Privacy Policy and Statement

Klubbviken – Privacy Policy and Statement
Klubbviken follow documented security procedures regarding how your personal information is collected, used and stored: further, we limit who sees it and we have a number of systems in place to stop unauthorized access to it. This privacy statement documents how we do this: We are committed to safeguarding the privacy of our clients (individuals, travel agents, tour operators) under the General Data Protection Regulation (GDPR) – Regulation (EU) 2016/679, we have a legal duty to protect your personal data. Klubbviken is will act as a Data Controller.

The Information we collect and why we do so:
Klubbviken will in the course of normal business collect personal information in a variety of ways in order to provide good service and carry out our business activities effectively. This information may be given to us in the following ways:

• A customer makes a booking, enquiry or subscribes to receive information through a website, email or by phone.
• Customers make amendments or changes to a booking or enquiry as above.
• Customers consent and take part in a survey or provide us with feedback.
• Customers subscribe to receiving more information about our services.
• You accept cookie usage on one of our Websites allowing us to track information about your computer or device, and your visits to and use of our services
• You send us any other information which is pertinent to the completion of your travel booking, in particular this may extend to personal information about you
• In other forms of correspondence such as email, letter, and telephone which pertain to the activities of the business

All email correspondence is stored locally and backed-up and can be accessed for quality and regulatory purposes. Access to emails and systems is secured via two step authentications so that only authorized staff can access personal data. Travel profiles are held while you remain an active client/traveler, and can be reviewed at any time at your request providing this does not prevent the company from carrying out its business activities. Any marketing materials we send you will be sent to you in electronic format or communicated by telephone. Should you wish to remove your details from our email marketing list, then you will need to email booking@brandonlodge.se

Sensitive personal information:
We may require you to provide us with some special categories of personal Information in order for Klubbviken to provide you with a better standard of service. For example, when making a booking you may choose to provide us with some information about your dietary or medical requirements, which may reveal details about your mental or physical health or conditions. This information helps us to fulfil our duty of care to you. The provision of this information is however entirely voluntary. If you do not consent to our processing of this type of information, it may impact on certain aspects of your trip.

The use of cookies and Website tracking:
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets us know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We may use cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to agent and their customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from using our website to its full potential.
Google Analytics – We use Google Analytics to understand and improve the experience of our website visitors. Google Analytics measures your website experience factors and uses cookies to collect data on our users’ behavior and their devices as well as collecting information on the webpages the visitor has visited. Aggregated data is anonymized from the outset to recommend improvements to webpages. No data from Google Analytics is ever used to identify an individual. Retention for google analytics data is set at 24 months.
Bokun –  We use Bokun (the data processor) to allow you to make booking onto our own and our partners services. As part of this process cookies are placed on your machine to allow the software to deliver the correct content and functionality. This data is not associated to any bookings that you may make. You can see their statement regarding privacy as a data processor here.
Google Adwords – We use Google Adwords to advertise our products to potential clients. Google Adwords measures the performance of our adverts and also some aspects of behavior of visitors to our site who come via an advert on Google. Aggregated data is anonymized from the outset however where visitors to the site make a booking some data may be collected.
Cookie and purpose
_ga Google Analytics. Used to distinguish visitors’ Persistent cookie that expires after two years. _gat Google Analytics. Used to optimise the performance of the _ga cookie. Session cookie that expires after 10 minutes. _gid Google Analytics. Session cookie that distinguishes visitors. Expires after 24 hours. PHPSESSID WordPress/PHP. Session cookie, deleted as you close the browser window. Mainly used so the administrator can stay logged in when updates are made. _icl_current_language WPML. Makes sure users keep their chosen language while using the site. Saved for 24 hours.

Disclosure:
Klubbviken will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, taxation, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Save as stated below, your personal information is not disclosed to third parties unless this is indicated by our sales agents, or is indicated on our Websites or as required or allowed by law.
Your personal information will be passed to a third party in order to fulfil your activity booking with a sub supplier or certain processes necessary for the operation of our website and marketing activities.
We may disclose your personal information to any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may, from time to time, expand or reduce our business and this may involve the sale and/or transfer of control of all or part of Klubbviken. Information provided by our clients will, where it is relevant to any part of our business being transferred, be transferred along with that business and the new owner or new controlling party will, under the terms of this privacy policy, be permitted to use the information for the purposes for which it was originally supplied to us. We may also disclose information to prospective purchasers of our business or any part of it. In this instance we will take steps to ensure your privacy is protected.

How Klubbviken protects your information:
At Klubbviken, security is of paramount importance. To give you confidence, all our systems are encrypted with two-step authentication and this is managed by the Data Protection officer and ultimately the Managing Director.
Please note, however, that the transmission of information via the internet is never completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website or email – any transmission is therefore at your own risk.
All Klubbviken employees and data processors, who have access to or are associated with the processing of personal information, are obliged to respect the confidentiality of that information. Access to our systems is secured by password and staff are encouraged to update their passwords on a regular basis. Should Klubbviken receive any complaint, notice, request or communication which relates directly to the processing of your personal information by a third party supplier (whether travel principal or technology supplier) and the supplier’s compliance with Data Protection laws, we shall notify you as soon as possible of any breach or suspected breach of personal information.
Email security – All Klubbviken outbound emails are encrypted, but please note that unless encrypted an email sent from you to us via the internet may not be secure and could be intercepted and read by someone else. Please keep this in mind when deciding whether to include personal information in any email you intend to send us.
Links- Our Websites contain links to and from other websites and accounts, including those of our suppliers. If you follow a link to any of these websites, please note that these websites will have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check external websites policies before you submit any personal information to these websites.
Your consent – Whenever you are required to submit personal information you will be given options to restrict our use of this information, which will include the use of this information for direct marketing purposes. By submitting your personal information, you consent to the use of that information as set out in this policy. If Klubbviken changes this privacy policy, it will post the changes on this page. Continued use of our service will signify that you agree to any such changes. We suggest you regularly check this page for updates.

Accessing your personal data and information from Klubbviken:
Klubbviken will process any personal information that it collects in accordance with the General Data Protection Regulation (GDPR) – Regulation (EU) 2016/679. If you wish to access personal information collected from you or you have an enquiry or concern regarding the processing of personal data by Klubbviken, please make an individual information request to: booking@brandonlodge.se
Under the General Data Protection Regulation (GDPR) – Regulation (EU) 2016/679 you can request a copy of your personal information. Klubbviken will provide you with a legible copy of the personal information it holds and to which you are entitled via electronic format. This will be sent to you within 30 days of your request. Please note Klubbviken requires proof of your identity before supplying the information and may ask you for further information to assist in locating your personal information. Individual customers requests are free of charge most of the time unless the requests are repetitive or excessive.

General statements
You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
If any court of competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
Unless otherwise agreed, no delay, act or omission by us or you in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This policy will be governed by and interpreted according to the laws of Sweden. All disputes arising under this policy will be subject to the exclusive jurisdiction of Sweden.

Changes to policy
This privacy policy may be updated from time to time, so you may wish to check it each time you submit personal information to our Websites
Klubbviken | 25 May 2018