Førsteklasses ferie

Privacy Policy of Dronningens Ferieby

 

1. Introduction

Dronningens Ferieby is a privately run disabled-friendly holiday resort, built in 1990 by Scleroseforeningen, which is a disease-fighting association whose main purpose is to support Danish people suffering from the disease Sclerosis, and to ease the conditions of the many Danish families who have the disease close to them. Dronningens Ferieby offers holidays in light, newly renovated houses with tasteful interior and ensures safety and freedom – in particular to people who are confined to a wheelchair, are walking-impaired, or who need extra flexibility or aids in everyday life. Thus, all the holiday houses in Dronningens Ferieby were tested by as many as ten special groups of people with different forms of disability – for example people with sclerosis, visually impaired, and wheelchair users, etc. This is for the benefit of many homes, day centres, care centres, and families.

We are required by law to inform you of our method of processing and disclosing personal data. When as a guest at Dronningens Ferieby or as an anonymous user you visit the websites of Dronningens Ferieby or book a stay with us, Dronningens Ferieby (in the following referred to as ”Feriebyen”) will as data controller collect and process a number of personal data.

We process personal data for the general purposes that

  • You as a user of Feriebyen’s websites have a good experience
  • We can enhance and develop our products and services for the benefit of our guests.

A detailed description is given below.

 

2. Types of personal data

Categories of data subjects and categories of personal data

All anonymous users:

We collect and process the following personal data when you visit Feriebyen’s website:

  • Mac address and other types of ID on the unit, for example tablets
  • Unit used to access the given website (for example tablet, smart device, pc, etc.)
  • Browser type, browser ID and language on unit
  • Website or app referring you to the relevant website
  • IP address
  • Geolocation of the unit used by you, including mobile units (either via IP address or GPS coordinates from your unit via your active consent)
  • Articles and sites visited by you, time, duration, and number of visits
  • Videos played by you and duration hereof.

 

All users desiring to book a stay at Feriebyen:

In addition to the above data, we also collect and process:

  • Name
  • Address
  • E-mail address
  • Telephone number
  • Need for aids and appliances (which indicates health information)
  • Membership number at Scleroseforeningen (which indicates health information) which allows the user to apply for a holiday resort grant (stay at a discount) if the user suffers from sclerosis.

 

All users desiring to receive newsletters from Feriebyen:

We collect and process:

  • Name
  • Address
  • E-mail address

 

 

3. Purpose 

All anonymous users:

We process personal data for the purpose of:

 

Personalization

  • To optimize your user experience and personalize it to you, for example analysis of your user behaviour, content selected, interests, and on this basis suggest content that we believe will be of relevance and interest to you.
  • To personalize the content on the basis of your personal preferences, such as sporting activities, etc.

 

Business development

  • Statistical and analytical purposes in order for us to enhance Feriebyen’s digital products and make them easier and better for our users and members. This involves, among others, enhancement of technological solutions and the user experience across Feriebyen’s digital services or development of new initiatives and services.

 

Compliance with legislation and other legitimate purposes

  • Compliance with current legislation (for example the EU General Data Protection Regulation and the Danish Data Protection Act) and other legitimate purposes
  • Obligatory documentation
  • Compliance with basic principles for processing of personal data and authority according to legislation to carry out the processing
  • Implementation and maintenance of technical and organizational security measures, including to ensure operating reliability and our possibility of protecting our services from any hostile attacks, for example hacker attacks
  • Safeguarding Feriebyen’s legal interests, for example violation of user rights and legislation on, for example, personal data and intellectual property rights
  • Investigation of suspected or known security breaches and reporting to individuals and authorities
  • Managing enquiries and complaints from data subjects and others
  • Managing inspections and enquiries from supervisory authorities
  • Managing disputes with data subjects and third parties
  • Statistical surveys and statements.

 

All users desiring to book a stay at Feriebyen:

We process personal data for these purposes (in addition to those described above):

 

Personalization

  • To target and personalize our communication to you.

 

Active contact

  • To provide customer service if you contact us with questions
  • To enable you asking questions, vote in competitions or otherwise send comments and content to our association.

 

 

4. Legal basis for collection and processing of personal data

 

All anonymous users:

Information on the legal authority to process the data.

 

Processing

Legal authority

All anonymous users

Display of content, etc. 

The EU General Data Protection Regulation, article 6(1) para (f) on legitimate interests, see section 6 of the Danish Data Protection Act.

Feriebyen’s legitimate interests are that you can use and access public websites with articles and information on Dronningens Ferieby.

Personalization

 

 

Consent, see executive order no. 2011/1148 on requirement for information and consent when storing or accessing information in end-users’ terminal equipment (”the cookie executive order”).

Business development

 

 

 

The EU General Data Protection Regulation, article 6(1) para (f) on legitimate interests, see section 6 of the Danish Data Protection Act.

Feriebyen’s legitimate interests are that we are to develop our existing products and have an eye for trends and future products and services.

Implementation of security

measures, etc.  

 

 

The EU General Data Protection Regulation, article 6(1) para (c), see Articles 32 to 36, and the EU General Data Protection Regulation, article 6(1) para (f) on legitimate interests, see section 6 of the Danish Data Protection Act.

The legitimate interests are that we can protect personal data.

 

All users giving consent to receive newsletters from Feriebyen 
(in addition to those described above)

Direct marketing, etc.

 

 

 

 

 

The EU General Data Protection Regulation, article 6(1) para (f) on legitimate interests, see section 6 of the Danish Data Protection Act.

Feriebyen’s legitimate interests are that we can send you the marketing and the notices you have asked for, for example by permission to e-mail marketing, that is to send you according to the EU General Data Protection Regulation, article 6(1) para (f), see section 6 (1) of the Danish Data Protection Act, and section 10 of the Danish Marketing Act.

 

All booking a stay at Feriebyen
(in addition to those described above)

For the purpose of Feriebyen’s collection and processing of sensitive personal data and information as to the state of health.

The EU General Data Protection Regulation, article 9(2) paras (h, i and j) on the conditions for legal processing of sensitive personal data, and the EU General Data Protection Regulation, article 6(1) para (b) on formation of contracts.

 

 

5. Voluntariness

When collecting personal data directly from you, you give us the personal data on a voluntary basis and to ensure that you will have access to the services we offer. You are not under an obligation to to give us the personal data but the consequence will be that you cannot book at stay at Feriebyen and, thus, will not be able to get access to a number of Feriebyen’s services and products.

 

 

6. Disclosure of personal data

Feriebyen discloses personal data to third parties in the following situations:

  1. For the purpose of travel planning, information is disclosed to a travel agent, see Article 6(1), para (b).

 

7. Transfer of personal data to data processors and recipients outside EU/EEA

We use the suppliers that we assess can best help us, and some of them process personal data in non-EU/EEA countries. For example, our data processors help us planning travels in third countries outside EU where application for visa may be required.

The legal basis for our international transfers is EU’s “Standard Contractual Clauses” for transfers from data controllers to data processors in non-secure non-EU/EEA countries. The standard agreement is available in different languages at this link: http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1401799946706&uri=CELEX:32010D0087, the recipient’s code of behaviour or certification or ”Binding Corporate Rules” (BCR/BVR). Transfers to the USA may also be based on EU-US Privacy Shield.

  

8. Retention period

We retain personal data on you as long as required for the above purposes. Retention is done in accordance with the rules on bookkeeping and the time limitation applying to criminal liability and liability to pay damages (absolute time limits), if relevant. If this is not relevant, we will erase the personal data before. The minimum retention period is at present the current calendar year and five years, according to the Danish Bookkeeping Act.

 

9. Your rights

When the processing of personal data is based on your consent, you are entitled to withdraw your consent without any negative consequences for you. However, it will not have an impact on the processing or disclosure of personal data prior to the withdrawal of the consent.

 

You have – subject to the restrictions of the law – certain rights, including:

  • The right of access to your personal data
  • The right to rectify incorrect personal data
  • The right to erasure of personal data
  • The right to restriction on personal data
  • The right to data portability
  • The right to object to the processing of the personal data, including automated individual decision-making.

 

If you desire to make use of one or more of the above rights, please contact us at post@dronningensferieby.dk.

 

You are also entitled to file a complaint to a competent supervisory authority, including the Danish Data Protection Agency.

 

Special information on objections

You are entitled to - for reasons related to your special situation – to object to processing of personal data for which the authority is found in Article 6(1), para (e or f), including profiling based on these provisions. Feriebyen is hereafter no longer allowed to process the personal data unless Feriebyen proves strong legitimate reasons for the processing which set aside your interests, rights or freedoms, or the processing is necessary to determine, submit or defend a legal claim.

If the personal data are processed for the purpose of direct marketing, you will at any time be entitled to object to the processing of your personal data for such marketing, including to object to profiling, to the extent that it relates to direct marketing. If you object to processing for the purpose of direct marketing, the personal data must no longer be processed for this purpose.

 

10. Contact

If you have any questions in relation to the processing of your personal data or the exercise of your rights, you are welcome to contact Dronningens Ferieby by either telephone or mail: 

  • +45 8758 3650
  • post@dronningensferieby.dk

 

Dronningens Ferieby

Dronningens Ferieby 1

DK-8500 Grenaa

Denmark

Web: Mercatus Reklamebureau A/S