Privacy Policy

Date of last revision: February 2024


The Graygency takes your privacy seriously and is committed to protecting and respecting it.
We want you to understand how we collect and use information about you.

This privacy notice (“Notice”) contains important information on who we are, on how and why we collect, store, use and share personal data, and on your rights in relation to your personal data.

It is important that you read this Notice, together with any other privacy policy or processing policy that we may provide to you on specific occasions, so that you are fully aware of how and why we use your personal data. This Notice supplements our other notices and policies and does not override them.

This Notice and our website,, are not intended for use by children and we do not knowingly collect personal data in relation to children.

1. Who are we?
We are The Graygency APS (referred to from now as “we” and via similar words, such as “our”). We trade under the name “The Graygency”. We are a company incorporated in Denmark under company number 42431526, and our registered office is at Stationsvej 27, Mørke 8544.

Our day-to-day contact details are set out in section 2 below.

Under data protection law, we are known as a “data controller”. This means we are responsible for the way in which we collect and process your personal data and must meet our legal obligations in relation to it. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters.

2. How can you get in touch?
If you would like to contact us about this Notice, our details are as follows:


The Graygency
Marianne Thomsens Gade 4b

3. Our key data principles
We live by the following principles:

  • We do not collect more personal data than we need
  • When we collect it, we do not use personal data more widely than is necessary
  • We safeguard your personal data.

4. What is “personal data”?
Any information that relates to an identified, or identifiable, living person is personal data.
You are identifiable if it is reasonably likely that your identity could be inferred from that data alone or from that data in combination with other information.

5. When do we collect personal data?
In the course of carrying out our core business, which involves conducting paid social, outsourced e-marketing, and creative campaigns, in each case for businesses, we collect personal data at the following times:

Direct interaction with you. For example, when you:

  • request information
  • engage us to provide services (and communicate with us during the course of our business relationship)
  • attend an event that we hold
  • register to receive emails or newsletters from us
  • take part in competitions or contact us via social media or other means
  • contact us (for example, with a question or to provide feedback)
  • apply for a position with us (and, if you are successful, our use of your personal data in a work context will be governed by our internal privacy policy for staff).

From third parties. For example:

  • if we receive your details from a business from whom you receive e-marketing, so that we can send e-marketing on that client’s behalf
  • from publicly available sources, such as LinkedIn
  • are one of our business partners and we receive information, for example, when you are copied on an email
  • referees whom we approach in respect of any job application.

    From automated technologies. As you use the Website, we collect Technical Data (see definition in section 6 below) about your equipment, browsing actions and patterns. We collect this by using cookies and other similar technologies, subject to receiving your consent for the setting of non-essential cookies. Much of this is not personal data in the legal sense – but, to the extent that it is, we treat it lawfully as such.

    Please see our Cookie Policy for further details. You are able to set your cookies as required.

6. What types of personal data do we collect?
It will depend on circumstances, but the types of personal data we may collect include:

  • Identity Data – such as your name, title, date of birth, and gender
  • Contact Data – such as your email address and mobile number
  • Technical Data – including your internet protocol (IP) address, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website
  • Profile Data – including any feedback and survey responses that you provide, and in some cases biographical information that you provide
  • Usage Data – including information about how you use our Website and services
  • Marketing Data – including your opt-in/opt-out preferences in relation to electronic marketing

Applying for a role
Note that if you apply for a post with us, and provide your CV, we will receive more detailed personal data (if you provide it), including biographical data about institutions you have attended and other posts that you have held.

Aggregated Data
We also collect Aggregated Data, which is large-scale statistical data. We use it for matters such as understanding the percentage of Website users that look at a particular page. Aggregated Data is not personal data, as it will not reveal your identity. However, if we combine Aggregated Data with your personal data, so that you can be identified, we will treat the combined data as personal data and use it in accordance with this Notice.

Special Categories
We do not ordinarily collect any “special categories” of personal data about you (this is the legal term describing details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Note: do you have to provide personal data?
In general, no – although in some situations we may be unable to provide a service if you do not. If we need to collect personal data by law, or to perform a contract with you, and you do not provide it, we may be unable to proceed.

7. How do we use your personal data?
We use your personal data to perform contracts with you, when our legitimate interests allow us to, to comply with the law, and when you consent.

Whenever we use your personal data, we need what is known as a “lawful basis”. These are prescribed by law and are limited in number. Please see the glossary below for more about lawful bases. Sometimes we may have more than one lawful basis for the same processing activity.

The key moments at which we use personal data are as follows:

  • Providing you with service
  • Conducting credit control
  • Communicating with you about this Notice
  • Asking and enabling you to complete a survey
  • Sending marketing emails or SMS
  • Responding to your questions or any complaints
  • Operating, evaluating and improving our business and the Website
  • Protecting against fraud and other criminal activity
  • Complying with our legal obligations (for example, to HMRC and to comply with requests not to send electronic marketing)
  • Participating in legal action
  • Evaluating your job application

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we fairly consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, and are lawfully entitled to do so, we will notify you and explain the new legal basis.

We will make sure we have your consent before sending direct-marketing communications to you via email or SMS on our own behalf.

If we are sending such communications on behalf of a client, it is the client’s responsibility to obtain such consent from you in a lawful way that enables us to act as their processor in sending communications on their behalf.  

You have the right to withdraw consent to e-marketing at any time. This will not affect the lawfulness of marketing that took place prior to the time when we action your withdrawal of consent.

As explained in our Cookies Policy, we will not set non-essential cookies unless we have your consent.

8. How do we share your personal data?
We share your personal data only when necessary and to people in the following categories:

Business partners and suppliers.
Like most businesses, we rely on partners to provide some services, and this may require use of personal data. These include:

  • suppliers and subcontractors who perform certain services and who need personal data for this purpose
  • e-mail and mail service providers
  • technical and support partners, such as the businesses that host our Website and who provide technical support and back-up services
  • professional advisers, such as lawyers, accountants, auditors and insurers, who require such information to provide services to us or for other lawful purposes
  • merger or acquisition partners, to the extent that sharing your personal data is necessary.

Law-enforcement agencies
We may be required to share personal data with a law-enforcement agency (or similar regulatory body) in connection with an investigation.

HM Revenue & Customs
We are required by law to maintain certain data for a period of years to enable proper assessment of taxation and similar matters.

9. How long will your personal data be kept?
We retain your personal data for no longer than is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (and whether we can achieve those purposes through other means), and the applicable legal, regulatory, tax, accounting and other requirements.

10. Marketing
We may store your contact details, and carry out marketing profiling activities, for direct electronic marketing purposes. If you have given your consent, we may contact you about our products or services that may be of interest to you.

If, having opted in, you later prefer not to receive any direct electronic marketing communications from us, you can opt out at any time. We will give you the option to opt out each time we send a marketing communication by electronic means.

Opting out will not affect our ability to use your personal data for the other purposes set out in this Notice, and it will not affect the lawfulness of electronic marketing carried out prior to the time when we actioned your opt-out request.​

11. International transfers
We may transfer your personal data to another location if we consider it reasonably necessary for the purposes set out in this Notice.

Where we do so, we will sure that transfers:

  • are made to countries that have been deemed to provide an adequate level of protection to personal data; or
  • are carried out under approved standard contractual clauses that enable the transfer.

12. Keeping your personal data secure
We have appropriate security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only our authorised employees and contractors, and those referred to in this Notice, have access to your personal data.

All our employees and contractors who have access to your personal data are required to adhere to this Notice and our internal privacy policy, and we have in place contractual safeguards with our third-party data processors to ensure that your personal data is processed only as instructed by us.

We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

13. Your information rights
You have certain rights in relation to your personal data. Please see the “Your Legal Rights” section of the glossary below for more information.

We may first need to verify your identity (and, in certain cases, verify that you have authority to make the request on another person’s behalf).

In general, we try to deal with genuine requests within one month. Occasionally it may take longer, in which case we will let you know in advance.

You do not have to pay a fee to exercise these rights. However, if your request is excessive, repetitive or unfounded, we may charge a reasonable fee or refuse to comply with your request.

14. Cookies
Our Website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy

15. Third-Party links
This Website may include links to websites, plug-ins and applications that are owned by someone other than us. Clicking on those links may allow the owner to collect or share your personal data. We have no control over other sites, are we not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit.

16. Changes to this Notice
We may change this Notice from time to time. Please check this Notice on our Website from time to time to ensure you are aware of the most recent version.​

17. How to complain
In the first instance, we hope you raise any issues with us directly – in almost all situations, matters can be resolved very simply. To do this, please use the details set out in section 2 above.

Should you be unsatisfied, you have a right to raise a concern with the UK’s information regulator, the Information Commissioner’s Office:


Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected (although we may need to verify the accuracy of the new data you provide to us).

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for legal reasons, which will be notified to you, if applicable, at the time.

Object to processing of your personal data where we are relying on a legitimate interest and where this adversely affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to continue to process your information.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy
  • Where our use of the data is unlawful, but you do not want us to erase it
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.