At Ligula Hospitality Group, we believe your privacy is extremely important and the measures we put in place to protect our customers’ personal data are taken very seriously. All your personal data is processed in accordance with Swedish and European legislation – the EU General Data Protection Regulation ‘GDPR’ will apply from 25 May 2018. At Ligula Hospitality Group, we process personal data about customers, business contacts and other users of our services.
Ligula Hospitality Group AB includes the following trade marks: Good Morning Hotels, Profilhotels, Collection, Motel L, Apartments and franchise hotels. If you contact any of these hotels and disclose personal data about yourself which is thereby passed on or shared with Ligula Hospitality Group (Ligula), your data will be processed in accordance with this Personal Data Policy.
1. Who is the data controller
Ligula Hospitality Group AB, corporate identity number 556792-6497, Södra vägen 12, 412 54 Gothenburg, Sweden, including subsidiaries, is the data controller in terms of processing personal data that you disclose in the context of contact with any of our hotels or associated services. Please feel free to contact us by e-mail if you have any questions, on firstname.lastname@example.org or by phone +46 (0)8-408 819 00.
2. What is personal data
Any type of information that relates directly or indirectly to a natural living person constitutes personal data. This may be name, contact details, social security number, account number, customer number etc. Any action taken with personal data constitutes processing of personal data regardless of whether or not this takes place automatically. Examples of normal processing are collection, storage, registration, sorting, processing, transfer or deletion of data.
3. Processing of personal information
Ligula processes your personal data in accordance with applicable privacy protection legislation. This means that from 25 May 2018 processing will take place in accordance with the EU General Data Protection Regulation ‘GDPR’ and will supplement national legislation concerning the protection of privacy.
4. Collection and processing of personal data
Your personal data may be collected and processed when you contact any one of our hotels or if you use Ligula’s services following your stay, if you contact us directly or in connection with reservations/payments during and after your stay.
Ligula processes your personal data to the extent necessary in order to fulfill an agreement to which you are party and to implement measures at your request before such an agreement is reached. An agreement may be reached if you order any of our services, for example, book a stay in one of our hotels.
Moreover, your personal data is processed if this is necessary in order to fulfill Ligula’s legal obligations (for example, to fulfill obligations in relation to Skatteverket (Swedish Tax Board), the police and enforcement authorities regarding accounting records).
In the event that you give explicit consent whereby you accept that Ligula processes personal data for one or more specific purposes, such consent will constitute a legal basis for the processing of your personal data in the respective case. If your consent is required, you will receive specific details of the processing involved in such cases and what approval means.
To the extent Ligula processes personal data beyond what is necessary in order to fulfill agreements or comply with legal obligations, and in the absence of explicit consent, such processing will be based on a balance of interests where Ligula has identified a purpose relating to a legitimate interest for which processing of personal data is necessary and where, after careful consideration, Ligula has found that your interests or basic rights and freedoms do not override in the context and require the protection of personal data. Ligula has legitimate interests in performing market and customer analysis, as a basis for marketing, method and business development and statistics, and conducting direct marketing. In the event that personal data is processed in the context of such activity, a balance of interests will constitute the legal basis for the processing of personal data which is necessary for the purpose relating to these legitimate interests.
5. Storage period
Ligula will store your personal data as long as you are one of our customers, i.e. throughout the term of the agreement between you and Ligula. Your personal data will be stored for a maximum of two years after the customer relationship and agreement have terminated. If you contact Ligula, but do not enter into an agreement, your personal data will be stored for a maximum period of 24 months. Such processing takes place on the basis of a balance of interests where Ligula has a legitimate interest in saving your details to facilitate further contact.
6. Which personal data is processed
Ligula only processes your personal data which is relevant for the purpose or purposes for which data is collected. Data that may be collected are, for example, details of name, address, phone number, e-mail address, selected language, user history, travel company details, booking preferences, payments, occupation, special dietary requirements, requirement for disabled facilities.
7. Purposes for which personal data is processed
Ligula collects personal data for various purposes. Which personal data is collected and how it is collected depends on how you contact us and what services you use.
Ligula uses personal data to:
- administer, provide, develop and maintain the hotel services Ligula offers under its trade names,
- process your bookings and orders,
- contact you via SMS, mobile apps or e-mail to notify you of your booking status or information relating to your booking before, during and after your stay,
- diagnose errors, optimize booking technology and to contact you in the event of any problems with a booking or the performance of services that Ligula provides.
Personal data which is processed in accordance with the above purposes may be processed primarily in consideration of what is necessary in order to fulfill agreements to which you are party and to implement measures at your request before such an agreement is reached. If personal data is processed beyond this (even if this is necessary in order to fulfill agreements), such processing may be based primarily on a balance of interests where Ligula has identified a purpose relating to a legitimate interest for which processing of personal data is necessary and where, after careful consideration, Ligula has found that interests or basic rights and freedoms do not override in the context and require the protection of personal data.
In accordance with applicable privacy legislation, Ligula is required to request your consent to:
- personalize communication with you regarding our services, for example by creating a profile for you and sending offers that match your profile as a user of the services that Ligula provides,
- analyze statistics and user behavior in relation to the services that Ligula provides,
- increase your benefits and experience of our services in other ways that we think you would appreciate or
- market services and products, directly or indirectly.
8. Where Ligula stores and sends your personal data
Ligula uses sub-contractors, for example, to manage its IT system, and personal data may therefore be transferred to or via these sub-contractors. Our sub-contractors process your personal data only on behalf of Ligula in accordance with our instructions and only after they have signed a data processor agreement in accordance with applicable legislation in order that Ligula can ensure an appropriate level of protection for your personal data. When your personal data is shared with data processors, this will only be for purposes compatible with the purpose for which Ligula has collected the data. Ligula checks all data processors to ensure they are able to provide sufficient guarantees regarding security and confidentiality.
9. Protection and sorting of Personal data
Ligula has implemented appropriate technical and organizational measures to protect your personal data against loss, manipulation or unauthorized access. Ligula adapts its security measures on a ongoing basis in line with continuous technical developments.
Ligula uses IT systems to protect access to personal data. We have implemented special security measures to protect your personal data against unauthorized processing. Only those persons who actually need to process your personal data in order for us to fulfill our stated purpose will have access to such data.
10. Other applications/websites
11. Correcting, restricting and viewing your personal data
Ligula will correct, restrict or delete inaccurate or incomplete personal data at your request or if Ligula discovers such data.
You are entitled to object specifically to the processing of your personal data for direct marketing purposes.
You are also entitled to request free of charge details of which of your personal data is processed. Subject access requests can be made in writing to Ligula Hospitality Group AB, Södra vägen 12, 5 tr, 412 54, GOTHENBURG, Sweden. Tel.: +46 (0)31-80 40 55. E-mail: email@example.com and must include details of your name, address, phone number, e-mail address (which is used to communicate with Ligula). The information will be sent to your officially registered address within one month of Ligula receiving your request.
You may withdraw your consent to further processing of your Personal Data at any time by contacting Ligula at Ligula Hospitality Group AB, Södra vägen 12, 5 tr, 412 53 GOTHENBURG, Sweden, E-mail: firstname.lastname@example.org. Ligula will then prevent such data from being processed any further. Please note that withdrawal of consent will not affect processing that has already taken place or processing that does not require consent.
If Ligula’s right to process your personal data is based either on your consent or the performance of an agreement with you, you will be entitled to request that data relating to you and which you have disclosed to Ligula is transferred to another data controller, or disclosed in a generally used machine-readable format (‘data portability’).
In some cases, Ligula may be entitled to deny your request if there are legal or contractual obligations, or legal claims, preventing us from deleting certain personal data. If Ligula is prevented from acceding to a request for deletion, Ligula will block personal data to prevent it from being used for purposes other than as required above.
14. Contact and complaints
If you have any questions regarding Ligula’s processing of personal data, please contact email@example.com.
If you wish to make a complaint: f you believe a company is in breach of privacy legislation, please contact the Swedish Data Protection Authority (regulatory authority). Read more at www.datainspektionen.se/in-english/about-us/. Phone: +46 (0)8-657 61 00.