Privacy Policy

Who we are

Previo is a product of NewNor Consulting ApS, CVR 43419536, Svendborggade 8, 3. th., 2100 København Ø, Denmark. We produce intelligence assessments from publicly available information, concerning individuals, companies and supply chains. Contact: compliance@previo-group.com.

Where we produce an assessment commissioned by a client, that client determines the purpose and we process on their documented instruction. We are a controller in our own right for our business records, for the integrity and audit trail of the assessments we produce, and for handling objections from data subjects.

Whose data we process

Depending on what is being assessed, personal data may concern:

• an individual who is the subject of an assessment;
• directors, officers and beneficial owners of a company being assessed;
• individuals connected to entities appearing in a supply chain being traced;
• individuals who appear in the public record alongside a subject, where that connection is material to the assessment.

What we process

Identifying data such as name, role, nationality, country of activity, and where supplied a date of birth or a registry identifier. To this we add publicly available information from sanctions and control lists, corporate and beneficial-ownership registries, official gazettes and insolvency notices, court and regulatory publications, adverse media, data-breach corpora, and public web sources.

Assessments may surface information relating to alleged or established criminal offences. Data of that kind is treated as restricted: it is processed only where relevant to the stated purpose, is never inferred, and is always reported with its source and date.

Lawful basis

Processing is carried out under Article 6(1)(f), legitimate interests, being the interest of the client and of Previo in establishing the integrity of a person, entity or supply chain before entering a relationship with it, balanced against the rights and freedoms of the individuals concerned. A Legitimate Interests Assessment is available on request.

Where processing concerns personal data relating to criminal convictions and offences, we rely on the basis available under applicable national law and limit processing to what that basis permits. Where consent is relied on for a particular assessment, it is obtained from the subject before processing begins and may be withdrawn at any time.

Where the data comes from

Most personal data we process is not obtained from the individual concerned. It is collected from the public sources listed above, and in some cases supplied by our client. Where we hold personal data that was not obtained from the individual, we provide the information required by Article 14 GDPR, or rely on an applicable exemption where notification would be impossible or involve disproportionate effort. We record which applies.

No automated decision-making

Assessments are not delivered on a purely automated basis. A person reviews and releases every report before it reaches a client, and no decision producing legal or similarly significant effects on an individual is made by Previo.

Sub-processors and transfers

We use third-party infrastructure and analysis providers to host data and to produce assessments. Where a provider processes personal data outside the EEA, we rely on Standard Contractual Clauses or an equivalent transfer mechanism. A current list of sub-processors is available on request.

Your rights

• Right of access (Subject Access Request)
• Right to rectification of inaccurate findings
• Right to erasure, where applicable
• Right to restriction of processing
• Right to object to processing carried out on the basis of legitimate interests
• Right to lodge a complaint with a supervisory authority (Datatilsynet in Denmark; the ICO in the United Kingdom)

To exercise any of these rights, or to contest a finding, contact compliance@previo-group.com. We respond within one month.

Retention

Assessments and the evidence supporting them are retained for as long as needed for the purpose they were produced for and for the period the client is required to retain them, ordinarily not exceeding six years, after which they are deleted. Working data that did not result in a finding is deleted sooner.

Contact

NewNor Consulting ApS, CVR 43419536. compliance@previo-group.com.