Date: 25 May 2018


Average Adjuster Vibeke Kofoed takes the protection of your personal data seriously. This privacy note describes what data and how it is collected and processed as well as your rights in respect of your personal data. Average Adjuster Vibeke Kofoed is bound by the EU General Data Protection Regulation 2016/679 (“GDPR”).


The terms personal data, controller, processor, data subject, third party, processing and profiling have the same meanings given to them in the GDPR.


1 Controller

Average Adjuster Vibeke Kofoed. 
Business ID: 38061178. 
Amaliegade 33 B, 1256 Copenhagen K, Denmark


2 Name of the Register

Average Adjuster Vibeke Kofoed (“Company”)


3 What Data is Collected

Personal data is any information with which one can directly or indirectly, identify a physical person (“Personal Data”). The Personal Data the Company collects or may already be in possession of due to an on-going client-relation, is data such as name, e-mail address, telephone number, street address, title and association with the client entity, personal identification number (where appropriate), banking details, insurance details, etc.


The Company may also have Personal Data on third persons due to the documentation it has been provided by the client related to any on-going assignment or work. This could be e.g. names and nationality of crewmembers, employees, board members, suppliers, contractors, co-operation partners, their lawyers and advisors.


4 How the Data is Collected

Personal Data is primarily collected directly from the data subject when managing client assignments and providing legal services. Furthermore, Personal Data is collected through the know-your-client processes and by conducting conflict of interest researches or when been provided by the clients in connection with assignments and case handling. We also collect Personal Data when we manage our marketing.


5 Purpose of Processing of the Personal Data

The purpose for processing the Personal Data is the relationship between the Company and its clients (“Legitimate Interest”). This includes, e.g., identifying the client including know-your-client processes, checking for conflicts of interest, handling of the assignments and claims, issuing Statements and Opinions, legal consultation, drafting of contracts and insurance conditions, registering of companies and property, managing client relationships, marketing, identifying information about the private clients, company representatives and its beneficial owners.


6 Where is Personal Data Stored

Processing and storing of Personal Data takes place on servers located within the EU/EEA. However, sometimes it may be necessary to transfer your Personal Data from a location within the EU/EEA to a third country e.g. in connection with obtaining local specialist advice related to an assignment or project. In such a case we shall inform you accordingly. With regard to transfers of Personal Data to countries where the local data protection legislation does not provide an adequate level of data protection, appropriate safeguards under GDPR are implemented to ensure that your Personal Data remains protected and secure. Any international transfers of Personal Data will be based on the standard contractual clauses approved by the European Commission.


7  RetentionTime of Personal Data

The Company retains the clients’ Personal Data up to five years after the Legitimate Interest between the data subject and the Company is considered to have ended. The validity of this Legitimate Interest is determined by, for example, communications between the Company and the data subject.


Personal Data may be stored for a longer time as stated above in order to comply with the legislation including obligations related to money laundering, accounting, audits and tax.


Related Personal Data will be deleted if the data subject withdraws his/her consent or objects to the processing of the Personal Data for direct marketing purposes.


Upon the expiry of the time limit as stated above your Personal Data will be destroyed in a secure way or irrevocably anonymized.


8  Protection of the Personal Data

Any physical material is stored in a locked space to which only the Controller or people with particular rights have access.
Digital material can only be accessed by the Controller and its employees and/or contractors as may be assigned from time to time and specifically entitled to do so with a personal user ID and password.


9 The Data Subject’s Rights

You may be entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Requests should be submitted by using the contact details set out below.


If you are aware of changes or inaccuracies in your Personal Data, you should inform the Company of such changes so that its records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that Company’s processing of your Personal Data infringes the applicable law.


The supervisory authority is Datatilsynet, Borgergade 28, 5. Floor, DK- 1300 Copenhagen K.


Contact person for register enquiries:

Average Adjuster, LL.M., Mediator Vibeke Kofoed

Telephone +45 28968498



10 Amendments

The terms of this Privacy Note may be amended from time to time and they will be applicable upon uploading of the same to the Company’s website.