CCTV, which may be set up, takes place in the context of crime prevention and also functions as a reassurance measure for employees and guests.
4. Data that Fænø Estate collects
Fænø Estate collects the following personal data:
- Name, address, telephone number, e-mail address, date of birth, and other general, nonsensitive personal data.
- Payment card details—typically to guarantee a reservation and to pay for accommodation.
- Other bank and payment details—typically as a guarantee of credit or for payment of, for example, a deposit.
- Demographic data.
- Purchase history including the use of Fænø Estate’s potential app and/or other digital services.
- Payment history.
- Browser information.
- The use of Fænø Estate’s potential customer/loyalty programme.
- Image data from Fænø Estate’s social media and other digital platforms belonging to Fænø Estate.
- Data from Fænø Estate’s social media and other digital platforms belonging to Fænø Estate.
- Data from Fænø Estate’s customer surveys.
- Data from any potential competitions.
- Data from credit reporting agencies.
- Data about the guest’s/customer’s company and relevant contact persons.
- Data included in our correspondence with you.
- Data about suppliers’ companies, as well as data on relevant contact persons and key persons including key accounts.
A guest/customer/supplier can voluntarily and by choice give Fænø Estate additional personal data that they consider is important to Fænø Estate’s operation and servicing of the guest/ customer/ supplier, or that they believe should be given for security purposes.
For example, this can be data on:
- Disability.
- Allergy.
- Special food preferences.
- Other health or medical information.
If a guest/customer/supplier voluntarily and by choice chooses to give such data, Fænø Estate considers it as consent to record and store such sensitive data about them.
In addition to the data that Fænø Estate receives directly from guests/customers/suppliers, Fænø Estate will, in some cases, obtain or process additional data that Fænø Estate has received from third parties, for example, a travel agent, booking portal, another intermediary or an employee of the company where the data subject is employed.
Where this is the case, the third party must inform the relevant guests/customers/suppliers of Fænø Estate’s Terms and Conditions, as well as the Privacy Policy of Fænø Estate. It is also the responsibility of the third party concerned to ensure that there is the necessary legal basis for collecting and processing such data, including obtaining the necessary consent to the processing of any sensitive data.
5. Payment by credit or debit card
Fænø Estate uses Nets to redeem payments made by debit and credit cards. Fænø Estate is approved and certified by the Danish Financial Institution’s Payment System (www.pbs.dk).
For reservations and bookings, Fænø Estate stores the data provided by the guest/customer/supplier for up to five years, after which the data is deleted.
In addition to processing the order, the data provided will only be used if a guest/customer/supplier, for example, contacts with questions or if there are errors in the order.
6. What is the purpose of the collection and processing?
Fænø Estate only collects personal data that is necessary to comply with the agreements entered into with guests/customers/suppliers for the provision of services, for example, an event, or the purchase/sale of products or services.
It is the nature of the individual agreement and the type of service which determines what personal data Fænø Estate collects and processes and which determines the purpose of the collection.
The purpose of the collection and processing of personal data will primarily be:
- To process a guest’s/customer’s booking and purchase of Fænø Estate’s services and products.
- To process suppliers’ quotes and sales of products and services.
- To contact the guest/customer before, during or after their stay.
- To fulfil the guest’s/customer’s request for offers or the purchase of services.
- For the improvement and development of Fænø Estate’s services.
- For the customisation of Fænø Estate’s marketing, public relations and other communications.
- For the analysis and reporting of the behaviour of guests/customers/suppliers and marketing to them.
- To customise Fænø Estate’s partners’ communication and marketing to guests/customers/suppliers.
- Administration and maintenance of the guest/customer/supplier relationship to Fænø Estate, including possible participation in Fænø Estate’s potential customer/loyalty programme, cultivation of new customers and continuous business relations.
- Compliance with legal requirements, for example, the requirement to register overnight guests according to immigration law, rules for Internet logging and passport regulations.
7. Legal basis for processing
Fænø Estate will most often process personal data because it is necessary to fulfil an agreement with Fænø Estate which a guest/customer or a supplier are party to. This may, for example, be in connection with accommodations, holding meetings and/or the processing and fulfilment of cooperation and supplier agreements.
Fænø Estate will also process personal data in connection with booking prior to a stay, holding meetings, parties, conferences, etc., and prior to entering into supplier agreements.
In some cases, Fænø Estate’s processing of personal data will take place as part of the fact that Fænø Estate has a legitimate/factual interest that precedes the guest’s/customer’s/supplier’s (the data subject’s) interests.
Such a legitimate interest could, for example, be the preparation of statistics, customer surveys, marketing and an analysis of general guest/customer behaviour, which aims to improve the overall experience at Fænø Estate and the quality of Fænø Estate’s services and products.
In connection with their stay/visit to Fænø Estate, if a guest/customer discloses particular personal preferences or considerations, including, for example, medical information, disability, religious beliefs or the like, Fænø Estate only uses the data to ensure that the guest’s/customer’s personal preferences, well-being and health etc., are taken into account.
In some situations, Fænø Estate receives personal data from third parties such as a travel agent, an agent or similar, including in connection with group bookings or booking for individuals. When this happens, the third party must notify the relevant guests/customers/suppliers of Fænø Estate’s Terms and Conditions and the content of this Privacy Policy.
Under the law, see the above under section 6, Fænø Estate is also required to record various data about overnight guests. This data must be kept for at least one year and a maximum of two years.
8. Rights of the data subject
According to the rules of the General Data Protection Regulation (GDPR), data subjects (customers/guests/suppliers) have different rights.
- A data subject has the right at any time to obtain access to the personal data that Fænø Estate processes on the data subject.
- A data subject has the right at any time to rectify and update the personal data that Fænø Estate has on the data subject.
- A data subject has the right at any time to delete the personal data that Fænø Estate has on the data subject. If a data subject requests deletion, all data that Fænø Estate is not required to keep by law must be deleted. A deletion of the data subject’s data may in some cases mean that Fænø Estate cannot fulfil agreements made or provide certain services to the data subject.
- If some of the data that Fænø Estate has on the data subject is given on the basis of the data subject’s consent, they are entitled at any time to withdraw their consent, which means that the data is deleted or is no longer used by Fænø Estate. This shall not apply to the data referred to above that Fænø Estate is legally obligated to store.
The option to request deletion, etc., may, however, be limited in order to protect the privacy, trade secrets and intellectual property rights of other persons and, for example, the option to enforce potential legal claims.
The data subject may at any time in writing ask Fænø Estate to obtain an overview and a copy of the personal data of the data subject that Fænø Estate possesses.
A written request to that effect must be signed by the data subject and include their name, address, telephone number and e-mail address.
The data subject may also contact Fænø Estate if the data subject believes that their personal data is being processed in contravention of the law or in breach of other legal obligations, such as the agreement/contract that the data subject has with Fænø Estate.
Written requests are to be sent to Fænø Estate, see the contact details above under section 1.
Fænø Estate will, as far as possible, within one month of receipt of the data subject’s written request, reply to the data subject’s postal address.
If the data subject asks for the correction and/or deletion of their personal data, then Fænø Estate will assess whether the conditions for the request have been met and Fænø Estate will make changes or deletions as soon as possible.
Fænø Estate reserves the right to reject requests which have the character of vexatory repetition, or which require disproportionate technical measures (such as the development of a new IT system), or which affect the protection of other data subjects’ personal data, or in other situations where it would be disproportionately resource-intensive or very complicated to meet the request.
9. Security
Fænø Estate protects the personal data of the data subject and has established guidelines to protect the data subject’s personal data from unauthorised disclosure and access or coming to the knowledge of unauthorised persons.
Only those persons/employees of Fænø Estate who, by virtue of their job function, need the personal data of the data subjects have access to it. Fænø Estate continually checks that there is no unauthorised access to the personal data of data subjects.
Fænø Estate regularly backs up data subjects’ personal data.
In the event of a breach of security where there is a high risk of misuse of the personal data of data subjects, including, for example, of identity theft, financial loss, loss of reputation or any other form of abuse, Fænø Estate will inform the data subject of the breach as soon as possible.
Fænø Estate’s security procedures are continually reviewed and updated in relation to technological developments.
10. Sharing personal data
We will not disclose data to any third party without your consent unless it is necessary to enable us to advise and serve you or because it is necessary to ensure compliance with applicable Danish law. We do not use your data for any purpose other than for the purposes described in this Privacy Policy.
Fænø Estate uses a number of external suppliers of IT services, IT systems, payment solutions etc.
Fænø Estate enters into ongoing data processing agreements with Fænø Estate’s suppliers/our data processors, in accordance with the Danish Data Protection Agency, and where it is required in relation to external data processors, to ensure that a necessary and high level of security is maintained with regards to the personal data of data subjects.
In order to comply with agreements with the data subjects and to meet the needs of guests and customers, Fænø Estate shares selected personal data with external suppliers such as restaurants, hotels, nature and culture guides, tourist attraction providers, etc. This is done only by agreement with the guest/customer in order to serve and assist the guest/customer in the best possible way in connection with the planning of, for instance, accommodation, visits to tourist attractions, preparation of transport, etc.
Fænø Estate also shares and discloses the personal data of the data subjects within the Group, including with sister companies. The purpose of this sharing is to provide the guest/customer with the best service and services, regardless of the restaurant/hotel or division of the Skouboe Group the guest/customer is using. And also as part of the Group’s marketing efforts in accordance with the relevant rules.
In some cases, Fænø Estate is legally obligated to disclose personal data or obligated to do so as a result of a decision of a public authority. We disclose or pass on personal data to the following categories of recipients:
- Bank connections with regards to the management of payments.
- Debt collection and credit reporting agencies in the event of a breach of payment, as well as posting with a credit reporting agency.
- Tax authorities and other authorities in relation to statutory reporting.
11. Deletion of personal data
Fænø Estate deletes your personal data when Fænø Estate’s legal obligation ceases or when the purpose of collecting and processing the data is no longer present. Fænø Estate generally follows the storing period that applies in accordance with the Accounting Act. In order to ensure proper handling of recurring customer relationships, potential complaints and warranty obligations and to meet our obligations, we have assessed that it is necessary to store data for up to five years and from when the current business relationship has ceased.
12. Cookies
Fænø Estate uses cookies. More information about Fænø Estate’s cookie policy can be found here: Cookie Policy
13. Complaints
Complaints about Fænø Estate’s processing of personal data can be made to the Danish Data Protection Agency, BORGERGADE 28, 5, DK-1300 COPENHAGEN K, TELEPHONE +45 3319 3200 – E-MAIL dt@datatilsynet.dk
14. Changes to the Privacy Policy
If Fænø Estate makes changes to our Privacy Policy, these changes will always be updated on our website under the “Privacy Policy” menu point. We recommend that you regularly check our Privacy Policy on the website for any changes.
15. Document information
This is the 2018 version of Fænø Estate’s Privacy Policy updated on 25th May 2018.
