Effective from May 25, 2018
Table of Contents
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- Introduction
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- What is personal data and what does the processing of personal data entail?
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- To whom does this policy apply?
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- What does this policy cover?
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- What does it mean to be a data controller?
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- Operakällaren AB as Data Controller
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- Why are we permitted to process personal data?
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- What personal data do we collect?
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- How long do we retain personal data?
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- Our measures to protect your personal data
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- When do we share personal data?
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- Your Rights
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- Changes to this Policy
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- Contact
1. Introduction
Thank you for choosing Operakällaren AB, and a special thank you for taking the time to carefully read this Privacy Policy. We would like to begin with a brief summary explaining why we have created this policy. Our fundamental goal is to clearly and comprehensibly
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- explain the roles that you and we have in this context
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- explain how we use the information you share with us to enable us to deliver and continuously develop Sweden's best hotel experience;
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- ensure that you understand what information we collect and what we actually do with it;
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- demonstrate how we work to protect your rights and your privacy.
Our objective is that, after reading this policy, you will feel confident that your personal privacy is respected and that your personal data is processed correctly. Therefore, we also continuously work to ensure that our processing of personal data fully complies with current legislation, primarily the new General Data Protection Regulation (GDPR), which has been in effect since May 25, 2018.
2. What is personal data and what does the processing of personal data entail?
2.1 Personal data refers to all information that can be linked directly, or indirectly in combination with other data, to a living physical person. A non-exhaustive list of examples of personal data includes:
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- Name
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- Personal identification number
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- Credit card number
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- Email address
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- IP address
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- Images
2.2 The processing of personal data includes every action taken with personal data, regardless of whether it is performed automatically or not. This means that, among others, the following actions are covered:
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- Collection
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- Registration
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- Use
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- Combination
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- Transfer
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- Deletion
3. To whom does this policy apply?
This Privacy Policy primarily applies to individuals who stay at our hotel and whose personal data we process (the 'Data Subject'). Different parts of this Privacy Policy may also be relevant to you depending on your relationship with Operakällaren AB. In summary, this policy applies to individuals who
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- are guests at our hotel
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- dine at our restaurant
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- organize meetings or events in our venues
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- when you visit our website or interact with us on social media
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- when you communicate with us through other channels, such as our customer service
By accepting this Privacy Policy, you consent to Operakällaren AB processing your personal data in accordance with its terms.
4. What does this policy cover?
This Privacy Policy outlines how Operakällaren AB collects and processes personal data to deliver and continuously enhance our Services.
5. What does it mean to be a Data Controller?
A Data Controller is an individual, legal entity, or other body that determines the purposes and means of processing personal data. A company acts as a Data Controller for the personal data it holds concerning its employees, customers, suppliers, and other relevant parties.
6. Operakällaren AB as the Data Controller
Operakällaren AB (Org. No. 556031-3974) is the Data Controller responsible for processing your personal data within the scope of Operakällaren AB's Services, ensuring that such processing complies with applicable legislation.
7. Why are we permitted to process personal data? 7.1 For personal data processing to be permissible, there must always be a basis in GDPR, known as a legal ground. Such legal grounds include, but are not limited to:
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- consent from the Data Subject
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- that the processing of personal data is necessary to fulfill a contract with the data subject, for instance, an agreement concerning the use of the Services
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- to comply with a legal obligation, such as retaining data due to accounting requirements
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- that following a balancing of interests, it is determined that Operakällaren AB's interest in processing personal data outweighs the data subject's interest in its protection.
7.2 Operakällaren AB always processes your personal data in compliance with applicable legislation. Our primary legal basis for processing your personal data is its necessity for fulfilling our agreement with you concerning the use of our services.
7.3 It is possible for the same personal data to be processed under multiple legal grounds, such as the fulfillment of a contract, specific consent, or the necessity to comply with other legal obligations. This implies that even if you withdraw your consent, and the processing based on that consent ceases, the personal data may still be retained by us for other legitimate purposes.
8. What personal data do we collect?
In this section of our policy, we aim to provide examples of how we manage personal data to ensure we consistently deliver exceptional experiences with a high standard of service.
8.1 When you book a room at our hotel
When you book a room at our hotel, whether the reservation is made at the hotel reception, by phone, via email, or through https://www.operakallaren.se, we process the following information that you provide to us:
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- Your name and contact information (phone number, email address)
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- Credit card number and other payment details
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- Your name and contact information (phone number, email address)
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- Your name and contact information (phone number, email address)
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- Your name and contact information (phone number, email address)
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- Information regarding your inquiry, feedback, or specific matter
8.1.1 We process your personal data for the following purposes:
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- To identify you in connection with your booking and stay at Operakällaren AB
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- Charge you for the services and products you have purchased from us
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- Contact you with information regarding your stay, for example, via email and SMS
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- Generate statistics and conduct analyses to improve our Services, goods, and offers
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- Provide, maintain, test, improve, and develop our Services and the technical platform used to deliver them
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- Ensure the security of our Services, to detect or prevent various types of illegal use or use that otherwise violates our terms of service
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- Inform you about personal and customized offers, campaigns, and benefits from us and our partners, for example, via email and SMS
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- Identify you in connection with your booking and restaurant experience at our restaurants
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- Charge you for the services and products you have purchased from us
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- Contact you with information regarding your stay, for example, via email and SMS
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- Generate statistics and conduct analyses to improve our Services, goods, and offers
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- Provide, maintain, test, improve, and develop our Services and the technical platform used to deliver them
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- Ensure the security of our Services, to detect or prevent various types of illegal use or use that otherwise violates our terms of service
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- Inform you about personal and customized offers, campaigns, and benefits from us and our partners, for example, via email and SMS
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- Identify you in connection with your booking and your experience at our hotel
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- Charge you for the services and products you have purchased from us
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- Contact you with information regarding your booking, for example, via email and SMS
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- Generate statistics and conduct analyses to improve our Services, goods, and offers
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- Provide, maintain, test, improve, and develop our Services and the technical platform used to deliver them
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- Ensure the security of our Services, to detect or prevent various types of illegal use or use that otherwise violates our terms of service
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- Inform you about personal and customized offers, campaigns, and benefits from us and our partners, for example, via email and SMS
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- Answer your questions and manage your case, for instance, by rectifying errors and handling complaints
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- Improve our Services and the information we communicate through our various channels
8.1.2 Legal basis for processing:
We process your personal data based on the fulfillment of a contract when we meet our obligations to you as a hotel guest (e.g., when we administer services related to your hotel room and provide relevant offers), and based on a balancing of interests when we have a legitimate interest in using data about your stays and purchases to generate statistics and to develop, improve, and ensure the security of our Services.
8.1.3 Storage period:
We store your personal data during your hotel stay and for up to 3 months thereafter. To ensure traceability, we store information about our communication with you for 12 months. Your hotel history is stored for up to 2 years based on our legitimate interest in analyzing trends over time.
8.2 When you book a table at our restaurants
When you book a table to dine at our restaurants, whether the booking is made inside the restaurant, by phone, via email, or at https://www.operakallaren.se, we process the following information that you provide to us:
8.2.1 We process your personal data to:
8.2.2 Legal basis for processing:
We process your personal data based on the fulfillment of a contract when we meet our obligations to you as a restaurant guest (e.g., when we administer services related to your table booking and provide relevant offers), and based on a balancing of interests when we have a legitimate interest in using data about your visits and purchases to generate statistics and to develop, improve, and ensure the security of our Services.
8.2.3 Storage period:
We store your personal data for up to 3 months after your restaurant visit. To ensure traceability, we store information about our communication with you for up to 12 months. Your visit history is stored for up to 2 years based on our legitimate interest in analyzing trends over time.
8.3 When you book our meeting and event venues
When you book any of our excellent meeting or event venues, whether the booking is made at the hotel reception, by phone, via email, or at https://www.operakallaren.se, we process the following information that you provide to us:
8.3.1 We process your personal data to:
8.3.2 Legal basis for processing:
We process your personal data based on the fulfillment of a contract when we meet our obligations to you as a visitor (for example, when we manage services related to your meeting or event booking and provide relevant offers). We also process data based on a legitimate interest assessment when we have a valid reason to use information about your stay and purchases to generate statistics and to develop, enhance, and ensure the security of our Services.
8.3.3 Storage period:
We store your personal data for up to 3 months following your visit. To ensure traceability, we retain information about our communication with you for 12 months. Your visit history is kept for up to 2 years, as part of our legitimate interest in analyzing trends over time.
8.4 When you communicate with us
You have the option to communicate with us through various channels, such as our social media accounts or by contacting our customer service via phone or email.
When you communicate with us, particularly during a booking, we process the following information that you provide:
8.4.1 We process your personal data to:
8.4.2 Legal basis for processing:
We process your personal data based on our shared legitimate interest in managing your inquiry (legitimate interest assessment).
8.4.3 Storage period:
To ensure traceability, we store information about our communication with you for 12 months.
8.5 When you use our Wi-Fi or visit our website
When you connect to our Wi-Fi, we act as the data controller for the processing required to connect you to the internet. However, we are not responsible for any subsequent data processing or the content of your communication over Wi-Fi. When you connect to our Wi-Fi, we process:
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- Your IP address and MAC address
When you visit our website, we process:
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- Information regarding your interaction with and use of our website, such as when booking a hotel room.
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- Information about your visits to our website, collected through cookies. For more details on our use of cookies, please refer to https://www.operakallaren.se/c…
8.5.1 We process your personal data to:
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- Provide our digital services
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- Provide you with support when you encounter technical issues.
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- Maintain, test, and improve our digital services
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- Detect and prevent security threats, such as virus attacks.
8.5.2 Legal basis for processing:
We process your personal data based on the fulfillment of a contract when providing Wi-Fi, and based on a legitimate interest assessment for our legitimate interests in maintaining, testing, and enhancing our digital services.
8.5.3 Storage period:
We store your personal data for 3 months after you have used our digital channels and for 6 months from the date you connected to our Wi-Fi.
9. How long do we store personal data?
Your personal data is stored only for the period necessary to fulfill the purposes for which the data was collected, in accordance with this Privacy Policy. Operakällaren AB may store the data for a longer period if required to comply with legal obligations or to protect Operakällaren AB's legal interests, for example, if there is an ongoing legal process.
10. Our measures to protect your personal data
10.1 At Operakällaren AB, we have ensured that appropriate technical and organizational measures have been taken to protect your personal data against loss, misuse, and unauthorized access, among other things.
10.2 To technically ensure that personal data is processed securely and confidentially, we utilize digital networks protected against intrusion through measures such as encryption, firewalls, and password protection. In the event of an intrusion, Operakällaren AB has established robust procedures for identification, damage minimization, and reporting. Furthermore, Operakällaren AB has developed an effective method to uphold the rights of the data subject, including the right to be forgotten.
10.3 To ensure a high level of knowledge regarding personal data processing, ongoing GDPR training is provided for both Operakällaren AB employees and the consultants periodically engaged to perform assignments for the company.
11. When do we share personal data?
11.1 Operakällaren AB will not sell, disclose, or disseminate personal data to third parties, except as specified in this Privacy Policy. Within the scope of the Services, personal data may be transferred to subcontractors and partners, for example, if necessary for the performance and provision of the company's services. In cases where we choose to share personal data, we enter into a data processing agreement to ensure that the recipient processes this data in accordance with applicable legislation and that the recipient has implemented the necessary technical and organizational measures under GDPR to adequately protect the rights and freedoms of the data subject.
11.2 Furthermore, we may disclose personal data if we are required to do so by applicable law, court order, or if such disclosure is otherwise necessary to cooperate with a legal investigation.
12. Your Rights
12.1 Operakällaren AB is responsible for ensuring that your personal data is processed in accordance with applicable legislation.
12.2 Upon your request or on its own initiative, Operakällaren AB will correct, anonymize, delete, or supplement data found to be inaccurate, incomplete, or misleading.
12.3 You have the right to request access to your personal data. This means you have the right to request an extract from the register regarding the processing we carry out concerning your personal data. You also have the right to receive a copy of the personal data being processed. Once per calendar year, you have the right to obtain, free of charge, a register extract via a written and signed application, detailing what personal data is registered about you, the purposes of the processing, and to which recipients the data has been or will be disclosed. You also have the right to receive information in the register extract about the anticipated period during which the data will be stored or the criteria used to determine this period.
12.4 You have the right to rectification of your personal data. Upon your request, we will correct any inaccurate or incomplete data we process about you as quickly as possible.
12.5 You have the right to erasure of your personal data. This means you have the right to request that your personal data be deleted if it is no longer necessary for the purpose for which it was collected. However, there may be legal requirements preventing us from immediately deleting your personal data, for example, due to applicable accounting and tax legislation.
12.6 You have the right to object to personal data processing carried out based on a legitimate interest assessment. If you object to such processing, we will only continue the processing if there are compelling legitimate grounds for the processing that outweigh your interests.
12.7 If you do not wish us to process your personal data for direct marketing, you always have the right to object to such processing by either unsubscribing directly in each specific email message or by sending an email to gdpr@operakallaren.se. Once we have received your objection, we will cease processing personal data for such marketing purposes. If you are not satisfied with how we handle your personal data, you also have the option to report our processing of your personal data to the Swedish Data Protection Authority (Datainspektionen). However, for smooth and efficient handling, we recommend that you first contact us so that we can assist you with any questions or concerns.
13. Changes to this Policy
Operakällaren AB reserves the right to revise this Privacy Policy from time to time. The date of the latest change is indicated at the end of the Privacy Policy. If we make any changes to the Privacy Policy, we will publish these changes on the website. You are therefore advised to read this Privacy Policy regularly to be aware of any changes. If we change the Privacy Policy in a way that significantly differs from what was stated when your consent was collected, we will notify you of these changes and, if necessary, ask you to re-consent to Operakällaren AB's personal data processing.
14. Contact
Operakällaren AB (Org. No. 556031-3974) is the data controller responsible for the processing of your personal data. If you require further information on how your personal data is handled, please contact us by sending a written, personally signed request to:
Operakällaren AB
Karl XII:s torg, Box 1690
103 22 Stockholm
In your letter, please provide your name, address, email, telephone number, and personal identification number, in addition to your inquiry. Please also enclose a copy of your identification. A response will be sent to your most recently registered residential address.