Privacy Policy
1. Introduction
This privacy policy applies to the processing of personal data carried out by Hurtigruten Svalbard AS when you travel with us, use our services, visit our websites or mobile applications, or otherwise interact with us.
It is important for us to use your information only in accordance with applicable privacy laws and your expectations, and we shall be clear about how we use it.
This privacy policy will explain what information is collected, why it is collected, how the collected information is used, and what options and rights you have regarding the collection of personal data.
2. Data controller
Hurtigruten Svalbard is the data controller for your personal data. Hurtigruten Svalbard is part of the Hurtigruten Group, which consists of several companies. Depending on which services you have purchased, we may share your personal data with other companies in the Hurtigruten Group. We also work with a number of suppliers, including public authorities, medical personnel, other business partners, and suppliers, and may share personal data with them if:
we have a legitimate reason
it is permitted or required by law, or
you have consented
Suppliers process your personal data according to a data processing agreement. The data can only be used in connection with the services you have purchased.
To deliver services to you, the following companies within the Hurtigruten Group may also be responsible for processing and storing your personal information:
Hurtigruten Destinations AS, organization number 921 885 156, is responsible for processing your personal data when traveling to Svalbard, including stays at our hotels, restaurants, and in connection with all our activities and excursions.
Hurtigruten Global Sales AS, organization number 914 904 633, is responsible for processing personal data through our centralized booking system, for our websites, for your account on our websites, for our mobile app, and for our loyalty program, as well as for all marketing and distribution of emails to our customers and contacts.
Hurtigruten Global Services AS, organization number 974 526 689, is responsible for processing personal data related to all financial information about you, such as when you receive an invoice or make a payment with us.
Hurtigruten Norway AS, organization number 927081946, is responsible for processing personal data when you are on board our vessels along the Norwegian coast. Hurtigruten Norway is also responsible for processing and storing your personal information in connection with all on-board activities and excursions.
Hurtigruten Expeditions AS, organization number 927 082 047, is responsible for processing personal data when you travel on an expedition with us. Hurtigruten Expeditions is also responsible for processing and storing your personal information in connection with all on-board activities and excursions.
3. What information we may collect
In connection with the various ways we can interact with you and the different services we offer, we may collect the following categories of information:
C1: Contact information, including name, address, phone number, and email address
C2: Identity information, including gender, date of birth, and nationality
C3: Passport information
C4: Information about next of kin
C5: Transaction information, including credit/debit card number, payment method, and purchase history
C6: Booking information and activity information, including information related to booked trips and excursions, flight reservations, hotel bookings, itineraries, travel companions, activities you participated in while traveling with us, etc.
C7: Information about communication between you and us, including recordings of calls to our service centers, email communication, chat, comments, and reviews collected through surveys or that you have posted on our channels or on social media.
C8: Digital information collected when you visit our websites, applications, or other digital platforms – including IP address, browser data, traffic data, booking history, social media behavior, and user patterns. If you subscribe to our newsletters, we may collect information about which newsletters you open, your location when you open them, and if you use any web links in the newsletters. Read more about why and how we collect C8 data - and how to disable this feature - on our cookies/information page.
C9: Health information, including information regarding allergies, disabilities, and illnesses
C10: Religious beliefs and ethnicity
C11: Recordings from video surveillance
4. Where we get your data from
Most of the information we have about you has been provided by you. We may also receive information from C1, C2, C5, C6, and C7 from our partners, such as travel agents, airlines, hotels, activity providers, transport providers, partner companies, branches, and agents if they have relevant information about you. C8 information is collected from our websites, applications, and any other digital platforms.
5. Why we use your information
We process personal data for the following purposes:
Booking
Description: We use information from C1, C2, C4, C5, C6, and C7 to facilitate, process, and confirm bookings. If necessary, we collect your passport number because we are obliged to provide this information to the port authorities. Additionally, we need C9 information to ensure we can accommodate you with regard to allergies, disabilities, and illnesses. We may also indirectly collect C10 information if you notify us of any dietary restrictions/preferences, etc.
Legal basis: Such information is processed to fulfill the agreement (booking the trip with Hurtigruten Svalbard). We will only collect C9 and C10 information based on your consent. Note that for safety reasons, you may not be able to book the desired trip if you do not provide C9 information.
Disclosure: To facilitate your trip in the best way possible, we may need to share your information with branches, agents, and partners.
Facilitation of the trip
Description: We use information from C1, C2, C4, C5, C6, C7, C9, and C10 to facilitate your trip. This includes offering you the services and products you need or want, and ensuring you get permission to disembark at ports. We may process information from C9 and C10 to ensure dietary preferences, allergies, illnesses, and disabilities are taken into account on the trip and to ensure you receive necessary assistance from medical personnel on board.
Legal basis: We use such information to fulfill the agreement with you (facilitate your trip). We will only process C9 and C10 information if you have given us consent.
Disclosure: We may share information about you with partners if this is necessary to fulfill the agreement with you.
Activities
Description: If you choose to participate in activities, we use information from C1, C2, C3 if necessary, C5, and C9 to make reservations on your behalf.
Legal basis: Such information is processed to fulfill the agreement (booking the activity). C9 information will only be collected if you have given consent. Note that for safety reasons, you may not be able to book the desired activities if you do not provide C9 information.
Disclosure: We may be required to share such information with partners so you can participate.
Communication
Description: We use information from C1 and C7 to provide you with relevant information about your trips and any excursions. This includes information regarding departure times, cancellations, and check-in times at hotels, etc. We may send you this information electronically or in other ways.
Legal basis: We use such information to provide important information about your trip that is necessary to fulfill our agreement with you (to organize your trip). We also use such information to give you other information necessary to protect our interests and to ensure your trips are as comfortable and smooth as possible. We will only record phone calls with you if you have given consent for such recordings.
Disclosure: We may share information from C1 and C7 with our partners, as they may need this information to communicate with you and to offer you support and assistance.
Direct Marketing
Description: We use information from C1, C2, C7, and C8 to offer you newsletters and offers from us and our partners.
Legal basis: As long as you have an existing customer relationship with us, all use of such information to advertise our services is based on our legitimate interest in providing you with relevant information and offers. You can unsubscribe from receiving such information and offers at any time. If you do not have an existing customer relationship with us, we will only use your information to send you marketing if you have given consent. We will only share your information with partners for marketing purposes if you have given consent.
Disclosure: We may share your information with partners so they can send you information and offers if you have given consent.
Profiling
Description: We may use and compile information from C1, C2, C6, and C8 to perform profiling. Profiling is the automatic processing of personal data, where personal data is used to evaluate, analyze, and predict preferences, interests, and behavior (profiling). We use this information to provide you with customized information about activities and offers that may be of interest to you.
Legal basis: We perform profiling to fulfill a legitimate interest, namely to tailor the services to your enjoyment and benefit. You can object to us using your personal data for profiling purposes at any time.
Disclosure: We will not share profiles we have generated based on your information with external parties, except for our partners and sales offices.
Security
Description: We use video surveillance in our stores and store C11 information to prevent crime.
Legal basis: We use video surveillance when it is necessary to fulfill a legitimate interest, specifically to prevent crime and ensure your safety when you travel with us.
Disclosure: We will not disclose images from video surveillance to external parties unless required by law or upon request from relevant authorities.
Statistics and Analysis
We use anonymized information to generate statistics and analyses.
6. How long do we store personal data?
We will only store your personal data for as long as necessary to fulfill the purposes for which it is processed.
We store information from C1, C2, C6, and C7 from the time of booking until 5 years after your trip ends. We may store your personal data longer if you request that we keep it for your next trip and you have given consent for this, or if required by law.
We store information from C3 and C4 from the time of booking until 90 days after your trip ends. We may store your personal data longer if you request that we keep it for your next trip and you have given consent for this, or if required by law.
If you have logged into Hurtigruten's portal, we will store information from C1, C2, C5, C6, C7, and C8 that you have provided on the portal as long as you are registered as a user of this portal.
We will store C5 information when required by applicable law, such as the Accounting Act.
If you have consented to receive information and marketing materials, we will store information from C1, C2, C6, C7, and C8 as long as you wish to receive this.
We may also store information from C1, C2, C5, C7, C8, and C9 for up to three years after your trip ends if we believe this is necessary to handle potential complaints or claims.
If you have not given consent and we believe the information is not necessary to handle potential complaints or claims, we will store information from C8 for 6 months.
We store video surveillance recordings for up to 30 days. If we believe it is necessary to hand over recordings to the police – for example, when a crime has occurred – we may store the recordings for up to 90 days.
7. International transfer of information
We have partners, branches, agents, and collaborators located outside the EEA and may transfer information to them as described in sections 2, 4, and 5 above.
We will ensure that your personal data is protected appropriately by the receiving party in these countries. Appropriate protection may include ensuring that the receiving party is contractually obligated to provide the same level of data protection and information security as we do. You can request more information or receive a copy of the security measures we use to ensure that your personal data is transferred in a legally compliant manner.
Hurtigruten Svalbard AS is part of the Hurtigruten Group, which offers services worldwide and has branches and partners in all European countries, the Pacific region, Africa, and South, Central, and North America.
8. How can you access, correct, or delete personal data or file complaints?
Click here to access "My Data" where you can request information about the data we have stored about you. You can also request a copy of the information we have collected about you.
You can ask us to delete the information we have collected from you. However, we are required to retain the information needed to fulfill our agreement with you, as well as information necessary to comply with applicable laws and regulations or requirements from authorities.
If you believe that we are not using or handling your personal data correctly, you can complain to the Data Protection Authority. Before submitting such a complaint, we ask that you contact us, as we may be able to provide the answers you need and resolve potential misunderstandings.
9. Cookies
We use cookies on Hurtigruten Svalbard's websites to ensure they function as intended, to analyze traffic on the sites, and to see which areas of the sites you have visited. Read our cookie policy for more information.
10. Changes to this privacy notice
From time to time, we may update this privacy notice. You will be notified of these changes when and where appropriate; they may also be published on our homepage. All changes will take effect after they have been communicated/published.
11. Contact information
If you wish to contact us, you can send us an email at info@hurtigrutensvalbard.com or send an inquiry to Hurtigruten Svalbard AS, Att: DPO, P.O.Box 548, N-9171 Longyearbyen.
Note: If you have questions regarding your booking, please contact info@hurtigrutensvalbard.com