Newsletters
When you choose to subscribe to newsletters, we at ESS Hotel Group AB and the destination where you choose to subscribe to our newsletters (”ESS”, “we”, ”our” and ”us”) process your personal data as necessary to:
- send newsletters to you; and
- analyse how newsletters are used (e.g. what you click on) to improve and develop them.
If you have stayed at any of our destinations, you will receive newsletters after your stay, read more about this here. Here you can find all our privacy policies which describe how we process personal data in other situations, e.g. if you visit our website or otherwise are in contact with us.
You can choose to unsubscribe from our newsletters at any time. In that case we will store your information in an “unsubscribe-list”.
Below you can read more about:
Which company is responsible for the processing of your personal data?
Detailed description of how we process your personal data
Who can gain access to your personal data and why?
Which company is responsible for the processing of your personal data?
The company who run the destination where you subscribed to our newsletters is responsible for the processing of your personal data together with ESS Hotel Group AB (Swedish registration number 556710-8047). You can find information about our destinations here.
If you wish to know more about how personal data is shared within our corporate group, you can find more information here.
Please contact us via our e-mail address privacy@essgroup.se, or give us a call on +46 775-553 553 if you have any questions regarding our processing of your personal data or if you wish to exercise any of your rights. Our postal address is ESS Hotel Group AB, Drakegatan 10, 412 50 Gothenburg, Sweden.
Detailed description of how we process your personal data
We gather your personal data directly from you and provide some personal data ourselves by analysing how you use our newsletters.
To send newsletters and to improve and develop our newsletters
What processing we perform
What personal data we process
Our lawful basis for the processing
- Send information about news, marketing, offers, discounts and invitations (“newsletters”) to you who have chosen to subscribe to our newsletters
- E-mail address
Consent
The personal data will be processed based on your consent. You can withdraw such consent at any time.
- Improve and develop our newsletters by analysing how you open them and what you click on in the newsletters
Do you want to read more about this type of analyse? You find a more detailed description of this in our information about cookies.
- Information about how you open our newsletters and what you click on
- IP-address
- E-mail address
Consent
The personal data will be processed based on your consent. You can withdraw such consent at any time.
Storage period: You can choose to unsubscribe or object to receiving newsletters and marketing at any time. If you object to receiving marketing from us, we keep track of this in our “unsubscribe-list” to avoid sending you any further marketing material.
If you object to receiving marketing from us
We will store information about you who have chosen to object to receiving marketing in newsletters from us.
To comply with marketing legislation
What processing we perform
What personal data we process
Our lawful basis for the processing
- If you have stated that you do not wish to receive marketing newsletters from us we will store such information in a “unsubscribe-list” to make sure we do not send any marketing to you
- Name
- E-mail address
Legal obligation
The processing is necessary to comply with legal obligations to which we are subject, i.e. marketing law which require us to not send marketing material to individuals who have objected to receiving such marketing.
We cannot make sure you will not receive marketing from us without processing your personal data for this purpose and you are therefore required to provide your personal data to us.
Storage period: You will be listed in our “unsubscribe-list” until further notice.
Who can gain access to your personal data and why?
Your personal data is initially collected and processed by us as controllers and we do not sell your personal data. This means that your personal data will be handled by our employees, but only personnel who need such access to conduct their work.
We also use processors that carry out processing on our behalf to conduct our business, such as suppliers and partners which therefore will process your personal data. We are responsible for any sharing of your personal data to such suppliers or partners and to make sure your personal data is safe when shared with third parties as set out below. We only use processors providing sufficient guarantees that the processing will meet all legal requirements and ensure the protection of the rights of the data subject.
- We will share your personal data with our IT suppliers who will process these on our behalf and on our instructions to ensure good and secure IT operations. We only share your personal data with our IT suppliers if it is necessary for them to fulfil their obligations towards us according to the contract that we have with them.
- We will share your personal data with the company which provide the marketing services we use.
- To handle your newsletters and text messages in the most efficient way we share your personal data within the company group.
Where are your personal data processed?
As a main rule we only process your personal data in the EU/EEA and choose suppliers based within the EU/EEA. The use of our suppliers will however in some instances mean that your personal data is transferred outside of the EU/EEA.
We only transfer your personal data outside of the EU/EEA if we can make the transfer according to the data protection rules. This means that the transfer either is governed by an adequacy decision or that we rely on Standard Contractual Clauses and supplementary measures to provide a safe transfer of your personal data.
If you want to know more about who we share your personal data with, please feel free to contact us. Our contact information can be found at the beginning of this privacy policy.
What are your rights when we process your personal data?
You have certain rights that you can exercise to affect how we process your personal data. You can read about what those rights are below. Contact us if you want to exercise any of your rights.
- Right to lodge a complaint with a supervisory authority
You always have the right to lodge a complaint with a supervisory authority. You may do this in the EU/EEA member state where you live, work or where an infringement of applicable data protection laws is alleged to have occurred.- The supervisory authority in Sweden is the Swedish Data Protection Authority (Integritetsskyddsmyndigheten, the IMY).
- The supervisory authority in Denmark is the Danish Data Protection Agency (Datatilsynet).
- The supervisory authority in Norway is the Norwegian Data Protection Authority (Datatilsynet).
- Right to withdraw your consent and object to processing
You have a right to withdraw any consent you have given us, partly or completely. You as well have a right to object to our processing of your personal data when the processing is performed for marketing purposes, such as sending newsletters.
- Right to information and access
You have the right to obtain confirmation as to whether we are processing personal data about you or not. If we do process your personal data, you also have a right to obtain a copy of the personal data processed by us as well as information about how we process your personal data.
- Right to rectification
You have a right to correct any inaccurate personal data concerning you that we may be processing and to ask us to have incomplete personal data completed.
- Right to erasure (“the right to be forgotten”) and restriction of processing
You have a right to request that we delete your personal data. We will delete the personal data for example when if you have withdrawn your consent and there is no other lawful basis for processing.You also have a right to request that we restrict our processing of your personal data. We will do this for example when the accuracy of the personal data is contested by you, or the processing is unlawful, and you do not want us to delete your personal data but instead you request that we restrict our use of them.
- Right to data portability
Under certain circumstances, you have a right to receive your personal data from us in a structured, commonly used and machine-readable format and, where technically feasible, have your personal data transferred to another company (“data portability”). This applies to personal data that you have provided to us in a structured, commonly used and machine-readable format, if our processing of your personal data is carried out by automated means and the lawful basis for our processing is based on your consent.
This policy was adopted on 2022-06-21.
Last updated 2023-04-18.
