This policy relates to the processing of personal data that V.S. VisitSweden AB or its subsidiaries
or
representation offices in different countries (‘Visit Sweden’ or ‘we’ or independently “Visit
Sweden-company”) obtains: in conjunction with the performance of our services; through you/your
organisation
in its capacity as, for example, our cooperating partner; through visiting our websites www.visitsweden.com,
corporate.visitsweden.com or our social media channels
(primarily Facebook, Instagram, WeChat and YouTube),
via electronic mail, SMS, telephone; or that we may receive from our cooperating partners, or from a
third
party. This policy also describes processing relating to the provision of the image bank ”Image Bank
Sweden”
(http://imagebank.sweden.se).
We care about your personal privacy. This policy regulates how we collect, use and protect data about
you and
how you can exercise your rights. Please contact us if you have any questions or comments regarding
this
Personal Data Policy.
With reference to law, we refer below to the General Data Protection Regulation (GDPR) and other
applicable
Swedish data protection legislation.
1. What data do we collect about you?
‘Personal data’ means data relating to you that can identify you.
You can usually use our websites without providing us with any data. There may be a request for data
about
you on some pages, for example, if you register to receive electronic newsletters, reports, webinars
or the
like. The personal data that we process about you will normally come from you or from someone within
your
organisation in conjunction with entering into a cooperation agreement or the like. You may also
have
provided data about yourself to a Visit Sweden-company, which has been transferred to one or more
other
Visit Sweden-companies or to our cooperating partners that is forwarded to us. Furthermore, we use
data
about you that we have obtained from other sources provided by a third party, e.g. marketing and
sales
activities companies.
The personal data about you that may be affected is:
Personal data and contact details (name, address, email address and telephone
number,
demographic information and – when clearly justified considering the purpose of the processing or
the
importance of secure identification – personal identity (ID) number)
Technical data about your unit or Internet connection (IP address, cookies,
electronic
images, videos and similar track and trace technologies on websites and in email communication and also your
geographic location and login details)
Information about your user behaviour (for example, your search patterns on the
website,
your response time for pages and how you use our services). Our websites and our email communication
may
include an electronic image (‘web signal’ or ‘pixel tag’)
User-generated information (content that you voluntarily register or publish, for
example in
conjunction with competitions and newsletter applications)
2. Purpose and legal basis
It is a precondition for our processing of your personal data to be lawful that there is a legal
basis for
doing so, i.e. that it is necessary to perform a contract with you or a legal obligation to which we
are
subject, or that the processing is done following a balance of interests or that you have given your
consent
to specific processing. The following are examples of the purposes for which we process your
personal data
and the legal basis on which this is done.
One of our primary purposes for collecting personal data is to be able to perform and administer our
services, either directly by us ourselves or through one or more Visit Sweden-companies, our
cooperating
partners, such as to provide ourselves with information about the circumstances of a specific
matter,
protect the interests of you and your organisation, for reporting and invoicing purposes and also,
as
regards personal data from our cooperating partners, to administer or perform contractual
obligations.
Legal basis: The performance of a contract or legal obligation, or if you are a representative,
employee or
otherwise represent an organisation that is on the verge of or has entered into a contract with us –
legitimate interest. Visit Sweden’s legitimate interest in the above-mentioned processing of
personal data
is to be able to perform contractual or legal obligations.
Another main purpose is to be able to offer you a good service through adapted services and to
deliver better
services with more relevant content. We use the data we collect to provide you with information
about
services you request but also to be able to better understand our customers and cooperating
partners. We
conduct, among other things, customer surveys to achieve this. Customer and market analyses and also
processing for statistical purposes are performed at an amalgamated level and are not intended to
identify
individual customers.
Legal basis: Legitimate interest. Visit Sweden’s legitimate interest in the above mentioned
processing
of personal data is to be able to offer you/your organisation better services and also to provide
you with
relevant information about the services.
We may use data about you to provide newsletters and also news information and marketing related to
our
services, both general and customer-specific, inform you about campaigns, special offers and other
information about our activities or services that we offer ourselves or through our cooperating
partners and
that we think may be of interest to you or your organisation. We may thus later use the data about
you for
direct marketing, unless you/your organisation have instructed us not to do this. However, if you
are a
private individual we will only use your data for electronic direct marketing if you have consented
to us
doing so.
You have an opportunity at any time to object to us using your personal data for marketing purposes
by
contacting us in the manner described in Clause 11 below, or directly in our electronic mailing.
Legal basis: Legitimate interest or consent. Visit Sweden’s legitimate interest in the
above-mentioned
processing of personal data is to be able to offer you/your organisation better services and also to
provide
you with personally adapted offers and other relevant information.
3. Information about cookies and how we collect data about you
We use cookies, electronic images, videos and similar track and trace technologies on our website and in our
email
communications. Read our cookie information, on our homepage, for further information about how we
use
cookies and the like.
We also obtain personal data in conjunction with the performance of our services or from you/your
organisation in our capacity as cooperating partner or the like. You personally decide whether you
want to
provide most of the other personal data beyond this, for example, by registering for our newsletter,
by
sending email messages to us or through social media activities or if you/your organisation provide
data to
us in some other way. One Visit Sweden-company may also possibly obtain data about you from one or
more
other Visit Sweden-companies, our cooperating partners or another third party.
4. Who do we disclose your data to?
We process your personal data with great caution, and your data is only used by us, other Visit
Sweden-companies, our cooperating partners, and by selected third parties.
Third parties that we engage to help us to conduct our business (for example, for customer surveys
and
mailings) only have permission to use your personal data on our behalf and for the specific tasks
they have
to perform following our instructions, acting as a data processor for us. They are obliged to keep
your
personal data confidential and secure. If and as stated by statutory you are entitled to get a list
of any
processors that process your personal data on our behalf.
We may also forward your personal data to one or more other Visit Sweden-companies, our cooperating
partners
and other third parties, who in that case generally act as independent controllers, to be able to
offer
better services and for marketing purposes, to enable them to perform a service for us or you/your
organisation, for example, regional tourism organisations, their industry, and other tourism
industry
actors, our operators, media agencies, postal or service companies for delivery of, for example,
mailings or
public authorities where such is required according to law.
We may also possibly disclose personal data for other special reasons, e.g. when we have reason to
believe
that the data is necessary to identify, contact or bring proceedings against someone who may have
intruded
into our website or in some other way infringed or encroached upon our rights or property, or the
rights of
other visitors, when we are acting in good faith and are convinced that legislation requires us to
disclose
personal data.
The transfer of personal data to countries outside the EU/EES requires the country in question to
have a
contract with the EU/EES, that the country is deemed to have sufficient data protection legislation,
or that
we have concluded an agreement with the third party in question about them being compelled to apply
the
clauses approved by the EU Commission relating to the protection of personal privacy. You will find
a list
of approved third countries and standard clauses on the website of the EU Commission or the website
of the
Swedish Data Protection Authority concerning the transfer of data to third countries.
5. Your rights
You are entitled to request information about Visit Sweden’s processing of the personal data relating
to you.
You should clearly state in such a request what information you wish to receive (for example, what
categories of specific personal data we process about you and for what purpose). The request must
also be in
writing and be personally signed. We will respond to your request as soon as possible and within one
month.
In the event that we cannot fulfil your request, we will notify you of this, stating the reasons
why. We
will send the information to your population register address.
Visit Sweden will, at your request or on its own volition, rectify personal data about you that is
incorrect
and, when necessary, supplement the same and/or restrict the processing of your data.
If you consider that the data about you is incorrect or incomplete, you are entitled to ask for it to
be
rectified in the manner prescribed by law. We will rectify or update the data about you as quickly
as
reasonably possible.
You are also entitled, in the manner prescribed by law, to have the data about you removed or request
that we
restrict the processing of your personal data and also to withdraw any consent. You are also
entitled, in
the manner prescribed by law, to have the personal data you provided to us transferred (ported).
Please note that it may be required that we retain necessary personal data in conjunction with
erasure,
withdrawal of consent or porting to be able to fulfil our obligations by law or contract. It may
also be
permitted for us according to law to retain certain personal data to satisfy our business needs.
You are entitled to object to such processing of your personal data that we do pursuant to a balance
of
interests. We must then, after you have specified the processing to which you are objecting,
demonstrate
that there are overriding interests. You are also entitled to object at any time to the processing
of your
personal data carried out for direct marketing.
6. How long do we save your personal data?
We will only save your personal data for as long as it is necessary for the purposes prescribed by
this
Personal Data Policy or for as long as is required by law or contract. Your personal data is thinned
out or
rendered anonymous when it is no longer relevant for the purposes for which it has been collected or
is no
longer required according to law or contract.
7. What do we do to protect your data?
All personal data that Visit Sweden handles is processed in accordance with the legislation
concerning the
processing of personal data applicable at any given time. The personal data is stored in operating
environments that use security measures to prevent unauthorised access. Reasonable standards for the
protection of personal data are complied with. The measures are taken with a view to preventing
unpermitted
or unlawful processing of the data about you and unintentional loss or destruction of, or damage to,
this
data.
If a personal data breach is detected, this will, in the manner prescribed by law, be notified to the
Swedish
Data Protection Authority and also to you when and in the manner prescribed by law.
8. Links to other websites
Please note that there may be links to other websites on Visit Sweden’s website and channels in
social media.
If you follow such a link, this may mean that you visit other websites that have other rules for the
protection of privacy than the provisions of this Personal Data Policy.
9. Image Bank Sweden – Image Bank of Visit Sweden and the Swedish Institute
To present and market Sweden abroad, Image Bank Sweden (imagebank.sweden.se)
is administered by the Swedish Institute and Visit Sweden. To the extent images and videos show identifiable
individuals, material in the image bank may constitute personal data. As such, if images and videos of you
exist in the
image bank this means that your personal data is processed through the provision of the image
bank.
If you have entered into a modelling agreement or in any other way have participated in a photo
shoot, your
image was added to the image bank in agreement with the photographer, image bureau or other
responsible
entity that you have been in contact with in relation to your participation. The processing of
personal data
consisting of the provision of images and videos is based on the necessity of the performance of a contract
regarding
your participation if you have entered into such contract. Alternatively, processing is legally
based on
purposes of the legitimate interests of Visit Sweden and its partners to present and market Sweden
abroad,
which are assessed in light of and weighed against what we know of your interests, fundamental
rights,
freedoms and the protection of your personal integrity. In this balancing of interests, after
careful
consideration Visit Sweden has found that your interests and basic rights does not outweigh our
interests
and require protection in this context and that Visit Sweden can provide image(s) in which you are
identifiable in the image bank based on our legitimate interests.
If you have questions or objections to our processing of personal data, please contact us at
[email protected]. As registered, you are entitled to request a limitation of our processing.
Such
request will be evaluated by Visit Sweden. If you have entered into an agreement regarding your
participation this can affect our evaluation. If no request is made, images and videos are stored for a period
of time
as stated in individual contracts or agreements with photographers and/or models.
Individual persons, organization and corporations may use the image bank to present and market Sweden
abroad
and will do so under the image bank terms of use. Such external party will be responsible for its
own use.
In addition to what is stated above, this Personal Data Policy is also applicable to the processing
of
personal data relating to the image bank and as such, your rights, our contact information and other
information is available under the other sections of this document.
10. Amendment of the Personal Data Policy
This Personal Data Policy may be updated by us. If there are significant amendments to this Personal
Data
Policy, we will notify you by putting a clear message on our website or in some other appropriate
way. We
invite you to read through this Personal Data Policy to keep yourself informed about how we process
your
personal data.
11. Complaints
Please notify us as soon as possible if you consider that the processing of your personal data has
been dealt
with incorrectly. You also have the option to make a complaint to the Swedish Data Protection
Authority
about our personal data processing.
You may be entitled to damages if you consider that you have suffered a loss because our processing
of your
personal data has taken place in violation of the law. You can then request damages from us or
institute
proceedings at a court.
12. Contact details
V.S. VisitSweden AB, corporate identity (ID) number 556500-7621, or the Visit Sweden-company in the
country
in which the collection of your personal data takes place, is the controller for the processing of
your
personal data as shown above, unless otherwise expressly stated in conjunction with the collection
of your
data. Please contact the controlling Visit Sweden-company directly, or us in accordance with the
following
if you have any questions about the policy or our processing of personal data.
Email: [email protected]
Postal address: Visit Sweden, Box 3030, SE-103 61 Stockholm
Telephone: +46 (0)8-789 10 00
_______________