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Loyalty Club Privacy Policy

1.                     Introduction

 

We, Stena Line Scandinavia AB, registration number 556231-7825 ("Stena Line"), are  Data Controller for the processing of your personal data. All references to "we", "us" or "our" in this privacy policy refer to Stena Line. Our contact details can be found at the end of this privacy policy. We respect your privacy and are committed to protecting your personal data.

 

Our loyalty clubs, Extra Blue, Extra Gold and Business Traveller are collectively referred to as "Loyalty Club(s)" below.

 

The following websites are referred to as our "Websites":

 

stenaline.se, stenaline.dk, stenaline.no, stenaline.fi, stenaline.pl, stenaline.lv, stenaline.lt, stenaline.ee, stenaline.ru, stenaline.pl, stenaline.cz, stenaline.de, stenaline.nl, stenaline.fr, stenaline.co.uk, stenaline.ie, stenaline.it, stenaline.es, stenalinetravel.com, wyjazdygrupowe.pl, szwecjazklasa.pl, blog.stenaline.se, blog.stenaline.dk, blog.stenaline.no, blog.stenaline.pl, blog.stenaline.co.uk, blog.stenaline.ie, blog.stenaline.nl, blog.stenaline.de.

Our Websites and other means of communication (email, telephone, support contact, social media, chat and paper forms) used by you in connection with membership in a Loyalty Club are referred to below as our "Loyalty Club Services".

 

2.                     Scope of this privacy policy?

 

This privacy policy applies to our processing of your personal data if you are a member of one of our Loyalty Clubs and use our Loyalty Club Services. This privacy policy includes information about the purposes for which we process your personal data, with whom we share it and what rights you have with respect to your personal data.

 

Information about our processing of personal data for other customers and website visitors can be found in Stena Line’s privacy policy for booking customers and website visitors.

 

For information on how we handle cookies, see our cookie policy.

 

For information about our camera surveillance onboard our ships, in our ports, terminals and offices and the processing of personal data in connection with it, see Stena Line’s CCTV privacy policy.

 

3.                     What categories of personal data do we process?

 

Stena Line processes the following categories of personal data:

 

(a)        Name

(b)        Date of birth

(c)        Gender

(d)        Contact details (address, telephone and/or mobile number, email address)

(e)        Loyalty Club membership information - type of membership (Extra Blue, Extra Gold or Business Traveller), membership number, how long you have been a member, how long you have been at the current membership level and membership point balance

(f)         Password

(g)        Transaction history (date, type of transaction, transaction details, points earned)

(h)        Booking history

(i)         Site information based on your IP address

(j)         Browser information (browser version)

(k)        Your employer and position (for business travellers)

 

4.                     Where do we obtain your personal data?

 

 Stena Line collects your personal data directly from you when you sign up as a member of one of our Loyalty Clubs, when you use our Loyalty Club Services, when you book a trip, when you carry out a transaction that earns you member points in a Loyalty Club or when you use member points as payment.

 

Stena Line also collects personal data from travel agents whom you have instructed to provide your personal data to us.

 

5.                     What happens if you do not provide us with your personal data?

 

Membership in a Loyalty Club is of such a nature that you must provide us with the personal data indicated in section 3 above in order to become and remain a member of our Loyalty Clubs. Thus, if you do not provide us with the personal data, we cannot offer you membership in a Loyalty Club.

 

6.                     For what purposes do we process your personal data and what is the legal basis for these processing activities?

 

Stena Line processes your personal data for the purposes set out below. For each purpose, we must have a legal basis. A legal basis may e.g. be (i) that the processing is necessary for the performance of a contract that we have entered into with you, or (ii) that Stena Line or a third party has a legitimate interest in processing the personal data, which is not overridden by your interest in not having the personal data processed. The legal basis on which Stena Line relies is stated under each purpose below.

 

( )         Providing membership in the Extra Loyalty Club

Stena Line uses your name, contact details, Loyalty Club membership information, transaction history and booking history to administer your membership, your earned and used points and your membership level, and to provide you with our agreed Loyalty Club Services as set out in terms of business for the Extra Loyalty Club. This processing of your personal data is based on our contractual obligations towards you.

 

(a)        Providing Business Traveller membership

Stena Line uses your name, contact details, Loyalty Club membership information, transaction history, booking history and details of your employer and position to administer your employer's membership, points earned and used and membership level, and to provide our contracted Loyalty Club Services in accordance with membership agreement for Business Traveller. This processing of your personal data is based on our legitimate interests.

 

(b)        Providing our Loyalty Club Services

Stena Line uses your name, contact details, Loyalty Club membership information and details of your employer and position to communicate with you when you use our Loyalty Club Services. This processing of your personal data is based on our legitimate interests.

 

(c)        Improving our Loyalty Club Services

We use your name, contact information, website information based on your IP address, browser information, Loyalty Club membership information, and transaction history to collect statistics about your use of our Services in order to improve our Loyalty Club Services by fixing bugs, quickly and easily identifying and resolving website conversion issues, modifying the interface so that you can quickly find the information you are looking for, or highlighting relevant offers on the Website. We do this by analysing your use of our Services. Personal data that we use to improve our Loyalty Club Services is aggregated to the extent possible. This processing of your personal data is based on our legitimate interests.

 

(d)        Preventing misuse of Loyalty Club Services

To the extent necessary, we may use names, contact details and membership numbers (as relevant in each specific case) to prevent misuse and fraud. This processing of your personal data is based on our legitimate interests.

 

(e)        Providing offers, discounts and upgrades based on your purchases

We use your name, contact information and Loyalty Club membership information to provide you with offers, discounts and upgrades based on your purchases under your Loyalty Club membership. This processing of your personal data is based on our legitimate interests.

 

(f)         Direct marketing

We use your name, contact information and Loyalty Club membership information, to the extent you have provided such personal data to us when using our Loyalty Club Services, to send you newsletters, offers and relevant information about our Loyalty Club Services. We will send these to you by post, text message, email and other forms of electronic communication. This processing of your personal data is based on our legitimate interests.

You have the right to opt out of direct marketing at any time as described in section 6(f)-(g). If you do so, Stena Line will no longer send you such direct marketing.

 

(g)        Handling complaints and defending and/or establishing legal claims

We use personal data only to the extent relevant in each specific case to handle complaints and defend and/or establish legal claims. This processing is based on our legitimate interests.

 

7.                     Who do we share your personal data with?

 

In order to fulfil the purposes stated above, Stena Line shares your personal data with the following recipients:

 

( )         Stena Rederi AB

(a)        Stena Line Travel Group AB

(b)        Stena Line Ltd.

(c)        Stena Line Irish Sea Ferries Ltd.

(d)        Stena Line BV

(e)        Stena Line GmbH & CO.KG .

(f)         Stena Line Danmark A/S

(g)        Stena Line Polska sp.z o.o.

(h)        UAB Stena Line

(i)         SIA Stena Line

(j)         Advertising and retargeting platforms such as Google and Facebook

(k)        Service providers that we engage to provide services, such as web hosts, mailing houses, analytics companies, IT providers, event hosts, etc.

 

8.                     Do we transfer your personal data outside the EU/EEA area?

 

Stena Line may transfer some of your personal data to the countries listed below which are outside the EU/EEA area. Where the European Commission has not determined that any of the countries below ensure an adequate level of protection for personal data, we will provide a description of the safeguards we take or the legal basis we rely on to ensure that the transfer of your personal data is in accordance with EU data protection laws.

 

Country: UK

Safeguard: adequacy decision (28 June 2021)

 

Country: USA

Safeguard: The European Commission's Standard Contractual Clauses for the Transfer of Personal Data (2010/87/EU) and (2021/915/EU)

Please feel free to contact our Data Protection Officer if you would like more information on the above safeguards. The contact details can be found in section 11 of this privacy policy.

 

9.                     How long do we keep your personal data?

 

Purpose

Type of personal data

Retention period

Providing Extra and/or Business Traveller membership

Name, date of birth, gender, contact details, Loyalty Club membership details, password, transaction and booking history, your employer and position

As long as you are a registered member of a Loyalty Club

 

Improving our Loyalty Club Services

Site information based on your IP address and browser information

For 26 months after you have used our Loyalty Club Services

Handling complaints and defending and/or establishing legal claims

Personal data relevant to assessing complaints against a Loyalty Club or defending and/or establishing legal claims

For as long as your personal data is reasonably needed to defend and/or establish legal claims (normally as long as the relevant legal statute of limitations)

 

10.                  What rights do you have?

 

Below is a summary of your rights under EU data protection law. There is no cost to exercise these rights, and you can do so by sending an email or letter to the addresses listed at the end of this document. You can also use the contact form on the website.

 

As a member of a Loyalty Club, you always have the option to delete or correct the information we hold about you. You can edit your data by clicking on the "My Profile" link once you have logged into the Loyalty Club on the Website. All emails you receive from the Loyalty Club will also contain a link to your personal profile, which you can use if you wish to update it. Please do not hesitate to contact us if you have any questions regarding your rights (see contact details at the end of this document).

 

Stena Line will always assess whether a request to exercise these rights is valid. Not all rights set out below are absolute. There may be exceptions.

 

In addition to the rights set out below, you always have the right to lodge a complaint about Stena Line's processing of your personal data with a supervisory authority.

 

( )         Right of access. You have the right to obtain, upon request, a copy of your personal data processed by Stena Line and also to obtain additional information about Stena Line's processing of your personal data.

 

(a)        Right to rectification. You have the right to have your personal data corrected and/or completed if it is inaccurate or incomplete.

 

(b)        Right to erasure. You have the right to request Stena Line to delete your personal data without undue delay in any of the following circumstances:

 

-       The personal data is no longer needed for the purpose for which it was originally collected or otherwise processed

-       You withdraw your consent to a processing activity for which there is no other legal basis

-       You raise a valid objection to the processing of your personal data

-       The personal data has been processed unlawfully

-       The personal data must be deleted to comply with a legal obligation

 

(c)        Right to restrict processing. You have the right to request restriction of the processing of your personal data in any of the following circumstances:

 

-       The accuracy of the personal data is under investigation

-       The processing is unlawful or no longer needed for its purposes, but you object to the deletion of your personal data and request restriction instead

-       Stena Line no longer needs the personal data, but you need the personal data to establish, exercise or defend a legal claim

-       You have objected to the processing of your personal data and your objection is under investigation

 

(d)        Right to data portability. In certain circumstances, you have the right to receive the personal data about you that you have provided to Stena Line for the purpose of transferring these to another service provider, if the processing of the personal data is based on your consent or the performance of a contract.

 

(e)        General right to object. You have a general right to object at any time to the processing of your personal data based on Stena Line's legitimate interests. We must then show that we have a compelling legal basis for the processing or that we need the personal data to establish, exercise or defend legal claims.

 

(f)         Right to object to direct marketing. You have the right to object at any time to the processing of your personal data for direct marketing purposes. Stena Line may then no longer process your personal data for this purpose.

 

11.                  How can you contact us?

 

You can contact us through the following communication channels:

 

Head Office:

Address: Stena Line Scandinavia AB, 405 19 Gothenburg, Sweden

Telephone: +46 770 - 57 57 00

Email: info.se@stenaline.com

 

Please note! We have appointed a Data Protection Officer whom you can contact if you have any questions about the processing of your personal data. Please feel free to contact our Data Protection Officer at dpo@stenaline.com.