The purpose of our Privacy Policy is to give you knowledge of how we process information about you. We are highly focused on processing any personal data with care, trust, and respect.

1. Data Controller and Contact Details

This website is operated and owned by:
LEGO Fonden
Koldingvej 2
7190 Billund
CVR-nr.: 12458339
e-mail: LEGOfoundation@lego.com

2. Our General Principles of Data Processing

To ensure that your data is processed correctly, we have adopted the following principles.

We will always inform you of the processing and its purpose, unless (and only in specific circumstances) we have a legitimate basis for not to do so. By "processing", we mean our collection, use, disclosure, storage and eventually deletion of your data.

We only collect and process your personal data if we have a legal basis for the processing under applicable laws, e.g.:

We have your permission (your consent)
It is necessary to perform an agreement with you
We are under legal obligation to do so
If the processing is necessary in order for us to pursue a legitimate interest, i.e. the administration of LEGO Fonden and the pursuit of the goals of LEGO Fonden

We only process your personal information for the original purposes or for the other purposes that are not incompatible with the original purpose.

For special categories of personal data, we may process your personal data, if it is necessary for the establishment, exercise or defense of legal claims, including exploiting a license obtained from you.

We strive to verify and update your personal information on a regular basis.

We might supplement your personal information with information from other sources to ensure that your data is correct and up to date.

We use high technical standards to protect your personal information.

We do not store your personal data longer than necessary to serve the purpose for which the personal information was collected and further processed.

3. Collection of Personal Data

You will always be informed if we collect personal information about you. The personal information collected by us may include, for instance, your name, email address, home address, phone number and similar identification data, including information about your navigation on the website.

We also collect your personal data when you interact with us on our various programmes and websites. When you take part of testing of products or concepts, we may process personal information about you, including special categories of personal information such as information concerning health. Here we will present you with specific terms telling you which specific information that might be collected and for which purpose.

In general, we typically process the following categories of personal data:

Contact details when you contact us via email or phone.
Information, posts etc. you provide in public fora on our websites and programmes.
Information you provide when you use our websites and programmes, our programmes on third party websites or third-party platforms such as social media and networks.

4. The Purpose and Legal Basis for the Processing

We process your personal information for the following purposes and on the basis of the following legal bases.

To reply to your inquiries, applications for donations, etc. We will use your personal information to be able to act on your inquiries, applications etc. The personal data is being processed on the basis of article 6(1)(f) (Necessary for the pursuit of LEGO Fonden’s legitimate interests). Our legitimate interest is to be able to respond to your inquiries, applications etc.
Administration of your activities: We will use your personal data to administer your activities with LEGO Fonden, including in our programmes, on the Website, and your participation in public foras. The personal data is being processed on the basis of article 6(1)(f) (Necessary for the pursuit of LEGO Fonden’s legitimate interests). Our legitimate interest is to be able to administrate your activities.
Improve the website experience: We will use your personal data regarding your activities on our websites to improve the structure of the Website. Such processing will be done on the basis of article 6(1)(f) (Necessary for the pursuit of LEGO Fonden’s legitimate interests). Our legitimate interest is to improve the structure of the Website in order to give you the best possible experience on the Website. Regarding our use of cookies, please see below in Clause 10.
When and if you participate in testing of our products: We may process both special and non-special categories of personal data about you when and if you participate in testing of our products. We will collect this information for the purpose of improving our knowledge, concepts and for marketing of LEGO Fonden at conferences, events, LEGO Fonden’s websites and on social media. Such processing will be done on the basis of article 6(1)(b) (agreement), article 6(1)(a) or art. 9(1)(a) (consent), article 6(1)(f) (necessary for the pursuit of LEGO Fonden’s legitimate interests to be able to administer tests within LEGO Fonden) and/or article 9(1)(f) (establishment, enforcement or defence of legal claims). We will provide you with more information about the specific processing, when this information is collected.
The personal data may also be used for educational and research purposes or other activities within our projects, programmes and other initiatives supporting creativity and learning through play. We may process both special and non-special categories of personal data about you when and if you participate in activities within our different programmes, studies, research projects, conferences and other events. We will collect this information for the purpose of supporting our work to support and communicate the value and importance of creativity, learning through play and the LEGO Idea and the value of play and the impact of learnings through play on children’s development and lifelong learning. Such processing will be done on the basis of article 6(1)(b) (agreement), article 6(1)(a) or 9(1)(a) (consent), article 6(1)(f) (necessary for the pursuit of LEGO Fonden’s legitimate interests to be able to collect information of, communicate and provide evidence for the importance and impact of creativity, learning through play and the LEGO Idea and transforming evidence into experiences) and/or article 9(1)(f) (establishment, enforcement or defence of legal claims). We will provide you with more information about the specific processing, when this information is collected.

Remember that when you provide personal data to us on third-party websites or platforms (e.g. via our programmes or via social media), the personal data, you provide, may be processed individually by the third-party websites or by the owner of the platform. The personal data we process is comprised by this Privacy Policy, whereas the personal data the third-party website or platform process is subject to the personal data principles of that third-party website or platform. The choice you have made in relation to confidentiality on the third-party website or platform does not apply to our use of personal data that we have processed directly via our websites, channels or programmes.

We process your personal data via special technology, e.g. cookies when you visit our websites, channels or programmes via third party websites or platforms.

View our Cookie Policy for further information cf. item 10.

5. Sources of Your Personal Information

We generally process personal information that is collected directly from you or from the device you are using, but we also receive your personal information via our partners in our programmes, studies research projects etc.

6. Recipients

We may share your personal information with:

Suppliers and vendors that We work with to assist Us, such as service providers, technical support, supply services and financial institutions.
LEGO Fonden group entities and the LEGO Group entities.
Public authorities, to the extent we are legally required to do so.

Furthermore, due to the collaborative nature of social medias, data that you post and other User Content, may be accessible by other users of the LEGO Fonden websites and social media channels from around the world.

7. Data transfers, Storage and Processing Globally

LEGO Foundation transfers, stores and processes your information (including your personal information and content) both inside and outside of Denmark. We operate globally and may transfer your personal information to third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal information is transferred, stored or processed by us or by companies carrying out such services on our behalf, we will take reasonable steps to safeguard the privacy of your personal information.

In some cases, We will be transferring your personal data to countries outside the EU/EEA. We may among others transfer personal data to Ukraine, USA, South Africa and Mexico.

Such transfers will take place on the basis of the following legal bases:

a) The countries have been deemed by the Commission of the European Union to have an adequate level of protection of personal data.

b) If the countries have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data, we will provide appropriate safeguards for the transfer:

by transferring to companies, which are EU-US Privacy Shield certified.
through the use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities.

8. Data Retention

We will retain your personal data for the period necessary to fulfill the purposes listed above. However, the data may be processed and stored for a longer period in anonymised form or may be retained for a longer period of time if we are legally required to do so.

9. Your Rights

You have the following rights:

You have the right to request access to and rectification or erasure of your personal data.
You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
You have the right to receive the personal data that is being processed in a structured, commonly used and machine-readable format (data portability).
If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent. You may withdraw your consent by contacting us by email.
Finally, you may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency, Borgergade 28, 5., DK-1300 Copenhagen.

Be aware that there may be conditions or limitations on these rights. It is therefore not certain for example that you have the right of data portability in the specific case - this depends on the specific circumstances of the processing activity.

You may exercise your rights by visiting the settings for your account or by contacting us at LEGOfoundation@lego.com. If you contact us at LEGOfoundation@lego.com we will have to verify your identity for security purposes.

If you have questions regarding the specific personal information about you that we process or retain, please contact LEGO Foundation at LEGOfoundation@lego.com.

10. Cookies

We use cookies on our website. You can read more about the use of cookies in our Cookie Policy which you can find on the following link.

11. Changes to this Privacy Policy

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. This updated and valid Privacy Policy may be viewed here: https://www.legofoundation.com/en/about-us/privacy-policy/

12. Links to other websites, etc.
Our website may contain links to other websites or to integrated sites. We are not responsible for the contents of the websites of other companies or for the practices of such companies regarding the collection of personal data. When you visit other websites, you should read the owners' policies on the protection of personal data and other relevant policies.

13. Contact details
If you have a request, comment or a question about this Privacy Policy, please contact our Administration officer:

LEGO Fonden
Att.: Tina Bache
Koldingvej 2
7190 Billund
Denmark
Email: LEGOfoundation@lego.com

This Privacy Policy was last updated on 02. January 2019