This is Foribon Oy’s/Haltia Lake Lodge’s register and privacy statement in accordance with Personal Data Act (10 and 24 §) and EU’s General Data Protection Regulation (GDPR). Created Jan 24, 2021. Our privacy policy is currently being translated and will be available here soon!

1. Data controller

Foribon Oy/Haltia Lake Lodge, Solvallanrinne 2, 02820 Espoo, Finland Email: info@haltialakelodge.com

2. Contact person responsible for the register

Teemu Tuomarla, teemu.tuomarla@haltialakelodge.com, +358 40 579 7858

3. Register name

Foribon Oy’s/Haltia Lake Lodge’s customer and marketing register

4. The purpose of processing personal data

• The data controller processes personal data for the following purposes: • customer relationship management and development • booking management • payments, payment monitoring, and debt collection • marketing of data controller’s items and services • developing data controller’s business and related customer service • monitoring and analysis of customer interest data and selections and preferences related to accommodation and programme services/activities, and development of related customer service • logging actions and benefits related to our loyalty program • accommodating the preferences of loyalty program customers, customer service development, and targeting our offering • logging benefits for partner businesses in our loyalty program The data is not used for automated decision-making or profiling.

5. Register data content

• The categories of people whose personal data we may process include data controller’s partner, stakeholder and client company contact persons, those considered partners and/or potential customers through the office they hold, and persons that have been in contact with the data controller. The register can include the following personal and organizational data: • customer information: name, date of birth, customer number, contact information (such as phone and mobile phone number, email address or other electronic address information) for the purpose of contacting them, title or profession, language code, gender, nationality, the number of adults and children accompanying the customer during their stay, and invoicing information • customer feedback information: customer satisfaction, comments regarding data controller services, and other information obtained with customer’s consent • booking information • organisation’s locations and their addresses • organisation business ID and revenue • profiling and grouping data (for example, the company’s line of business, and mailing groups) • web addresses • data relevant to customer relationship management • data related to selling marketing services • other additional information provided by customer

6. Regular sources of information

The register’s sources of information include hotel’s booking and invoicing systems (Mews and Fare Harbor), messages collected with online forms, email clients (MailChimp and GuestJoy), phone, social media services, agreements, meetings with customers, and other situations where customers provide their information.

7. Disclosure of personal data and transfers of data out of EU or EEA

The processing of personal data is confidential. Foribon Oy/Haltia Lake Lodge can, however, disclose information as allowed by law when, for example, a third party can offer specific information or advantage to businesses/organization. The data controller can also disclose customers’ personal data to outsiders when required by actions of Finnish authorities. With data subject’s consent, data can be transferred out of EU or the European Economic Area.

8. Register protection principles

The register is processed with care, and all data processed with data systems are appropriately protected. When register data is stored on online servers, the physical and digital security of the hardware is properly addressed. The data controller ensures that stored data, server access, and other information critical to the security of personal data is handled in confidence and only by employees whose job description requires handling said data. The information network and hardware where the register is located are protected with a firewall and other technical measures. Any materials containing personal data are discarded in a way that ensures data security.

9. Right of inspection and right to demand rectification

Every person in the register has the right to review their personal data stored in the register and demand rectification of any inaccuracies or omissions in their data. Should a person want to review or demand correction to their stored personal data, the request should be submitted with a personally signed letter to Haltia Lake Lodge/Tietosuoja, Solvallanrinne 2, 02820 Espoo, Finland. If necessary, the data controller may ask the requester for proof of their identity. The data controller shall respond to the customer within the time period set by EU’s General Data Protection Regulation (generally within one month).

10. Other rights related to processing of personal data

The data subject also has the right to prohibit the data controller from processing their data for the purposes set out in this register policy, unless otherwise agreed between the data controller and the data subject. Correction requests to information concerning marketing opt-outs (phone calls, printed direct marketing, text message, and email) should be submitted with a personally signed letter to Haltia Lake Lodge / Tietosuoja, Solvallanrinne 2, 02820 Espoo, Finland. Apr 21, 2021

ACCESSIBILITY

When designing the accessibility and visual look of the site, we have endeavoured to consider any visual impairments or other limitations a user might have. Our customer service is also happy to help you if you need guidance on using the site or if you prefer to contact us by, for example, phone to make a reservation