PRIVACY POLICY Ver1 (April 2020)

Flayen Executive is a cooperation of independent management consultants. The partners and associated partners are representing the same legal entity registered in Denmark.

The partners all work within their independent business, contractually obliged to follow standards, rules, and procedures, including the Privacy Policy set-forth by Flayen Executive as well as Danish and EU legislation.

Flayen Executive and all partners are obliged to follow the rules of the General Data Protection Regulations (GDPR), enforced by the European Union in May 2018, when processing Personal Data. 

This Privacy Policy describes how Flayen Executive processes your Personal Data.    

Data Responsible

All partners and associated partners of Flayen Executive (from now on called “FEX”) are individually and solely responsible for processing your Personal Data. The primary contact address of FEX is:

Flayen Executive
Enigheden, Bygmestervej 57
DK-2400 Copenhagen NV
Att.: Claus Bengtsson

+45 5128 8858

Purpose of processing Personal Data

FEX process Personal Data for the following purposes:

  • to conduct services for our clients that involve the search for and evaluation of qualified candidates for a specific assignment,
  • to contact potential candidates concerning job opportunities,
  • to collect personal CV’s and job applications for a concrete job position
  • to assess candidate qualification to particular assignments
  • to assist individuals upon outplacement assignments

The legal basis for FEX to process Personal Data (to the extent permitted or required by applicable regulations) is Danish Law.

Collecting Personal Data

Personal Data is, in general, collected from yourself. FEX also collects Personal Data from open sources, such as LinkedIn, Facebook, Google Search, etc. FEX may also collect Personal Data from third parties in our network.

All Personal Data are processed equally under this Privacy Policy, no matter how any Personal Data are collected and received.

Categories of Personal Data

FEX process two different kinds of Personal Data:

Standard Personal Data, such as; name, address, email, telephone number, educational background, academic degree(s) and other qualifications, languages and other skills, age/date of birth, job title(s), salary, and other compensation data and government-issued information. In general, FEX considers your CV as standard Personal Data.

Sensitive Personal Data is critical data like health data, disability information, marital status, criminal record, religion, or sexual preferences.  Sensitive Personal Data will only be processed when necessary to fulfill our obligation towards third parties.

FEX only process Sensitive Personal Data upon your prior and explicit consent.

Transfer of Personal Data

FEX may disclose or transfer your Personal Data to the following third parties:

  • Our clients #
  • Research service providers, who screen for applicable candidates and collect Personal Data (typically CV’s) on behalf of FEX,
  • Service providers that perform individual profiling tests,
  • Cloud-based IT solutions that either transfer data or store data, such as email programs, WeTransfer, Dropbox, OneDrive, ICloud, or the like.

# FEX only discloses your identity and Personal Data to our clients upon your prior and explicit consent.

Your Personal Data may also be disclosed or transferred between the Partners of FEX, in such case only via secured, electronic means, such as WeTransfer or the like.

Data retention and storage

FEX will retain your Personal Data for a while sufficient to fulfill the purpose for which FEX collects the Personal Data. However, FEX does not keep Personal Data for more than three (3) years.

FEX may retain Personal Data for an extended period beyond three years; however, in such cases, the Personal Data will be anonymized. In general, FEX deletes Personal Data upon closing the assignment to which the Personal Data was collected.

CV’s and the like that are uploaded to FEX from individuals, and which are not directly related to a specific assignment, will be deleted after oné (1) year.

Storage of non-electronic data (such as a CV on paper) will be stored in a secure, physical store, when not being processed. FEX protects data stored electronically by adequate mean, i.e., secured by passwords to avoid disclosure to non-authorized parties.   

Consent and the right to withdraw consent

In some cases, FEX asks for your consent to process your Personal Data. In such case, you have the right to withdraw your consent by contacting our responsible partner.

If you, at any time, partly or wholly, withdraw your consent, it will not deem our use of your Personal Data illegal from the period of your original consent to the date of your withdrawal.    

Your rights

Under the GDPR Directive, you have certain rights concerning our processing of your Personal Data. If you want to call upon your rights, please contact our responsible partner.


You have the right to get insight into all specific Personal Data that FEX process about yourself.


You have the right to have any or all Personal Data deleted by FEX, also before the end of our retention period.


You have the right to limit the processing of your Personal Data by FEX. Upon limitation, FEX may only process (except for storing) limited Personal Data with your specific consent.


In some cases, you have the right to oppose to our use (processing) of your Personal Data.


Under certain circumstances, you have the right to obtain your Personal Data in a structured, commonly used, and machine-readable format and to have such data transferred to another data provider.


You have the right to file a complaint to “Datatilsynet” ( if you do not find our processing of your Personal Data correct or illegal.

Copenhagen, April 1, 2020

Claus Bengtsson, Partner –

Flayen Executive

Flayen Innovation & Consultancy / CVR 33820283