3 November 2023
J.No. 2023-7320-0189
Doc.no. 506285
Caseworker
Your complaint regarding Finansi
The Danish Data
Protection Agency
1. The Danish Data Protection Agency (hereinafter referred to as ‘the Danish DPA’) returns to Carl Jacobsens Vej 35
the case in which you have complained to the Swedish Authority for Privacy Protection 2500 Valby
Denmark
(hereinafter referred to as ‘IMY’) about Finansi’s processing of your personal data.
T 3319 3200
[email protected]
Pursuant to Article 56 of the General Data Protection Regulation1 (GDPR) IMY has forwarded datatilsynet.dk
the complaint to the Danish DPA, which has the assumed role of leading supervisory authority VAT No. 11883729
in relation to Finansi.
2. It appears from the case that you over the lapse of a year received advertising from Finansi.
You have on two occasions asked Finansi to delete you from their database due to the fact
that the information related to your phone number is wrong, as you never took a loan from
Finansi. You also stated that you did not wish to receive advertising from credit/loan
companies.
On June 3rd 2022 the Danish DPA asked FIRSTBORN ApS, who seems to be the rightful
owner of Finansi, to provide the following information:
• whether Finansi has erased all personal data about the complainant
• If no, whether Finansi intends to accommodate the complainant’s request in the light
of the complaint to the DPA, and
o if no, Finansi’s reasons for refusing to erase the personal data; and
o Whether the processing of the personal data in Finansi’s view is in accord-
ance with the requirements of Article 5(1)(e) of the GDPR on “limitation of
storage”
On June 15th 2022 Firstborn ApS confirmed that your details have been deleted from all their
systems.
3. On this basis, the Danish DPA finds no basis for taking further action in relation to your
complaint about Finansi’s handling of your request for erasure.
1 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural per-
sons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC
(General Data Protection Regulation).
This is due to the fact that a closer investigation of the case – regardless of whether the Dan- Page 2 of 2
ish DPA will find a breach of the data protection rules – will not significantly improve your
legal position. The resources required for such an investigation is not commensurate with
what could be achieved by doing so.
The Danish DPA has placed emphasis on the fact that Finansi has now deleted your per-
sonal information from all their systems.
The Danish DPA refers to Article 57(1)(f) of the GDPR, which states that a supervisory author-
ity shall handle complains lodged by a data subject and investigate, to the extent appropriate,
the subject matter of the complaint.
In making this assessment, the DPA may, for example, consider the resources available to the
DPA and the potential result expected to be achieved by an examination of the subject matter
of the complaint.
4. The Danish DPA hereby considers the case to be closed.
This decision cannot be brought before any other administrative authority, cf. Section 30 of
the Data Protection Act2. However, the decisions of the Danish DPA may be brought before
the courts, cf. Section 63 of the Danish Constitution.
Kind regards
2 Act No. 502 of 23 May 2018 on supplementary provisions to the regulation on the protection of natural persons with regard
to the processing of personal data and on the free movement of such data (the Data Protection Act).