Freelance Database supplied by Visma IMS
  • twoday’s ERP-system supplied by Visma Business
  • twoday’s payroll administrator performed by Azets
  • Public authorities

8. Storing of your personal data
8.1

Your personal data is processed in twoday’s Entry Freelance Database, which is provided by Visma IMS A/S and acts as our data processor.
8.2

twoday stores your personal data for as long as needed. However, you will receive a notification every 12 months regarding twoday's ongoing processing of your personal data. The notification refers to twoday’s privacy policy, including your right to erasure.

9. Consent
9.1

If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time by contacting twoday by e-mail or by letter. Contact details are stated in section 1(2). If you withdraw your consent, twoday will immediately cease to process such personal data.
9.2

If you withdraw your consent, it will not affect the lawfulness of the processing of your personal data that has already taken place in accordance with a previously granted consent. The withdrawal only concerns any future processing of your personal data.

10. Your rights
10.1

Pursuant to the General Data Protection Regulation, you have several rights as listed in sections 10(4) – 10(8), which you can have fulfilled upon request to twoday.
10.2

twoday must comply with your request without undue delay and will forward your request to all relevant parties. Please note that your rights do not apply (in full) in all events. For example: we do not delete personal data that we are required to store by law.
10.3

twoday will inform the recipients to whom your personal data may have been transferred to, of your request for rectification, erasure or restriction, unless this proves impossible or excessively challenging.
10.4

Right of access
You have the right to request access to the personal information twoday has registered/and processes about you, cf. Article 15 of the General Data Protection Regulation.
10.5

Right to rectification
If there are errors in the personal data that twoday processes about you, you have the right to have this information corrected, cf. Article 16 of the General Data Protection Regulation.
10.6

Right to erasure
You have the right to request erasure of your personal data if the conditions in Article 17 of the General Data Protection regulation are met.
10.7

Right to restriction
You have the right to have twoday’s processing of your personal data restricted if the conditions in Article 18 of the General Data Protection Regulation are met.
In the event that the processing of your personal data has been restricted, twoday is only entitled to process your personal data (i) with your prior consent, (ii) for the establishment, exercise or defence of a legal claim or (iii) to protect natural and/or legal persons or important public interests.
10.8

Right to object
You have the right at any time - for reasons relating to your specific situation - to object to otherwise lawful processing of your personal data, for example, if you have compelling legitimate grounds against the processing, in accordance with Article 21 of the General Data Protection Regulation. twoday will then assess the necessity of the processing again and may possibly cease the processing of your personal data as a result.

11. Complaints
11.1

If you have any concerns in regard to how twoday processes your personal data or if you wish to file a complaint, please don’t hesitate to contact twoday, so that a solution can be found.
11.2

You are, at any time, entitled to file a complaint with the Danish Data Protection Agency, if you find the way twoday processes your personal data unsatisfactory.
11.3

Contact information for the Danish Data Protection Agency can be found here: www.datatilsynet.dk.

12. Changes
12.1

twoday may change this privacy policy at any time. You are encouraged to review the privacy policy on twoday’s website regularly.

Last updated: July 9th 2024

1 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of the natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). Article 13(1) and (2) states that the data controller must provide data subjects with certain information when personal data are collected from the data subject.