Privacy Policy — KHM Portal

DRAFT — awaiting board approval. This is a translation of the Danish policy, which is the authoritative version. All [...] placeholders are filled in. On approval: set _Last updated_ to the approval date and remove this block.

Last updated: 2026-08-22

1. Data controller

Københavns historiske markeder Maglemosevej 31, 2640 Hedehusene, Denmark CVR (company reg. no.): 37149977 Email: info@khm.dk

Please direct any questions about your personal data here.

2. What information we process

When you are registered as a user (volunteer, actor or administrator) we process:

  • Identity: name, any nickname/actor name, date of birth
  • Contact: email address, phone number, postal address
  • Identification: uploaded ID document, where your role requires it
  • Account: role and permissions, login (Passkeys, Google login, magic email link), language preference
  • Activity: notifications and an audit log of actions in the system
  • Health and dietary information (special categories): information about health considerations, allergies and special diets that you voluntarily provide so we can adapt tasks, catering and accommodation to you. This is processed solely on the basis of your separate, explicit consent (see the dedicated consent declaration), stored encrypted, accessible only to volunteer coordinators, and deleted on withdrawal or when the consent expires (13 months).

Sensitive fields (name, email, phone, ID, health information) are stored encrypted.

When you apply as a volunteer

You can submit an application without having a user account. We then process:

  • Contact: first name, last name, email address and phone number
  • Date of birth: the full date, that is day, month and year
  • Your participation: which days you are available, your team preferences, whether and how you want to sleep over, and your t-shirt size
  • Qualifications: trailer or truck driving licence, food hygiene certificate and first aid certificate with expiry date, and your own text about previous experience
  • Language: the language you read the form in

We ask for the full date of birth for three reasons: you must have turned 15 when the market starts, the association must be able to report the age distribution of participants when applying for municipal grants, and we want to be able to send you a birthday greeting.

Contact details and your text about previous experience are stored encrypted.

When you apply as an actor

You can submit an application without having a user account. We then process:

  • Contact: name, email address, phone number, and if you provide them: company registration number and links to your website or social media
  • About the stall and camp: group name, period, stall type, what you sell or make, dimensions of stall and camp, number of people, the drawing of your camp, information about open fire and gas, and your own comments
  • Photos: the pictures of stall and camp you attach yourself

Contact details are stored encrypted. Photos are re-encoded on receipt, which removes EXIF data — including GPS position.

3. Purposes and legal basis

  • Administering your participation as a volunteer/actor — Contract / legitimate interest, art. 6(1)(b)/(f)
  • Checking that you meet the minimum age for volunteers — Contract / legitimate interest, art. 6(1)(b)/(f)
  • Reporting the age distribution of participants when the association applies for municipal grants — Legal obligation / legitimate interest, art. 6(1)(c)/(f)
  • Sending you a birthday greeting — Legitimate interest, art. 6(1)(f)
  • Sending you essential operational messages (shifts, critical notices) — Legitimate interest, art. 6(1)(f)
  • Login and account security — Contract, art. 6(1)(b)
  • Audit log for security purposes — Legal obligation / legitimate interest, art. 6(1)(c)/(f)
  • Measuring how the mobile network performs in the field app, so the association can size its infrastructure — Legitimate interest, art. 6(1)(f)
  • Adapting tasks and catering to your health/allergies — explicit consent, art. 9(2)(a) (+ art. 6(1)(a))
  • Processing your actor application and preparing a contract — Steps prior to a contract, art. 6(1)(b)
  • Showing your stall on our website — consent, art. 6(1)(a)
  • Sharing your stall on social media — consent, art. 6(1)(a)

The last two are optional. If you say no, we process your application in exactly the same way, and you may withdraw the consent at any time.

You may object to the birthday greeting, see section 7.

Health information is processed exclusively on the basis of your explicit consent. You may withdraw consent at any time without consequence for your participation otherwise; we then delete the information.

4. Cookies and storage on your device

The portal sets one necessary cookie to keep you logged in. It is strictly necessary for the site to function and does not require consent. We use no analytics, marketing or third-party tracking cookies.

Measuring the mobile network in the field app

The field app (Ravenhub) measures how the mobile network behaves while you use it: how long a request takes, whether it fails, and how long an action sat waiting because the device was offline. Each measurement carries a coarse indication of which part of the app you were using — for example catering or tokens — never the exact address and never the content of the request.

The measurements contain no names, email addresses or IP addresses. They do, however, store a pseudonymous device reference in your browser's storage, so measurements from the same phone can be kept together. The reference is replaced at every market. Combined with the shift plan it can point to a person, and we therefore treat it as personal data. The measurements are also queued in your browser's storage and only sent once the connection works again — the queue is necessary precisely because it is the poor connections we are investigating.

The legal basis is the association's legitimate interest, art. 6(1)(f) in being able to decide whether a server has to stand on site during the market, or whether a better connection is enough. We have weighed this against your privacy: the measurements are technical, they contain no names, the reference is replaced every year, and they are not used to assess your work. Nor is there a less intrusive way to get the answer — a measurement taken with equipment other than the phones actually in use would measure something else. We therefore consider the interference small and proportionate to the purpose.

The measurements are kept for 24 months and then deleted automatically.

You can opt out of the measurement under "My page" — in the field app as well as in the portal. Opting out stops the collection immediately and discards the measurements still held on your device. It has no bearing on your work in the app. Measurements already sent remain until the 24 months have passed.

5. Recipients and processors

We do not disclose your information to others, but use data processors for operations:

  • Hosting: Hetzner Online GmbH (servers in the EU)
  • Email delivery and the association's mailboxes: Google Ireland Limited (Google Workspace)
  • Login: Google Ireland Limited (only when using Google login)

A data processing agreement is in place with each of them.

Google may process information outside the EU/EEA as part of its operations. The transfer relies on the European Commission's standard contractual clauses and on Google's participation in the EU-US Data Privacy Framework.

6. Retention

We retain your information for as long as you are an active participant. After that, a separate period applies per type of information. The periods are listed below.

Actor applications: contact details, your comments and your photos are removed 13 months after the end date of the market. Group name, stall type, dimensions, number of people and the outcome remain, so the association can see how many applied and how many were turned down. If your application is approved, the contact details move to your user account immediately, and the application remains without them.

Volunteer applications: name, contact details, date of birth, qualifications, team preferences, your available days and your text about previous experience are removed 13 months after the end date of the market. Market, status and timestamps remain, so the association can see how many applied and how many were turned down. If you are approved, the details move to your user account immediately, and the application remains without them.

Your user account: name, contact details and address are removed 2 years after the account is archived. Your participation history remains without them, so the association can see how many took part and when.

Actors (the company record): the bank account number and other personal data on the actor record are removed 5 years after the most recent market you left a trace in. The period follows the retention duty in the Danish Bookkeeping Act. Company name, CVR number and website remain — that is company data, not personal data. If your membership of the actor is still active, the record stays unchanged regardless of age.

Health information, allergies and special diets: deleted when you withdraw your consent, and otherwise 13 months after the end date of the market.

Notifications and messages to you are deleted after 1 year.

Weather data used for safety alerts is deleted after 30 days. It contains no information about you.

Field measurements: the technical measurements from the field app are kept for 24 months from the time of measurement and are then deleted automatically.

The audit log is retained for 2 years for security purposes. It records who did what and when, but contains neither personal data nor access tokens — only references to the rows an action touched.

7. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection. You may withdraw a consent. Contact info@khm.dk. You may lodge a complaint with the Danish Data Protection Agency, Datatilsynet (datatilsynet.dk).

8. Security

Sensitive information is stored encrypted, access is role-controlled, and actions are logged. Data is hosted in the EU.