Privacy policy for the App

Privacy policy - My Distribution App

This privacy policy describes how FK Distribution A/S processes personal data in connection with your use of the My Distribution App, which is a digital work tool used for the performance of your job tasks.

1. Data Controller and Contact Information

My Distribution App (“App” or “the App“) is provided by FK Distribution A/S, which is the data controller for the processing of personal data about you in the App.

Our contact details are:
FK Distribution A/S
CVR no. 26899737
Bredebjergvej 6
2630 Taastrup

(Hereafter “FK,” “We,” “we“)

If you have questions regarding FK’s processing of personal data, you can send an email to GDPR@northmedia.dk.

 

2. Description of the Processing

2.1 Login and Verification

We process your personal data in connection with your login to the App to ensure that the App can only be accessed by individuals employed at FK who have a work-related need.

We process the following personal data about you: payroll number, self-selected password, multi-factor authentication, and phone number.

We collect the personal data directly from you through your use of the App.

We process your personal data based on GDPR Article 6.1.b, as the processing is necessary for the performance of a contract (employment agreement) to which you are a party, under which it has been agreed that we provide digital work tools to you for the purpose of carrying out your job duties as a distributor.

We retain the above personal data about you for as long as you have an active employment relationship with us and for five years thereafter for FK’s documentation of your employment.

 

2.2 Continuous Use of the App

We process your personal data in connection with your ongoing use of the App in order to provide you with a functional App that you can use in the performance of your work as a distributor and to give you ongoing insight into your employment relationship, including salary conditions and related benefits.

We process the following personal data about you: IP address, device ID, device platform, device model, device OS, user ID, session ID, app version, rejection or acceptance of push notifications, employment status, financial information, salary, earned points, preferred language in the App, acceptance of terms of use of the App, rejection or acceptance of cookies, profile and contact information including address, date of birth, email, name, gender, language preference, and phone number, information about routes, route reports including error reports, walking sequences including specific requests for changes in leaflet packaging, final reports, and status of completion of help videos.

We collect the personal data directly from you through your use of the App.

We process your personal data based on GDPR Article 6.1.b, as the processing is necessary for the performance of a contract to which you are a party, whereby it is agreed that we provide digital work tools for your use in the execution of your duties as a distributor.

We retain the above personal data about you for as long as you have an active employment relationship with us and for five years thereafter for FK’s documentation of your employment.

 

2.3 Special Conditions Regarding Points and the Point Shop

If you are a young distributor (under the age of 18), we process your personal data in connection with the registration of accumulated points, selected favorite products, history of point usage, and purchases you make in the Point Shop. The purpose is to manage your earned points and ensure the correct delivery of purchased gifts.

We process the following personal data about you: IP address, device ID, device platform, device model, device OS, user ID, session ID, app version, information about earned points, preferred language in the App, profile and contact information including address, email, name, gender, language preference, and phone number, selection of gifts as favorites, gift purchases including the chosen gifts, and use of points.

We collect the personal data directly from you through your use of the App or our web application, which offers the same functionality as the App.

We process your personal data based on GDPR Article 6.1.b, as the processing is necessary for the performance of a contract to which you are a party, under which it has been agreed that we provide digital work tools to you for use in carrying out your duties as a distributor.

We retain the above personal data about you for as long as you have an active employment relationship with us and for five years thereafter for FK’s documentation of your employment.

 

2.4 Special Conditions Regarding Map Functionality

We process your personal data in connection with your use of the App’s map functionality to display your route, including navigation to the individual addresses on your route. The processing is carried out to make it easier for you to complete your route in the best possible way.

The map functionality only works if you have granted permission to use your GPS location on your tablet or smartphone.

We process the following personal data about you: IP address, device ID, device platform, device model, device OS, user ID, session ID, app version, information about routes and walking sequences.

We collect the personal data directly from you through your use of the App.

We process your personal data on the basis of GDPR Article 6.1.b, as the processing is necessary for the performance of a contract to which you are a party, under which it has been agreed that we provide digital work tools for you to carry out your duties as a distributor.

Please note that Google Cloud EMEA Limited (when using Android products) or Apple Inc. (when using Apple products) may process information about your GPS location in order to link your GPS coordinates to an address or vice versa. We are not responsible for this independent processing.

We retain the above personal data about you for as long as you have an active employment relationship with us and for five years thereafter for FK’s documentation of your employment.

 

2.5 Special Conditions Regarding Chat Functionality

We process your personal data in connection with your use of the chat function in the App, where you have the opportunity to ask questions, including how to best pack your trailer, how to finalize your route, and similar topics.

We process the following personal data about you: user ID, session ID, and chat content, including both questions and answers.

We collect the personal data directly from you through your use of the App.

We process your personal data on the basis of GDPR Article 6.1.b, as the processing is necessary for the performance of a contract to which you are a party, under which it has been agreed that we provide digital work tools for you to carry out your duties as a distributor.

We retain the above personal data about you for as long as you have an active employment relationship with FK and for two years thereafter for FK’s documentation of your employment.

 

2.6 Special Conditions Regarding Push Notifications and Notification Inbox

If you have given consent to receive push notifications in the App, we process your personal data in order to send you relevant messages directly to your phone via the App. Push notifications may include, for example, reminders about timely final reporting or information about your distribution. Regardless of whether you have given consent to receive push notifications or not, all messages will be available in the App’s notification inbox. Messages via push notifications and the notification inbox cannot be replied to. You can withdraw your consent to receive push notifications in the App at any time via your profile.

We process the following personal data about you: IP address, device ID, device platform, device model, device OS, user ID, session ID, app version, acceptance or rejection of push notifications, employment status, financial information, preferred language in the App, profile and contact information including address, date of birth, email, name, gender, language preference, and phone number, information about routes, route reports including error reports and final reports, and status of completion of help videos.

We collect the personal data directly from you through your use of the App or our web application that offers the same functionality as the App.

We process your personal data on the basis of GDPR Article 6.1.b, as the processing is necessary for the performance of a contract to which you are a party, under which it has been agreed that we provide digital work tools for you to carry out your duties as a distributor.

We retain the above personal data about you for as long as you have an active employment relationship with us and for five years thereafter for FK’s documentation of your employment.

 

2.7. Special Conditions Regarding Front Page Banner

We process your personal data in connection with the display of the front-page banner in the App. The banner may contain personally relevant messages that are important for your employment—for example, missing salary information. The banner may also include news and announcements that are relevant to you as a distributor.

We process the following personal data about you: IP address, device ID, device platform, device model, device OS, user ID, session ID, app version, employment status, missing submission of personal information including signature of the employment contract and tax card details, preferred language in the App, profile and contact information including address, date of birth, email, name, gender, language preference, and phone number.

We collect the personal data directly from you through your use of the App or our web application, which offers the same functionality as the App.

We process your personal data on the basis of GDPR Article 6.1.b, as the processing is necessary for the performance of a contract to which you are a party, under which it has been agreed that we provide digital work tools for you to carry out your duties as a distributor.

We retain the above personal data about you for as long as you have an active employment relationship with us and for five years thereafter for FK’s documentation of your employment.

 

2.8. Special Conditions Regarding Analysis and Statistics

We process your personal data, including information about your interaction with the App, when you use the App. The processing is carried out in order to optimize, customize, and develop the App and potentially other related products. The processing of your personal data for this purpose is only carried out if you have given your specific consent.

We process the following personal data about you: IP address, device ID, device platform, device model, device OS, user ID, session ID, app version, status of cookie acceptance, and the associated processing of your personal data.

We collect the personal data directly from you via cookie-like technologies.

We process your personal data on the basis of GDPR Article 6.1.a, as the placement of cookie-like technologies, the collection of information about your use of the App, and the associated processing of data for statistical and analytical purposes are based on your consent.

We retain the above personal data about you for two years, after which the data will either be deleted or irreversibly anonymized.

 

2.9. Security and Logging

When you use the App, we log information about your use of the App. This processing is carried out for the purpose of troubleshooting and correcting any crashes or similar technical errors, and is also necessary to maintain an appropriate level of security.

We process the following personal data about you: IP address, device ID, device platform, device model, device OS, user ID, session ID, app version, and your significant actions in the App.

We collect the personal data directly from you.

We process this personal data pursuant to GDPR Article 6.1.c, as we are legally obligated, including under GDPR Article 32, to maintain an appropriate level of security, including ensuring the integrity, availability, and confidentiality of your personal data.

We retain the above-mentioned personal data in application and firewall logs for 13 months.

 

2.10. Support and Disputes

When you contact FK with questions related to the App via email to your distribution manager or via app.support@fk.dk, we process personal data about you for the purpose of handling your inquiry.

We may also process personal data about you in order to handle any disputes that may arise as a result of your use of the App.

We process the following personal data about you: email address and any information contained in your inquiry.

We collect personal data directly from you.

We process the above personal data based on GDPR Article 6.1.f, where FK’s legitimate interest is to respond to your inquiries or, if necessary, to defend or assert a legal claim in connection with a dispute.

As a general rule, we retain personal data related to your inquiry for 30 days from the conclusion of the support case. In the event of a dispute, we may retain your data until the dispute is finally resolved and for five years thereafter for documentation purposes.

 

3. Recipients of Personal Data

We disclose your personal data to third parties when it is necessary to comply with a legal obligation, handle a specific dispute, or where legislation otherwise requires us to do so.

This may include situations such as:

• Reporting to SKAT, Arbejdsmarkedets Erhvervssikring (AES), or other public authorities.
• Handling a specific dispute where it is necessary to document the course of events.

The disclosure is made pursuant to GDPR Article 6.1.c or f, depending on the specific context.

We also use external suppliers (data processors) for technical and administrative operations. These data processors process personal data on our behalf and only in accordance with our instructions under data processing agreements concluded pursuant to GDPR Article 28. This includes, among others, providers of IT operations and support, communication solutions, payroll and HR systems, as well as other system administration. We use, for example, Microsoft (Azure) as a central provider for the operation and hosting of our IT infrastructure.

All data processors are subject to confidentiality obligations and are required to implement appropriate technical and organizational security measures in accordance with applicable data protection legal requirements.

 

4. Transfers to Countries Outside the EU/EEA

As a general rule, your personal data is processed within the EU/EEA. In cases where personal data is transferred to third countries outside the EU/EEA, we ensure that a valid legal basis for the transfer exists and that appropriate safeguards are in place in accordance with Chapter V of the General Data Protection Regulation – typically in the form of the European Commission’s Standard Contractual Clauses, cf. GDPR Article 46.2.c.

As a result of our use of Microsoft Azure, personal data may be transferred to, processed, and stored in the USA or other third countries where Microsoft and its subprocessors operate. Transfers by Microsoft are carried out in accordance with GDPR Article 45 or 46 – either on the basis of an adequacy decision (e.g. the EU-U.S. Data Privacy Framework) or through the use of the European Commission’s Standard Contractual Clauses.

You can read more about Microsoft’s terms here: https://azure.microsoft.com/en-us/support/legal/. You can also request a copy of the relevant transfer mechanism or be informed of where it is available by contacting us using the contact information provided in section 1.

 

5. Your Rights

You have the following rights:

• You have the right to request access to, rectification, or erasure of your personal data.
• You also have the right to restrict the processing of your personal data.
• If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
• You have the right to receive the personal data that you have provided yourself in a structured, commonly used, and machine-readable format (data portability).
• You can always lodge a complaint with a data protection supervisory authority, for example, the Danish Data Protection Agency via dt@datatilsynet.dk.

In addition, you have the right to object to FK’s processing of your personal data in the following situations:

• If FK’s processing is based on GDPR Article 6.1.f, see the legal basis for each processing activity above, you have the right to object at any time on grounds relating to your particular situation.
• You have an unconditional right to object to FK’s processing of your personal data or direct marketing purposes.

You can exercise your rights by contacting FK using the contact details in Section 1.

 

6. Version

FK reserves the right to make changes to this privacy policy. As a general rule, no notice will be given regarding changes to this privacy policy unless the changes are of material significance to you.

Please refer to the table below for information on any changes made to the policy.

Version	Date	Remarks
1.0	March 17, 2025	N/A
2.0	July 8, 2025	Section 2.3 has been changed to 2.4. Section 2.4 has been changed to 2.5. Inserted new section 2.6 on push notifications and the notification inbox. Inserted new section 2.7 on the front-page banner. Section 2.5 has been changed to 2.8. Section 2.6 has been changed to 2.9. Section 2.7 has been changed to 2.10. Section 3 has been adjusted linguistically. Section 4 has been adjusted linguistically.