Personal data policy
Springtime resors Website Privacy Policy
1. introduction
Springtime Group AB (“Springtime“) is the data controller for the processing of personal data in connection with the ordering of travel and related services as well as the subscription to Springtime’s digital newsletter via the website www.springtime.se (the “Website“).
This privacy policy is intended to ensure that you, as a user of the Website, feel confident that Springtime, as a data controller, handles your data in accordance with applicable privacy legislation, including the General Data Protection Regulation (Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016).
We take all appropriate technical and organisational security measures necessary to protect your personal data against unauthorised access, alteration or destruction.
If you have any questions, please do not hesitate to contact us.
2. Data controller
Data controller: Springtime Group AB
Organisationsnummer: 559056-0677
Address: Gustavslundsvägen 151E
167 51 Bromma, Sweden
Telephone: Patrik Yderberg, +46 (8) 545 535 40
E-mail: personuppgifter@springtimegroup.se
3. when do we use your personal data?
“Personal data” means any information relating directly or indirectly to a natural person who is alive. “Sensitive personal data” means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and personal data concerning health or sex life.
Springtime processes your personal data when you:
- Ordering any of Springtime’s travel/services on the Website; and
- Consent to the processing of your personal data for marketing purposes (sending of newsletters).
4. How and what personal data do we use?
Below, Springtime has summarised the personal data processed in the context of the Website, for what purposes and on what legal basis.
| DELIVERY OF SPRINGTIME TRAVEL | |||
| Legal basis | Purpose of the processing | Categories of personal data | Retention period of the personal data |
| Fulfilment of the contract(Delivery of the journey) | Deliver and customise trips you book on the Website.Manage payment for trips you book on the Website. | Personal and contact information:– Name- Address- E-mail- Phone number- Payment history- User details from My Pages. | Stored for a maximum of 1 year and deleted 2 months after the end of the journey. |
| Consent | Customise our trips to your specific needs, for example inform airlines of any allergies. | Sensitive personal dataHealth information:– Allergies, if any- Pregnancy, if any- Disability, if any, requiring support services during the journey. | Stored for a maximum of 1 year and deleted 2 months after the end of the journey. |
| Legal obligation(Accounting) | Recording the payment and accounting of travel bookings. | Personal and contact information:– Name- Address- Email- Phone number- Payment history- Order history | Stored for a maximum of 7 years, deleted after fulfilment of obligations arising from applicable accounting and bookkeeping laws |
| DISTRIBUTION OF THE SPRINGTIME DIGITAL NEWSLETTER | |||
| Legal basis for processing | Purpose of the processing | Categories of personal data | Retention period of the personal data |
| Consent | Send digital newsletters with information on new trips, products and services. | Personal and contact details:– E-mail | Stored for the duration of your consent to the processing.Deleted after consent is withdrawn. |
5. More about Personal Data Processing in the delivery of our trips
If you do not provide your personal data when booking a trip, Springtime will not be able to fulfil its contractual obligations to you or deliver the trips you book from us.
Unless you have given your consent for us to process your personal data for marketing purposes and have only provided your personal data to book a trip, your personal data will not be used for any other purpose.
For more information on how Springtime processes your personal data in connection with the sending of newsletters, see section 6 below.
5.1 Who we may share your personal data with
In order for us to be able to deliver our travel packages and services to you after you have placed your order, we cooperate with other actors such as airlines, travel agencies, local hotels and event organisers (“Partners“). Your personal data may be transferred to our Partners. Please note that the Partner to which your personal data will be transferred depends on the type of travel you have booked. Some of our Partners are: Thomas Cook and local hotels. Springtime has entered into processing agreements with all of our Partners and fulfils the requirements of the Data Protection Regulation.
Furthermore, we will transfer your personal data to third parties who provide the solution for the Springtime administration system.
5.2 Sensitive personal data
In order to be able to inform our Partners about any special arrangements for your trip, we will, with your consent, process information about any allergies, pregnancy and/or disability.
You do not need to provide this information when you book a trip, but if you want us to customise the trips according to your needs, we need your consent to process this personal data. Please note that you can always contact our Partners directly and provide any sensitive personal data needed to customise the trip if you do not consent to us processing this sensitive personal data.
5.3 How long do we keep your personal data?
Personal data that is necessary to deliver trips that you have ordered from Springtime, such as information about departure date, name and address is deleted by Springtime 2 months after you have completed your trip and stored for a maximum period of 1 year. We will immediately delete any sensitive personal data within 2 months after you have completed your trip. The reason why Springtime saves this information for up to 2 years after completion of the trip is to ensure that your rights under the Package Travel Act (1992: 1672) regarding complaints can be exercised. The decision to delete this personal data after 2 months is based on the General Complaints Board’s decision (ARN 1993/94 ref. 34) where the Board considered that a complaint made after 2 months after the traveller’s return home was made “within a reasonable time”.
However, personal data needed to fulfil contractual obligations to our Partners and legal obligations (e.g. the Accounting Act) will be stored for as long as they are needed to fulfil the obligation in question.
If you have only provided personal data to book our trips and have not consented to us using your personal data for marketing purposes, we will delete the personal data immediately after our obligations (by law or contract) have been fulfilled.
5.4 Transfers to non-EU/EEA countries
We always endeavour to process your personal data within the EU/EEA. All our own IT systems are located in the EU/EEA.
When you book a trip with us, your personal data may be transferred to a country outside the EU/EEA. For each such transfer, we will ensure that the transfer is compatible with the provisions of the Data Protection Regulation by, among other things, entering into an assistance agreement.
6. More about the processing of personal data in connection with the distribution of the Springtime digital newsletter
The personal data we process to send you Springtime’s newsletters and to send you marketing only includes your e-mail address.
6.1 Who we may share your personal data with
For marketing purposes, your email address will only be transferred to our provider who provides the solution for sending newsletters.
6.2 How long do we keep your personal data?
The e-mail address that Springtime processes for sending Springtime’s newsletters is saved as long as you consent to us sending you newsletters.
WITHDRAW CONSENT
You can withdraw your consent to our processing of your e-mail address for the purpose of sending you the Springtime newsletter at any time by sending an e-mail to: info@springtime.se
You can also withdraw your consent by visiting us in person at:
Gustavslundsvägen 34, 1 tr
167 51 Bromma
Sweden
6.3 Transfers to non-EU/EEA countries
We always endeavour to process your personal data within the EU/EEA. When processing your personal data for marketing purposes (newsletters), your personal data will be transferred to a country outside the EU/EEA. For each such transfer, we will ensure that the transfer complies with the provisions of the General Data Protection Regulation by, among other things, entering into an assistance agreement.
7. your rights
You always have the right to:
You have the right to lodge a complaint regarding the processing with the Data Protection Authority or another competent supervisory authority in the EU.
Get access to your personal data. You can request a copy of the data you would like and verify the information we hold about you. A copy is free to request.
obtain rectification of inaccurate or incomplete personal data
Have your data deleted in certain cases, for example if your personal data is no longer necessary for the purposes for which it was collected.
Obtain restriction of processing of your personal data in certain cases – e.g. if you have objected to the processing of your personal data carried out on the basis of a balancing of interests – while we check whether our reasons outweigh your interests, rights and freedoms.
Obtain and transfer personal data to another controller in certain cases (data portability).
You have the right to object to the processing of your personal data based on a balance of interests. In such a case, the continued processing of your personal data requires that we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms or if it is for the establishment, exercise or defence of legal claims.