Privacy Policy & GDPR

Effective from 17 May 2026. Last updated 17 May 2026.

1. Data controller

The data controller for processing of personal data on this microsite is:

  • Particulair (sole proprietorship)
  • Højtoften 12, 2690 Karlslunde, Denmark
  • VAT/CVR no. 34129894
  • Privacy/GDPR contact: gdpr@particulair.com

Particulair has no statutory Data Protection Officer (DPO). Thomas Lyngskjøld personally handles data-protection enquiries.

2. Categories of personal data we process

We process the following categories of personal data about visitors to the VACE microsite:

  • Data from the contact form and email enquiries: name, company, email address, phone number (optional), environment type (optional), and the contents of your message.
  • Statistics via Google Analytics 4: an anonymous client pseudo-identifier (user_pseudo_id), truncated IP address, browser and device type, language, referring URL, pages visited, timestamps, and approximate location at city/region level.
  • Google Ads conversion data: click identifier (_gcl_au) and the defined conversion events (email-link click, phone-link click, contact-page view).
  • Google Consent Mode v2 pings: when you have not given consent, Google Tag Manager sends anonymous, cookieless pings without a persistent identifier. Google uses these for aggregated modelling; they contain no identifiable personal data.
  • Weply chat: if you open the chat widget and write messages, Weply A/S processes the conversation on our behalf. The chat widget only loads after you give marketing consent.

We do not process special categories of personal data (GDPR article 9), data about criminal convictions (article 10), or payment/accounting data from this site.

3. Purposes and legal bases

Each processing activity has an explicit purpose and an explicit legal basis:

  • Contact form and email enquiries. Purpose: to answer your enquiry, send quotes and serve you as a potential or existing customer of vacuum accessories for ATEX/ESD and food/pharma environments. Legal basis: GDPR article 6(1)(f) (legitimate interest). Our legitimate interest is to be able to answer a B2B professional who has reached out to us. See section 10 for our written Legitimate Interest Assessment (LIA).
  • Google Analytics 4 (statistics). Purpose: to understand how visitors use the site and improve the content. Legal basis: GDPR article 6(1)(a) (consent), obtained via our cookie banner (Statistics category).
  • Google Ads conversion tracking and remarketing. Purpose: to measure the effect of our advertising and optimise campaigns. Legal basis: GDPR article 6(1)(a) (consent), obtained via cookie banner (Marketing category). For a small portion of the processing Particulair is joint controller with Google, see section 5.
  • Weply chat (marketing). Purpose: to let you chat directly with us from the site. Legal basis: GDPR article 6(1)(a) (consent, Marketing category). The content of the chat itself is processed on the basis of article 6(1)(f) (legitimate interest) on the same footing as the contact form.
  • Consent Mode v2 pings and the consent cookie. Purpose: to record and respect your cookie choice and meet our documentation obligations. Legal basis: GDPR article 6(1)(c) (legal obligation, in conjunction with the Danish cookie order) for the consent cookie itself, which is technically necessary and therefore exempt from the consent requirement.

4. Recipients and data processors

We do not disclose your personal data to third parties beyond the data processors and joint controllers needed to operate the site. The following parties process personal data on our behalf:

  • Complitia.eu (VAT 43505130, Denmark) is the data processor for setting up and operating Google Tag Manager, Google Analytics 4, Google Ads and Google Consent Mode v2 on our behalf. The processing is governed by a written data processing agreement following the Danish DPA standard clauses, cf. GDPR article 28.
  • Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) is the contracting party for Google Analytics 4, Google Tag Manager and Google Ads in the EU/EEA. Google Ireland acts as a sub-processor for Particulair via Complitia.eu.
  • Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) is a sub-processor for the technical operation of the Google platforms. Transfers to the USA occur under the EU-U.S. Data Privacy Framework, see section 6.
  • Infomaniak Network SA (25 Eugène-Marziano, 1227 Les Acacias, Switzerland) is the data processor for hosting and email. Switzerland is recognised by the European Commission under an adequacy decision, and data does not leave Swiss territory under normal operations.
  • Weply A/S (Denmark) is the data processor for chat conversations you start via the chat widget. Data is stored in Denmark and the EU.

5. Joint controllership for Google Ads conversion data

When you click one of our Google ads and subsequently trigger a conversion event on the site (email-link click, phone-link click, contact-page view), the conversion signal itself is processed jointly by Particulair and Google Ireland Limited. Each party has its own defined purpose: Particulair wants to measure the effect of advertising, and Google operates its advertising platform and serves other advertisers.

For this specific portion of the processing there is therefore joint controllership under GDPR article 26. The internal split of responsibility follows Google's Controller-Controller Data Protection Terms, which Particulair has accepted via the Google Ads admin interface. Headline points:

  • Particulair is responsible for having a valid legal basis (your consent in the Marketing category) for sending conversion signals to Google.
  • Google Ireland is responsible for its own subsequent processing of the signal, including any Google-internal purposes.
  • Both parties must respond to requests from data subjects. You can always send your request to Particulair at gdpr@particulair.com, and we forward or coordinate as needed.
  • You can withdraw your marketing consent at any time, and conversion tracking will then cease for your future visits.

The remaining processing in the Google stack (GTM, GA4 statistics, internal operations) is ordinary processing under article 28 and is covered in section 4.

6. International transfers

Some of the personal data we process is transferred to the USA via Google LLC's operation of Google Tag Manager, Google Analytics 4, Google Ads and Google Consent Mode v2. The transfer takes place under the EU-U.S. Data Privacy Framework (DPF), which the European Commission adopted on 10 July 2023 (implementing decision 2023/1795). Google LLC is actively certified under the DPF, and we verify the certification at least quarterly at dataprivacyframework.gov.

The EU General Court upheld the DPF on 3 September 2025 in case T-553/23. That decision is currently under appeal at the Court of Justice of the EU, and an eventual ruling may affect the adequacy basis. Should the DPF be invalidated, we will pause or migrate the processing to an EU-based alternative without delay.

Hosting at Infomaniak in Switzerland is covered by the European Commission's own adequacy decision for Switzerland and does not require additional transfer safeguards. You can always request a copy of the relevant basis by writing to gdpr@particulair.com.

7. Retention

We do not keep personal data longer than necessary. The following periods apply per data category:

  • Contact form and email correspondence: until the matter is concluded plus 1 year, after which the material is deleted. Accounting records that may contain personal data are kept for 5 years pursuant to the Danish Bookkeeping Act.
  • Google Analytics 4 event data: 14 months, after which client-level data is automatically deleted at Google. Aggregated report data remains available.
  • Google Ads conversion data: 13 months at Google for client-level data.
  • Weply chat logs: according to our data processing agreement with Weply A/S and Weply's own deletion procedure.
  • Consent Mode v2 pings: contain no persistent identifiers and are therefore not in scope for individual retention.
  • The consent cookie particulair-consent: 12 months from last update, after which the banner is shown again and you can re-decide.

8. Your rights

You have the following rights under GDPR articles 15-21:

  • Access to the personal data we process about you (article 15).
  • Rectification of inaccurate or incomplete data (article 16).
  • Erasure of your data under certain conditions (article 17).
  • Restriction of processing (article 18).
  • Data portability for data processed on the basis of consent or contract (article 20).
  • Objection to processing based on legitimate interest (article 21).

You can exercise your rights by writing to gdpr@particulair.com. We respond within one month of receipt and may extend the deadline by a further two months in complex cases.

An important practical limitation. Our statistics and ads data from Google Analytics 4 and Google Ads are tied to a pseudonymous client identifier (user_pseudo_id) or a click identifier (_gcl_au). We cannot easily link these identifiers to you as a named person. To perform access, erasure or portability on your tracking data specifically, we need you to tell us your GA4 client_id or to give us other concrete reference points. You can always end the processing for your future visits by withdrawing your consent (see "Withdraw consent" in our cookie policy) and clearing your cookies.

9. Hosting and security

The site is hosted at Infomaniak Network SA with servers in Switzerland and within the EU. Infomaniak is ISO 27001 certified, and the hosting environment uses TLS-encrypted data transmission, encrypted storage and logical separation between customers. The infrastructure runs on 100% renewable energy, and the Geneva-region data centre reuses server waste heat for district heating. We take regular backups of site content and email data via Infomaniak's own mechanisms.

Access to our systems is limited to people with a concrete work-related need and goes through individual logins with multi-factor authentication.

10. Legitimate interest (LIA) for the contact form

For the processing we perform under GDPR article 6(1)(f) (contact form and subsequent dialogue), we have carried out a written Legitimate Interest Assessment based on EDPB Guidelines 1/2024 and the CJEU ruling in case C-621/22 (4 October 2024).

  • Our interest. We have a real and present commercial interest in being able to answer professional enquiries from B2B visitors who have reached out to us about vacuum accessories for ATEX/ESD and food/pharma environments.
  • Necessity. To answer the enquiry, we need to process the data you have provided (name, company, email, optional phone and environment type, and the message itself). Less intrusive alternatives do not exist for conducting the dialogue itself.
  • Balancing of interests. You have initiated the contact yourself and know the purpose. The dataset is minimised to the fields strictly necessary. Phone and environment type are optional. The processing takes place in a B2B context and involves neither special categories of personal data nor automated decisions with legal effect. The retention period is limited to closure plus 1 year. We conclude that your fundamental rights and freedoms are not overridden by our interest.
  • Your right to object. You have at any time the right to object to this processing under article 21. Write to gdpr@particulair.com and we will assess each request individually.

11. Complaints and contact

If you have questions about how we process your personal data, or you want to exercise one of your rights, you can write to gdpr@particulair.com.

You also have the right to complain to the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, Denmark, phone +45 33 19 32 00, datatilsynet.dk/english.

12. Changes to this policy

We update the policy when our processing changes or when new legislation or practice makes it relevant. Material changes are flagged with a new "Last updated" date at the top of the page. For intrusive changes that affect your existing consent, we also re-display the cookie banner so you can re-decide.

Particulair