Adopted on 01/05/2018
At De Bergenske AS (comp. reg. no. 916207654), a Norwegian private limited company with business address Zander Kaaes gate 6, Norway, and at other De Bergenske companies (including, but not limited to: Hotel Augustin, Hotel Zander K, Grand Hotel Terminus, Hotel Bergen Børs, De Bergenske Servering AS), we will process personal data for our customers, guests, suppliers, employees, newsletter subscribers, and other users of our digital services (“Services“).
We endeavour to protect your right of privacy and to comply with current legislation designed to safeguard you as an individual. De Bergenske AS and companies in the De Bergenske group are hereinafter collectively referred to as “De Bergenske“.
De Bergenske is the data controller responsible for the personal data processed in connection with the Services, but other De Bergenske companies may act as data controller or hold joint data controller responsibility for certain personal data, e.g. data relating to hotel reservations. “Personal data” means all information that directly or indirectly can be linked to a natural person.
We strive to ensure a high level of data protection. De Bergenske will primarily use personal data to manage, supply, develop, and maintain the Services, process your bookings, enhance your experience when using the Services, and adapt communication to suit your requirements. We ask that you read this Privacy Policy carefully in order to understand how and for what purposes your personal data is being processed. By providing us with your personal data and accepting the terms and conditions, you consent to the processing of the data in accordance with the terms and conditions specified for each of the Services and for this Privacy Policy. If in a particular case your consent is required by law, this will of course be obtained.
This Privacy Policy, De Bergenske’s newsletter terms & conditions, De Bergenske’s booking terms & conditions, De Bergenske’s website terms & conditions, De Bergenske’s guidelines for the use of cookies, and relevant terms & conditions for De Bergenske’s processing of personal data are collectively referred to as the “Data Privacy Statement“. The Data Privacy Statement describes how we process the personal data we collect or you provide when using the Services. Therefore, some of our Services have separate terms and conditions for the processing of personal data, and you have to accept the terms and conditions for each of the Services you use.
Amendments to our data protection provisions are published via www.debergenske.no/en/privacy-policy, and we recommend that you read these regularly.
If you are providing personal data on behalf of someone else, you are obliged to ensure that the person consents to De Bergenske processing his or her personal data in accordance with the Data Privacy Statement.
1. How personal data is collected and processed
De Bergenske will only collect and process personal data to the extent permitted by law. Data may be collected and processed when you are using the Services, e.g. when you are making a booking or by other means during or after your stay. We use various methods to collect personal data, such as cookies, web beacons, customer surveys, and subscriber services. At times we also receive information about you from other De Bergenske companies, comprising details that may be added to your profile (if a profile has been created).
It is important to De Bergenske to keep your personal data up-to-date and accurate at all times. We may thus collect personal information about you from external sources, such as public records.
Where consent is required by law for the processing of certain personal data or for certain types of processing, such consent will be obtained prior to any processing.
2. Data from and about you that we collect and process
We will only collect personal data relevant for the purpose outlined in the terms and conditions for each of the Services and this Privacy Policy, such as name, address, telephone number, e-mail address, IP address, information to simplify use of the Services (log in), standard language, user history, subscriber details, information on fellow travellers, bookings, payments, profession, next of kin, food preferences, disabilities, and other information you may provide when using the Services. Examples of personal data collected from companies outside of De Bergenske are details such as up-to-date address and demography.
3. Purpose of processing your personal data
De Bergenske collects personal data for several purposes. Which personal data is collected, and the collection method used, will depend on the Services you use. The information is used to build a bespoke profile through which De Bergenske can fulfil its obligations and offer more flexible and customised experiences. Information relating to an unidentified person is used to create a pseudo-profile, based on identifiers such as cookies, and may, if the person later on reveals his/her identity by e.g. making a booking or subscribing to the newsletter, be combined with the profile created for this purpose.
De Bergenske uses personal data to:
manage, supply, and develop the Services;
process your bookings or orders;
contact you, e.g. via SMS or other mobile applications or e-mail, or notify you of the current status of your booking or provide information on your booking prior to, during, or after your stay;
diagnose errors, optimise technology, and contact you in the event of problems with a booking or use of a Service;
analyse and improve the quality and experience of the Services, e.g. verifying that your user account is not used by anyone else;
customise the way we communicate with you about our Services, e.g. by creating a profile and sending offers suitable for the profile and you as the user of our Services,
analyse statistics and the use of our Services;
offer advantages and improved experiences when using the Services in ways that we believe you may appreciate, or;
promote and market services and products, directly or indirectly, based on the user’s behaviour.
You may at all times and at no charge ask that De Bergenske refrains from using your personal data for marketing purposes, or you may withdraw your consent to this. This right can be exercised by contacting De Bergenske on the address specified in pt. 10.
4. Where we store and how we share your personal data
De Bergenske stores personal data in accordance with this Privacy Policy and current legislation. Personal data may be transferred between De Bergenske units to be processed for the purposes stated in the Data Privacy Statement. De Bergenske uses subcontractors for operations such as IT, with whom personal data may be shared. To ensure high-level privacy protection, our subcontractors will only process your personal data on behalf of De Bergenske and in accordance with our instructions, and only when a data processing agreement pursuant to current legislation has been entered into.
De Bergenske may disclose personal data to third parties such as the police or other law enforcement agencies as part of a criminal investigation, or share information in order to comply with legal obligations or orders from public authority bodies.
De Bergenske will, in general, not transfer personal data to countries outside the EU/EEA, but if we have a subcontractor located outside the EU/EEA or this is necessary for us to fulfil our obligations to you, personal data may be shared outside the EU/EEA even if the country in question has been deemed by the European Commission not to provide an adequate level of protection for personal data. To ensure high-level privacy protection in such circumstances, and to adhere to EU and EEA provisions, De Bergenske will enter into data processing agreements with such subcontractors. These agreements will regulate the processing of personal data and, if relevant, the transfer of personal data in accordance with current EU and EEA data protection provisions. The agreements include terms and conditions imposed by the European Commission, and fulfil the requirements of the current data protection legislation.
6. How your personal data is protected and removed
De Bergenske has implemented appropriate technical and organisational measures to protect your personal data against e.g. loss, manipulation, or unauthorised access. Our safety measures are adapted in line with the ongoing technological development.
De Bergenske will remove personal data in accordance with legislation. This means that De Bergenske will delete or anonymise personal data when processing no longer is required. The purposes for processing your personal data are stated in the above pt. 3 and in the Data Privacy Statement.
6. Other applications/websites
The Services may contain links to other applications and websites outside the control of De Bergenske. This Privacy Policy only applies to your use of the Services. De Bergenske is not responsible for the content in applications/websites to which we link, or for personal data that may be collected by the owner or operator of the websites to which we link.
8. Amendment, removal, and review of your personal data
De Bergenske AS will ensure that all the De Bergenske companies receive clear guidelines for the processing of personal data, and will state the purpose for which personal data will be used by De Bergenske. If there are changes to your personal data, please notify De Bergenske in writing on the address specified in pt. 10. De Bergenske accepts no responsibility for problems that may arise due to outdated or erroneous information if you have not informed us of the changes.
De Bergenske will, on your request or if discovered by De Bergenske, correct or delete erroneous or incomplete information. You are also entitled to receive, without charge, a print-out of the personal data that is being processed. Requests for print-outs must be submitted in writing to De Bergenske AS on the address specified in pt. 10, and must be signed by you and state your name, address, telephone number, and e-mail address (used in the communication with De Bergenske). Print-outs will be forwarded to the address provided within a month of De Bergenske receiving the request. The number of times such print-outs can be requested may vary depending on where you live.
You may withdraw your consent to further processing (but not with retrospective effect) of your personal data at any time by contacting De Bergenske on the address provided in pt. 10, after which De Bergenske will block any further processing of such information. However, withdrawal of consent does not affect processing that De Bergenske is entitled to perform without your consent (e.g. processing bookings that you have made), but may lead to reduced quality of Services or render impossible for the De Bergenske to offer the Services.
8. Cookies
De Bergenske uses cookies in connection with its digital services.
Google Analytics and Google Tag Manager
We use information derived from cookies to compile statistics on how our website is being used in order to establish which pages we should be focussing on and which pages may need improvement or should be deleted. Google Analytics uses cookies prefixed by ga and gid. Google Tag Manager sets cookies prefixed by dcgtm. These have a lifespan of up to 2 years. We have enabled the “anonymizeIP” functionality to ensure that your IP address is not stored by Google.
HubSpot
We use HubSpot to learn more about our customers in order to further improve our service. User data collected by HubSpot are names, contact details, job titles, and company names. HubSpot will also collect technical information: date and time, type of device (PC, mobile, etc.), operating system, screen size, and IP address. This is a link to a full overview of cookies set by HubSpot and their function. Cookies set by our HubSpot are hssrc, hssc, __hstc, and hubspotutk.
Craft Commerce
To allow us to remember what you have put in your shopping basket, we use a cookie with a name ending in commercecookie.
Zopim
We offer a live chat service on our website. In order to function properly, it sets a cookie named __zlcmid.
9. Transfer
If we sell, restructure, or in other respects transfer all or parts of our operation, your personal data will be transferred at the same time.
10. Contact
If you have questions, comments, or complaints relating to De Bergenske’s processing of personal data and compliance with the Data Privacy Statement or current legislation for the processing of personal data, please contact De Bergenske by sending a letter to De Bergenske AS, Zander Kaaes gate 6, 5015 Bergen. De Bergenske AS will, if necessary, ensure that your communication is forwarded to and processed by the De Bergenske company in question.