Privacy notice

Privacy notice, updated July 1^st 2020

1. Introduction

The purpose of this privacy notice is to provide information on how Navigare Properties (“Navigare” or “we”) process your personal data in connection with our contacts with you as a customer and when we are marketing and informing about our business.

All processing of personal data is carried out in accordance with the European Union’s General Data Protection Regulation (the “GDPR”). This privacy notice describes how we process and use the personal data that we receive from you when using this website and its related services and how you can contact us if you have additional questions regarding our processing of your personal data.

2. Purposes and legal basis for processing your personal data

In the below, we have described which personal data we process about you and for which purposes as well as the applicable legal bases for such processing.

When using our contact form
- What personal data will be processed and why?

When you are using our contact form, we collect and process your name, email address, your request/message and other personal data that you may include in the contact form when you contact us. This personal data helps us to fulfil and administrate your request e.g. provide you with the information requested and answer your questions and concerns.

What is the legal basis for processing your personal data?

The processing of your personal data is based on our legitimate interest to fulfil your request or answer your comments or concerns. When sending a request/message through our contact form it is also in your interest that we can use your personal data to provide you with the information requested. We only process personal data voluntarily provided by you and the personal data necessary to fulfil the purpose. Furthermore, the personal data is not of a sensitive character and is not shared with third parties unless needed to fulfil the described purpose. Based on the abovementioned factors, we have conducted a balancing interest test with the result that we consider to have a legitimate interest that is not outweighed by your interest in not having your personal data processed for the described purpose. You are always entitled to object to this assessment. You can read more about your rights below.

When using our booking service
- What personal data will be processed and why?

When you are using our booking service we collect and process your contact information (e.g. name, address, email address and telephone number), your personal identity number/national security number, passport number, as well as financial information, such as your bank account number. This personal data enables us to process and administrate your request or booking.

To be able to offer you our additional services, we might also collect and process your height, weight and age, in order to e.g. administrate ski rental, as well as your food preferences etc. If relevant, we may also process your travel information (e.g. flight reservations etc.) if you choose to procure such services.

What is the legal basis for processing your personal data?

The processing of your personal data for the above purposes is necessary to enter into and fulfil our agreement with you regarding the requested services. If you do not provide this personal data to us, we will not be able to fulfil our obligations under such agreement and, thus, provide you with the requested services.

When we send you marketing material
- What personal data will be processed and why?

We may collect and process your [name, address, telephone number and email address] to contact you regarding sales and offers or to inform you about upgrades to our services. We may also contact you regarding events that take place at your destination or provide other information that is relevant for your stay. [The marketing will be provided to you via email, SMS and mail.]

What is the legal basis for processing your personal data?

The processing of your personal data for marketing purposes is based on our legitimate interest to market our services and provide information about our business. Marketing is a crucial part of our business and we always strive to provide you with marketing and information that is relevant for you. We find it to be in your interest to receive marketing since you voluntarily expressed interest in our services by contacting us or booking our services It is also in your interest to receive relevant marketing, e.g. information regarding events taking place at your destination. Furthermore, the personal data is of a non-sensitive character and we will not share your personal data with third parties unless necessary to fulfil the purpose. In all marketing material sent to you via [email] and [SMS] there is always a possibility to unsubscribe from further marketing and if you choose to do so, we will stop sending you marketing material by [email] and [SMS].

Based on the abovementioned factors, we have conducted a balancing interest test with the result that we consider to have a legitimate interest that is not outweighed by your interest in not having your personal data processed for the described purpose. You are always entitled to object to this assessment. You can read more about your rights below.

When we conduct profiling
- What personal data will be processed and why?

To provide you with personalised information and marketing offers, we conduct profiling. The profiling entails that we process your personal data, such as the destination of your travel and information about additional services, to adapt and personalise marketing material and information in order to suit your specific needs. By the use of profiling we will be able to offer you personalised information and marketing offers that we find appropriate for you.

What is the legal basis for processing your personal data?

The processing of your personal data for profiling purposes is based on our legitimate interest to design our marketing and information in a way that appeals to you, which we also believe is in your interest. We will not create extensive personal profiles and the processing is conducted manually and, thus, we do not use any system or service provider to compile the personal data. Your personal data will only be processed by us for the described purpose and any third party that gains access to this data will only process it based on our instructions. We always ensure to not use more personal data than needed in order to fulfil the purpose and the personal data is stored securely with limited access.

3. For how long is your personal data stored?

Your personal data will only be stored as long as necessary for the purpose for which it was collected or as long as permitted or required under local law. This means that certain personal data, such as financial information and bookings, will be retained in accordance with applicable accounting laws. Regarding personal data relating to our additional services the personal data will only be stored until the purpose for which it was collected is fulfilled, e.g. when the travel has ended, or longer if you asks us to retain it for a longer time period, e.g. to keep such data for future travels. For other types of personal data, such as your contact information, we will conduct yearly assessments to evaluate if your personal data is necessary for the purpose for which it was collected, however, your personal data will be stored for a maximum period of [●] years after the latest contact with you.

4. Your rights

Navigare Properties AG

Untere Dorfstrasse 54, 3906 SWITZERLAND

CHE- 467.766.534

Email: info@navigare-properties.com,

is the controller of the processing of your personal data. This means that we are responsible for your personal data being processed correctly and in accordance with applicable laws. In the below, we have summarised your rights in relation to the personal data we process about you.

You have the right to know what personal data we are processing about you, and you can request a copy of such data.
You have the right to have incorrect personal data about you corrected, and in some cases you may request that we delete your personal data (g. if your personal data is no longer necessary in order to fulfil the agreement with you).
You have the right to object to certain processing of your personal data, and request that the processing of your personal data be limited. Please note that limitation or deletion of your personal data may result in us not being able to contact you or fulfil our obligations under the agreement with you.
Under certain circumstances you also have the right to extract your personal data in a machine-readable format and to transfer the personal data to another controller.
If you have given your consent to processing of your personal data for an explicit purpose you may always withdraw your consent.

If you have questions regarding how we process personal data about you, or want to withdraw your consent, you are most welcome to contact us through the contact information stated above.

If you have any objections or complaints about the way we process your personal data, you have the right to file a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at Feldeggweg 1, CH – 3003 Berne or info@edoeb.admin.ch. You may also contact the supervisory authority where you live, the relevant supervisory authorities can be found here: https://www.cnil.fr/en/data-protection-around-the-world.

5. Who has access to your personal data?

We have implemented appropriate technical and organisational measures to protect your personal data against loss, accidental and unlawful access and unauthorised disclosure. The number of persons with access to your personal data is limited. Only individuals associated with Navigare that need to process your personal data in accordance with the purposes presented in this privacy notice have access to your personal data and will be obliged not to use it for any other purpose.

We may share your personal data with other entities within Navigare Group, in order to provide you with our services and relevant information and marketing regarding the business in our group companies.

In addition, we may share your personal data with suppliers and partners that carry out services on our behalf or in other ways collaborate with us, including our IT-providers of our booking system, customer relationship management system and provider of marketing services, our payment acquirer and banks involved in transactions. [These collaboration partners are established in Sweden and the US.]

Your personal data will be transferred to countries outside of EU/EEA, [including the US], which may have a lower level of protection than within the EU/EEA. When transferring personal data to countries outside the EU/EEA, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data. The standard contractual clauses can be found via the following link: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

6. Changes

If any changes are made concerning the processing of your personal data, we will inform you by publishing an updated version of this privacy notice on our webpage, www.navigare-properties.com.