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1.
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Introduction
We are Stena Line Scandinavia AB with company registration number 556231-7825 (“Stena Line”) and are responsible as data controller for the processing of your personal data. All references in this privacy policy to “we”, “us” or “our” should be considered a reference to Stena Line. Our contact information is included in the end of this privacy policy. We respect your privacy and are committed to protecting your personal data.
Our loyalty clubs Extra Blue, Extra Gold or Business Traveller are together referred to below as the “Loyalty Clubs”.
The following sites are referred to as our “Websites”:
https://www.stenaline.se/, https://www.stenaline.no/,
https://www.stenaline.dk/, https://www.stenaline.cz/,
https://www.stenaline.de/, https://www.stenaline.ee/,
https://www.stenaline.es/, https://www.stenaline.fi/,
https://www.stenaline.fr/, https://www.stenaline.co.uk/,
https://www.stenaline.ie/, https://www.stenaline.it/,
https://www.stenaline.lt/, https://www.stenaline.lv/,
https://www.stenaline.nl/, https://www.stenaline.pl/,
https://www.stenaline.ru/, https://www.stenalinetravel.com/,
https://www.stenalineshopping.se, https://www.stenalineshopping.no
Our Websites and other communication interfaces (e-mail, telephone, support contact, social media, chat and paper forms) used by you in connection with the Loyalty Club membership are referred to below as our “Loyalty Club Services”.
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2.
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Scope of privacy policy
This privacy policy applies to our processing of your personal data when you are a member of one of our Loyalty Clubs and use our Loyalty Club Services. This privacy policy, inter alia, contains information about the purposes for which we process your personal data, with whom we share it, and what rights you have in relation to your personal data.
If you wish to obtain information on our processing of personal data when you are a customer or Website visitor, please see Stena Line’s Privacy Policy for Booking Customers and Website visitors Privacy Policy.
For information regarding how we handle cookies, please see our Cookie Policy.
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3.
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What categories of your personal data do we process?
Stena Line processes the following categories of personal data:
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(a)
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Name;
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(b)
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Birth date;
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(c)
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Gender;
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(d)
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Contact details (address, telephone and/or mobile phone number and email address);
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(e)
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Loyalty Club Membership Information (type of membership (Extra Blue, Extra Gold or Business Traveller), membership number, time as a member, time of membership level and membership points balance);
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(f)
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Password;
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(g)
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Transaction history (date, transaction type, transaction details and earned points);
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(h)
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Booking history;
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(i)
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Site information based on your IP address;
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(j)
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Browser information (browser version); and
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(k)
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Your employer and position (for business travellers).
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4.
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From where do we obtain your personal data?
Stena Line collects your personal data directly from you when you register as a member to one of our Loyalty Clubs, when you use our Loyalty Club Services, when you book a trip or when you make a transaction that will earn you Loyalty Club membership points or when you use such points as payment.
Stena Line also collects personal data from travel agents that you have instructed to provide us with your personal data. The information is held in the country where the travel agent stores the personal data.
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5.
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What happens if you do not provide us with your personal data?
Due to the nature of the Loyalty Club membership, it is necessary that you provide us with the personal data as specified above in Section 3 in order for you to become and stay a member of our Loyalty Club(s). If you do not provide us with the personal data, it is thus not possible for us to offer you Loyalty Club membership.
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6.
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For what purposes do we process your personal data and what is the legal basis for such processing activities?
Stena Line processes your personal data for the purposes set forth below. For each purpose Stena Line must have a legal basis. A legal basis could e.g. be (i) that the processing is necessary in order for the performance of a contract to which you are a party, or (ii) that Stena Line or a third party has a legitimate interest to process the personal data which is not overridden by your interest of not having the personal data processed. Under each purpose listed below, the legal basis that Stena Line relies on will be identified.
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(a)
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Provide Extra Loyalty Club membership
Stena Line uses name, contact details, loyalty club membership information, transaction history and booking history to administrate your membership, your earned and used points as well as membership level and to provide you with our contractual Loyalty Club Services in accordance with the Extra Loyalty Programme Terms & Conditions. This processing of your personal data is based on our contractual obligations towards you.
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(b)
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Provide Business Traveller membership
Stena Line uses name, contact details, loyalty club membership information, transaction history, booking history, your employer and position to administrate your employer’s membership, earned and used points as well as membership level to provide our contractual Loyalty Club Services in accordance with the Business Traveller Programme Membership Agreement. This processing of your personal data is based on our legitimate interest.
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(c)
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Provide our Loyalty Club Services
Stena Line uses name, contact details, loyalty club membership information, your employer and position to communicate with you when you use our Loyalty Club Services. This processing of your personal data is based on our legitimate interest.
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(d)
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Improve our Loyalty Club Services
In order to improve our Loyalty Club Services (in order to fix bugs, quickly and easily identify and solve Website conversion problems, change the interface so you easily can access the information you search for or to highlight relevant offers on the Website), we will use name, contact details, site information based on your IP address, browser information, loyalty club membership information and transaction history to obtain statistics on how you use our Services. We do this by analysing your use of our Services. When we use your personal data to improve our Loyalty Club Services, we use it in an aggregated form to the extent possible. This processing of your personal data is based on our legitimate interest.
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(e)
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Prevent abuse of Loyalty Club Services
To the extent necessary, name, contact details and membership number (as relevant in each specific case) may be used in order for us to prevent abuse and fraud. This processing of your personal data is based on our legitimate interest.
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(f)
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Provide offers, discounts and upgrades based on your purchase
Furthermore, we use name, contact details and Loyalty Club membership information to provide offers discounts and upgrades to you based on your purchase in relation to your Loyalty Club membership. This processing of your personal data is based on our legitimate interest.
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(g)
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Direct marketing
We use name, contact details and Loyalty Club membership information to the extent you have provided us with such personal data when using our Loyalty Club Services to send newsletters, offers and relevant information about our Loyalty Club Services. We send you these by mail, text message, e-mail and other forms of electronic communication. This processing of your personal data is based on our legitimate interest.
You have a right to, at any time, opt-out from receiving direct marketing as described in Section 6 (f) - (g). If you do this, Stena Line will no longer send such direct marketing to you.
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(h)
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Handling of complaints and defend and/or establish legal claims
We solely use personal data as relevant in each specific case in order to handle any complaints or defend and/or establish legal claims. This processing is based on our legitimate interest.
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7.
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With whom do we share your personal data?
In order to fulfill the purposes listed above, Stena Line will share your personal data with the following recipients.
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(a)
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Stena Rederi AB
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(b)
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Stena Line Travel Group AB
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(c)
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Stena Line Ltd.
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(d)
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Stena Line Irish Sea Ferries Ltd.
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(e)
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Stena Line BV
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(f)
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Stena Line GmbH & Co. KG
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(g)
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Stena Line Danmark A/S
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(h)
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Stena Line Norge AS
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(i)
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Stena Line Polska sp.z o.o.
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(j)
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UAB Stena Line
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(k)
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SIA Stena Line
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(l)
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Advertising and retargeting platforms, like Google Adwords, Youtube and Facebook
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(m)
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Service suppliers who we engage in order to provide you services such as web-hosting companies, mailing vendors, analytics providers, information technology providers, event hosting services, etc.
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8.
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Will we transfer your personal data outside of the EU/EEA?
Stena Line may transfer some of your personal data to the countries outside the EU/EEA listed below. If the EU Commission has not decided that a country listed below ensures an adequate level of protection for your personal data, then we will provide a description of the safeguards implemented by us or the legal basis relied on by us to ensure that the transfer of your personal data is in compliance with European data protection legislation.
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Country
United States of America
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Safeguard
The European Commission’s Standard Contractual Clauses for the Transfer of Personal Data (2010/87/EU)
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You are welcome to obtain a copy of the above described safeguard(s) by contacting our Data Protection Officer. Please see section 11 in this privacy policy for contact details.
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9.
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For how long do we store your personal data?
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Purpose
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Type of personal data
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Storage period
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Provide Extra Loyalty Club and/or Business Traveller membership
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Name, birth date, gender, contact details, Loyalty Club membership information, password, transaction history and booking history, your employer and position
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For the time you are a registered member with one of our Loyalty Clubs.
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Improve our Loyalty Club Services
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Site information based on your IP address and browser information
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For 26 months after you have used our Loyalty Club Services.
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Handle complaints or defend and/or establish legal claims
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Personal data relevant to assess Loyalty Club complaints or defend and/or establish legal claims
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For as long as your personal data is reasonably required in order to defend and/or establish legal claims (this will generally be the length of the relevant legal limitation period).
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10.
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What rights do you have?
Below is a summary of the rights you have under European data protection legislation. The exercise of these rights is free of charge and you may exercise the rights by sending an email or mail to the contacts listed at the end of this document. You can also use the contact form provided on the web site.
As a Loyalty Club member you always have the opportunity to remove or correct the information we have about you. You can edit your details by clicking on the link to “My Profile” after you have logged on to your Loyalty Club member page on the Website. In addition, whenever you receive an email you will be able to link to your personal profile to update it. Please do not hesitate to contact us should have any questions regarding your rights (see contact details in the end of this privacy policy).
Note that Stena Line will always assess a request to exercise a right to determine whether the request is valid. All rights listed below are not absolute and exceptions may apply.
In addition to the rights set forth below, you always have the right to lodge a complaint with a supervisory authority regarding Stena Line’s processing of your personal data.
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(a)
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Right of access. You are upon request entitled to receive a copy of your personal data that Stena Line processes and also to obtain supplementary information about Stena Line’s processing of your personal data.
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(b)
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Right to rectification. You have the right to have your personal data corrected and/or completed if it is inaccurate and/or incomplete.
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(c)
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Right to erasure. You have the right to request that Stena Line erases your personal data without undue delay in the following circumstances:
- the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw your consent to a processing activity and there is no other legal basis for the processing;
- you make a valid objection to the processing of your personal data;
- the personal data has been unlawfully processed; or
- the personal data has to be erased for compliance with a legal obligation.
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(d)
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Right to restrict processing. You have the right to request restriction of the processing of your personal data in the following circumstances:
- the accuracy of the personal data is under examination;
- the processing is unlawful or is no longer needed for the purposes of the processing but you oppose the erasure of personal data and request restriction instead;
- Stena Line no longer needs the personal data but you need the personal data for the establishment, exercise or defence of legal claims; or
- you have objected to the processing of your personal data and such objection is under verification.
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(e)
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Right to data portability. Under certain circumstances you have the right to receive the personal data concerning you which you have provided to Stena Line in order to transmit these to another service provider if the processing of the personal data is based on your consent or the performance of a contract.
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(f)
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General right to object. You have the general right to, at any time, object to the processing of your personal data that is based on Stena Line’s legitimate interests. If you object we have to demonstrate that we have compelling legitimate grounds for such processing or that we need the personal data for the establishment, exercise or defence of legal claims.
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(g)
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Right to object to direct marketing. You have a right to, at any time, object to the processing of your personal data for direct marketing purposes. If you do this, Stena Line may no longer process your personal data for such purposes.
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11.
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How can you contact us?
You may come in contact with us through the following communication channels:
Headquarters:
Address: Stena Line Scandinavia AB, 405 19 Gothenburg, Sweden
Telephone: (+46) 770 - 57 57 00
E-mail: [email protected]
National subsidiary (data processor on behalf of Stena Line):
Stena Line Limited
Stena House, Station Approach
Holyhead, Anglesey, LL65 1DQ, UK
Telephone: (+353) (0)1 904 7777
E-mail: [email protected]
Please note that we have appointed a so-called Data Protection Officer that you may contact if you have any questions about the processing of your personal data. Our Data Protection Officer Wiebke Jensen may be contacted at [email protected] .
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