Privacy policy at Greenland by Topas

Privacy Policy at Greenland by Topas

This Privacy Policy has been established by Topas Travel and Greenland by Topas (collectively referred to as "Topas", "we", "us" or "our" in this Privacy Policy) and applies to all of our customers, suppliers and partners.

1. About Greenland by Topas

Greenland by Topas is a division of the travel agency Topas Travel, which develops, sells and conducts trips to Greenland, offering authentic experiences with respect for culture, nature and the environment.

As part of its business, Greenland by Topas collects and processes personal information for the purposes set out in this Privacy Policy. Greenland by Topas is the data controller in relation to the processing of personal data for these purposes.

If you have any questions about this Privacy Policy or our processing of your personal information, please contact us here:

Greenland by Topas
C/o Topas Travel
Bakkelyvej 2
8680 Ry
Denmark 

Email: greenland@topas.dk 

2. Data security is important to us

For us, responsible handling of personal information collected as part of the operation of our business, is crucial to our business goals and reputation. This Privacy Policy explains how your personal information is collected and used when you are a customer, supplier or partner at Greenland by Topas and how you can access your own personal data.

3. What is personal information?

Personal information is any information about an identified or identifiable natural person. An identifiable natural person means a person who can be directly or indirectly identified, inter alia by an identification number or one or more elements specific to a given person's identity.

4. What type of personal data do we process about you and why?

The information we collect about you will be used for various purposes in connection with your customer relationship and the operation of our business. The information collected may vary depending on whether you are a customer, supplier or business partner, but generally it will include information about customer management, supplier management and information about Greenland by Topas' rights and obligations.

Failure to provide personal information on your part may mean that Greenland by Topas will be unable to fulfil its obligations regarding your customer or supplier relationship.

Greenland by Topas generally collects and processes ordinary personal data only. However, in specific cases when booking a trip, we may need to process sensitive personal information to a limited extent (e.g., information regarding special menus on your flight or information on the need for special assistance on your trip) in order to provide the required travel for you.

4.1 Information regarding our customers

Greenland by Topas will typically collect / process the following information about our customers solely on the basis of information that you provide to us when you book a trip or request an offer, for example online through the website or by contacting us via mail or telephone. The following information may be collected: contact information (first name, middle name(s), last name, address, telephone number, email address and any position), bank details, debit card information, information that you give us in relation to your specific preferences on the journey (E.g., information on special diet, need for special assistance in case of illness or similar), health information (if this is a knowledge you want us to have) height information, (for use in connection with seating on the aircraft), size of clothing (for use ordering seal skin clothing) the purpose of the trip, information about which languages you speak, citizenship, contact information for your insurance company, information you provide us with your preferences in relation to marketing or communication, as well as information that you provide to us if you contact us with a question, to report a problem, or when you contact us in connection with your customer relationship with us.

4.2 Information about our suppliers and partners

Information you provide to us in connection with the conclusion of a supply or collaboration agreement, including contact information (work, job title, first name, middle name(s), surname, address, telephone number and email address), information that you provide to us regarding your preferences in relation to marketing or communication, as well as information that you provide to us if you contact us with a question to report a problem or when you contact us as part of our cooperation.

5. What do we use your personal information for?

Greenland by Topas processes your personal information for the purposes set out below. Please note that not all of the stated purposes, categories of information, recipients of information or types of information processing apply to you in all cases.

Greenland by Topas processes your personal data only to the extent necessary in connection with your customer, supplier or cooperation relationship (taking into account any interests in each case) or in accordance with applicable law.

5.1 Customer Management

Greenland by Topas processes your personal information in connection with the establishment and ongoing administration of your customer relationship with Greenland by Topas as part of the operation of our company, including booking travel and delivery of our other products (such as cancellation insurance, transfer services, participation in lectures, etc.), maintaining our customer records, billing, debt collection, marketing, statistics, etc. We store information about our customers' travel destinations, which can be viewed by logging into www.mytopastravel.greenlandbytopas.com, in order to be able to advise our customers in the best possible way and at the same time provide a service where our customers can access their travel history. All statistics and analyses are compiled in anonymised format and therefore do not contain information directly attributable to you as a person.

5.2 Managing supplier and collaboration relationships

Greenland by Topas processes your personal information in connection with the management of supplier and/or collaboration relationships where you are a supplier or partner or contact person of a supplier or a partner with whom Greenland by Topas works with us in the operation of our company, including maintaining our CRM register with information about our contacts with our suppliers and partners.

5.3 Compliance with applicable laws and regulations

Greenland by Topas processes your personal information in connection with compliance with laws and regulations that Greenland by Topas is subject to in connection with the operation of the business or to fulfil various reporting or disclosure obligations under applicable laws and regulations.

Greenland by Topas does not use your personal information to make decisions based solely on automatic processing, including profiling.

Greenland by Topas strives to ensure that all personal information we process is accurate and up to date. We therefore ask you to always notify us of any changes in your personal circumstances (E.g., change of address) so that we can ensure your personal information is always correct and up to date.

6. Legal basis for processing your personal data

Greenland by Topas basically processes the information about you on one of the following grounds: (1) entering into or fulfilling your contract / purchase of travel with Greenland by Topas, (2) the consideration of Greenland by Topas legitimate interests, i.e., the purposes described above, (3) your consent, (4) the fulfilment of a legal obligation imposed by Greenland by Topas, (5) the protection of your or another natural person's vital interests, (6) the processing required, in order for a legal claim to be established, enforced or defended, and (7) the treatment is necessary to comply with Greenland by Topas or your labour, health and social legal obligations under national or EU law. In addition, there may be situations where we process your personal data for the sake of the legitimate interests of third parties for the purposes described above, unless the consideration of your interests weigh more heavily.

7. Sharing of personal data

Greenland by Topas will only disclose the information to the extent necessary as part of the operation of our company, including to be able to deliver your travel as well as the other products you have purchased from us in connection therewith.

Greenland by Topas will typically disclose personal information to the following recipients in connection with booking a trip and related products:

7.1 Global Distribution Systems (GDS)

A GDS is an IT network system owned or operated by a company that enables transactions between the travel industry's service providers, mainly airlines, hotels, car rental companies and travel agencies. A GDS connects services, prices and booking by consolidating products across the three travel sectors, i.e., flight reservations, hotel reservations and car rentals.

Greenland by Topas uses the following GDSs as part of our business: Amadeus

7.2 Airlines

Greenland by Topas discloses personal information to airlines in connection with booking your trip. For the purpose of booking your flight, we will typically pass on information about first name, middle name(s), surname, departure airport, destination, date of departure and return, special requests in connection with your trip, including ordering special menus during the flight and any special assistance required on the plane or at the airport of the chosen airline.

In addition, when travelling to special destinations, we may disclose information about your passport number to the airline.

7.3 Hotels

Greenland by Topas discloses personal information to the hotels you must use on your trip. For the purpose of booking your hotel accommodations, we will typically provide information about first name, middle name(s), last name, destination, date of arrival and departure, room category and name of any fellow travellers, as well as special wishes in connection with your trip, including any special needs to be met during your hotel stay.

7.4 Bus companies

Greenland by Topas discloses personal information to bus companies when used as part of the trip you purchased. For the purpose of booking the bus journey, we will in some cases provide information about first name, middle name(s), surname, pick-up location, date and time of the bus journey, as well as destination.

7.5 Shipping companies

Greenland by Topas discloses personal information to shipping companies if you are going on a ship trip as part of your journey. For the purpose of booking your ship journey, we will typically pass on information about first name, middle name(s), last name, destination, itinerary, date and time of departure and return, and any special wishes in connection with the voyage. Certain destinations also require information about your passport number, which will then be forwarded.

7.6 Travel Agents

If you need to participate in excursions or need a transfer as part of your trip, Greenland by Topas may disclose personal information to travel agents. These persons have the task of arranging the excursions or transfers concerned by ordering the desired services from local suppliers at the destination. For the purpose of booking your excursions, transfers, etc., we typically provide information about first name, middle name(s), last name, date and time of arrival and/or departure, destination and special requests related to the transfer or excursion - including booking of special menus.

8. International transfers of your personal data

Due to the nature of Topas' business, your personal data will be transferable to countries outside the EU / EEA when booking a trip with us. In order to provide our services to you, in some cases we need to use partners and suppliers outside the EU / EEA.

Without the possibility of transferring your information to recipients outside the EU / EEA, Topas will be unable to provide the desired journey to you. This applies if booking your travel requires transfer of information to recipients outside the EU / EEA, e.g., to be able to book flights, hotels, etc. at your travel destination.

Data protection legislation in these countries may be more lenient than it is in Denmark and the rest of the EU / EEA, since in most cases these will be countries where the EU Commission has assessed that the level of data protection is not at the level of data protection within EU / EEA.

Where practicable for us, the transfer of your personal data will take place on the basis of the standard transfer contracts drawn up by the European Commission specially designed for this purpose. As far as transfers to the US are concerned, these will, as far as possible, be done on the basis of Privacy Shield. Privacy Shield is an agreement between the EU and the US, which stipulates, among other things, a strong set of data protection rules and security measures that US companies joining the scheme are required to comply with when processing personal data.

However, in some cases Topas will not be able to enter into a standard transfer contract or use Privacy Shield as a legal transfer basis. In such cases, the transfer of the information will take place on the basis of Article 49 (1) (b) of the Data Protection Regulation, as the transfer of your personal data to that country is necessary for the purpose of fulfilling the contract between you and Topas (booking your trip) or for the sake of to implement measures taken at your request prior to the conclusion of such a contract.

It is therefore important to note that the transfer of your personal data to non-EU / EEA countries when booking a trip with Topas means that your personal data will not enjoy the same protection as under Danish or EU- legal rules.

When transmitting the information, there is an inherent risk that, in that country, there are no clear, precise and accessible rules on the access of your country's authorities to the use of your personal data; that there are no rules requiring access by your country's authorities to your information and proportionality; that the country does not have an independent and effective supervisory authority, and that the country does not have available and effective remedies for the data subjects.

If you do not want Topas to send your personal information to recipients outside the EU / EEA when booking your travel(s), please inform us at the latest when booking your trip.

Topas will in no case disclose your personal information to recipients outside the EU / EEA, unless this is necessary in order to carry out our business and fulfil your needs by, for example, providing the desired journey to you.

9. Data integrity and security

Personal information is kept by Greenland by Topas to fulfil the purpose for which it was collected, including the storage necessary to comply with national legal requirements, including statutory retention periods in connection with bookkeeping, etc.

It is Greenland by Topas' policy to protect personal data by taking adequate technical and organisational security measures. We store information about our customers' travel destinations, which can be viewed by logging into www.minrejse.topas.dk , in order to be able to advise our customers in the best possible way and at the same time provide a service where our customers can access their travel history.

10. Your rights

You have the right to assert your rights at any time under applicable data protection laws. You may, among other things, request access to the personal data held by Greenland by Topas and object to the processing of the information, including objecting to automated decisions and profiling or to the use of your personal data for direct marketing. In addition, you may request correction or deletion of any incorrect information about yourself, anonymisation of older travel history, withdraw consent to process your personal data, and assert your right to data portability.

If you wish to exercise one or more of your rights, please contact us at greenland@topas.dk . Your request will be processed in accordance with applicable data protection laws at all times.

Complaints about Greenland by Topas' processing of your personal data may be made to:

Data Protection Agency
Borgergade 28, 5.
1300 Copenhagen K
Denmark

E-mail: dt@datatilsynet.dk

11. Updates

Topas Travel is continuously evaluating and updating this Privacy Policy. Therefore, you should regularly check this Privacy Policy for any changes that may affect our processing of your personal information.

Last updated 18th May 2018