Privacy policy

Group 8

Data protection and confidentiality are important to KIRKBI Invest A/S (“we”, “us”, or “our”). This Privacy Policy sets out clear guidelines for KIRKBI Invest A/S’ processing of your personal data when you visit our website, https://www.travbyen.dk/, or in other ways interact with us via the website regarding Travbyen in Billund. 

1. Data controller
KIRKBI Invest A/S is data controller for the processing of your personal data. You can find our contact information below:

KIRKBI Invest A/S
Koldingvej 2
DK-7190 Billund
CVR No. 31159830
Phone: +45 75 33 88 33
E-mail: kontakt@travbyen.dk

2. Purpose, legal basis, and types of personal data
Below we have listed for which purposes we process your personal data when you interact with us regarding Travbyen in Billund.

  1. To reply to your inquiries
    If you contact us via the contact information on the website or in other ways, we will use your personal data to be able to respond to your inquiry. We typically process the following personal data about you: name, email, phone number and the topic of your inquiry.

    We use art. 6(1)(f) in the GDPR (the rule on balancing of legitimate interests) as our legal basis. Our legitimate interest is to be able to respond to your inquiry and communicate with you.

    We collect the personal data directly from you and we will keep your personal data only for the period necessary to fulfil the purposes listed above and e.g., for documentation, depending on specific request.

  2. Pictures, video clips etc. from events
    In connections with events regarding Travbyen we will sometimes take mood pictures, video clips or similar (hereinafter the “Recordings”) of the activities. In this connection, we may process your personal data (your picture). 

    We use the Recordings internally to be able to communicate about Travbyen, and for internal evaluation. In addition, we use the Recordings for external communication about Travbyen, including in presentations, reports, and other external material and on the website for Travbyen where we may use some of the pictures to communicate about the development of Travbyen and the citizen involvement in the development of the area. We do not use the pictures for marketing. 

    We use the rule on balancing of legitimate interest in Article 6(1)(f) of the General Data Protection Regulation as our legal basis for this processing. Our legitimate interest is to be able to document project Travbyen, the ctizen involvement and to be able to communicate about the development of Travbyen, as described above. 

    We store the pictures for as long as necessary for the above purposes. When we no longer need to process them for the fulfillment of one or more of the purposes listed above, the personal data will be deleted.

  3. To process proposals for activities or development of the area
    If you submit proposals for activities or development of the area, either via the contact form, the contact information on the website or in other ways, we will use your personal data to be able to respond to your inquiry or assess your proposal. We may also contact you in this connection to find out more about your proposal or further dialogue to include any proposals in the development of the area.

    We typically process the following personal data about you: name, email, phone number and the content of your proposal.

    We use art. 6(1)(f) in the GDPR (the rule on balancing of legitimate interests) as our legal basis. Our legitimate interest is to be able to assess your proposal and communicate with you regarding your proposal to find out more about your proposal or further dialogue to include any proposals in the development of the area.

    We collect the personal data directly from you and we will keep your personal data only for the period necessary to fulfil the purposes listed above and e.g., for documentation, depending on the specific proposal.

  4. Use of our website
    We use cookies on the website. You can read more in our cookie policy

  5. Events and workshops, etc.
    If you register for one of our events, workshops, etc., we will process your personal data to manage your registration and communicate with you throughout the event. To manage event registrations, we only process ordinary personal data about you, including your name, email, phone number, age, job title, workplace, which event/workshop you wish to attend, and language preferences.

    We use Article 6(1)(a) of the General Data Protection Regulation as the legal basis if your consent is required for participation in the relevant workshop. We may also use Article 6(1)(b) of the GDPR as the legal basis when you register for an event, as the information is necessary to fulfill the agreement with you regarding your participation, and we may rely on the legitimate interest basis under Article 6(1)(f) of the GDPR as the basis for processing, where the legitimate interest is to manage the events and subsequently send out evaluation forms, etc.

    We normally collect the personal data directly from you, but we may also receive it from another party registering on your behalf, for example, your employer.

    We retain your personal data for as long as necessary to complete the relevant event and to conduct evaluations. If an event is part of a series of related events, we retain your personal data until the entire series is completed and evaluated.

  6. Newsletter
    We process your personal data for the purpose of direct marketing of Travbyen, including updates on construction, background articles, and invitations to events and activities.

    We process your normal personal data for direct marketing based on our legitimate interest in marketing Travbyen and the activities organized in Travbyen pursuant to Article 6(1)(f) of the GDPR. We send marketing material via email based on your active prior consent in accordance with Section 10(1) of the Danish Marketing Act.

    The information we process about you includes your name, email address, and consent declaration, as well as your interaction with the newsletter.

    We process the information you provided when you subscribed to the newsletter and your interactions with the newsletter.

    Your personal data will be deleted when the marketing consent is withdrawn or if we do not use the consent within a period of 1 year. However, the consent declaration itself will be retained for 2 years after the withdrawal of consent or after the consent has expired.

    Once the marketing consent is withdrawn, we will no longer process your personal data for the purpose of sending newsletters or for any other marketing.

    You may withdraw any consents you have given at any time. If you no longer wish to receive newsletters from KIRKBI Invest A/S, you can always click "Unsubscribe newsletter" at the bottom of the newsletter.

    If you withdraw your consent, this does not affect the lawfulness of our processing of your personal data prior to the withdrawal.

  7. sign-up list
    If you choose to sign up for sign-up list, we process the personal data necessary to contact you regarding future residences or rental properties that may be of interest to you.

    When you sign up for our sign-up list, we register the following personal data about you: name, email address, age range, postal code, and which types of residences/rentals may be of interest to you.

    We use Article 6(1)(b) of the GDPR as the legal basis, as the processing of your personal data is necessary to fulfill the agreement with you regarding being added to the sign-up list and to communicate with you in this regard.

    We collect the personal data directly from you, and we retain it for as long as you wish to remain on the list. We will contact you by email every 3 years regarding your continued interest. It is therefore important that you inform us if your contact details change. If we do not hear from you within 6 months after the deadline for responding regarding your continued interest, we will delete your personal data. Your personal data will also be deleted if you notify us that you no longer wish to be on the list.

    We process the information you provided when signing up for the sign-up list and your interactions with us in this regard.

    You may contact us at any time if you no longer wish to be registered on the sign-up list.

3. Recipients
In order to fulfil the above purposes, we may disclose your personal data to third parties, who on a contractual basis with KIRKBI Invest A/S, deliver relevant services, e.g., IT services. Such disclosure is subject to data processing agreements, and the data processor may not use the data for other purposes than to perform the processing on our behalf.

In general, your personal data is not disclosed to other data controllers without your consent, unless we are legally required to do so.

4. Processing of personal data outside the EU/EEA
KIRKBI Invest A/S transfers, stores, and processes your data (including personal data and content) both inside and outside Denmark. Wherever in the world your personal data is transferred, stored, or processed by us or by companies carrying out such services on our behalf, we will take reasonable steps to ensure that your personal data is adequately protected in accordance with applicable data protection laws.

If your person al data is transferred to countries outside the EU/EEA, such a transfer will be made on the following legal basis:

  • Binding Corporate Rules

  • The country has been approved by the European Commission as having an adequate level of security or the recipient are certified under e.g. the EU-U.S. Data Privacy Framework

  • If the country is not approved by the European Commission as having an adequate level of security, we will transfer the data by use of "Model Contracts for the Transfer of Personal Data to Third Countries" (Standard Contractual Clauses), as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities

  • By declaration of consent from the involved data subjects. 

5. Security
We have high standards for security, including when it comes to the protection of your personal data. We, therefore, have internal procedures and policies in place to ensure that we live up to our high standards and thereby comply with the requirements of implementing appropriate technical and organisational measures. Thus, we do our best to safeguard the quality and integrity of your personal data.

6. Retention of personal data
We will retain your personal data for the period necessary to fulfil the purposes listed in Section 2. Data may be processed and stored for a longer period in anonymized form or if we are legally required to do so.

7. Your rights
In accordance with the General Data Protection Regulation and the Danish Data Protection Act, you have certain rights.

  • You have the right to request access to and rectification or erasure of your personal data;

  • You have the right to object to the processing of your personal data and have the processing of your personal data restricted;

  • 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).


Please note that there may be conditions to or limitations of these rights. It is, therefore, not certain that you e.g., always have the right of data portability - this depends on the specific circumstances of the processing activity.

You can exercise your rights by contacting us (see below). If you contact us by email, we will have to verify your identity for security purposes.

If you disagree with the way, we process your personal data or the purposes we process the data for, you are welcome to contact us. You can also file a complaint with:

The Danish Data Protection Agency
Carl Jacobsens Vej 35
DK-2500 Valby
T: +45 33 19 32 00
E: dt@datatilsynet.dk

8. Changes to this Privacy Policy
We reserve the right to change this Privacy Policy to accommodate material changes in legislation, new technologies, new and improved functions or to improve our website.

Contact information
Send a mail to kontakt@travbyen.dk – with “Privacy Policy” in the subject line if you would like us to change or delete your personal data or if you have any questions related to this Privacy Policy.

This Privacy Policy was updated July 2025