PERSONAL DATA POLICY
We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. Your privacy matters to us, so please do take the time to read this information which explains:
- What types of personal data we collect and why we collect it.
- When and how we may share personal data with other organisations.
- The choices you have, including how to access and update your personal data.
We have tried to keep this as simple as possible
1. What personal data we collect and why
Personal data means all kinds of information that can be directly or indirectly attributed to a living, natural person. This includes their name, national ID number, address, email address and telephone number. It may also include the likes of booking numbers and IP addresses where these can be linked to individuals.
Data collected in order to manage a booking
When you book with Lapoint we collect personal data from you in order to complete your booking. If your booking includes other people or your children, we also collect this data, provided that this is necessary in order to fulfill the booking. The following are potential examples of such data
Identity information, such as your name, date of birth, phone number and address.
Contact information, such as your address and email address.
Contact information in case of emergency you supplied us with.
Booking information, such as your booking number, how long you will be travelling, the destination, and what products you have ordered.
Information about your purchases, including what you bought, when and where you bought it, how you paid and credit or other payment information.
Health information, such as your height, weight and shoe size, for example in order to set you up with correct equipment on location.
Data collected via customer service
We collect personal data when you contact us in order to manage the customer relationship between us. First and foremost, we collect the personal data necessary to be able to answer your question or handle your case.
Information collected via our our newsletter
If you choose to subscribe to our newsletter, we collect your name and email address in order to send you the newsletter. If you choose to provide it, we also collect data about your postal code and country of residence.
Data collected on location
We love photography and most of our guests do to, we use video as part of our coaching techniques and if this is included in your package, we will film and store your footage in case you return so we can see your development. We also take pictures as part of the service or to sell as a separate service.
If you choose to answer our question form we collect your email address if you choose to provide it. We also collect information about gender, nationality and previous experience with Lapoint. We do this in order to be able to contact you if we feel that we would like to understand your feedback better.
We may use CCTV images to help maintain the safety of anyone working in or visiting our premises and other buildings, and for the prevention, detection and prosecution of criminal offences. We may also rely on the images to establish, exercise or defend our legal rights
Data collected when using our websites
When you use any of our websites, we collect data about your use of the service in question. Some of this data may be personal data, for example your IP address if it can be linked to individuals.
Information collected from someone other than yourself
When booking and when in contact with us in relation to various matters, it may happen that a person provides personal data about one or more other guests in a travelling group. We assume that the person providing this data has the consent of all the individuals involved to disclose this personal data. If you have not made a booking yourself, but someone else has made a booking which includes you, we collect personal data about you from that person. When you provide personal data about other guests, you must make sure that they consent to this and that you have permission to submit the data. If appropriate, you should also make sure that they understand how their personal data may be used by us.
2. How we use and store your data
Lapoint’s legal basis for processing your personal information
Lapoint processes your personal data in accordance with the law. It can happen that the same personal data is processed on the basis of multiple legal bases, such as the performance of a contract, based on a balancing of interests or specific consent from you, or on the basis that the data is necessary in order to comply with other legal obligations. Primarily, we process your data for the performance of a contract to which you are party, such as a booking.
Administration of your trip
In order to be able to deliver the services and products you have ordered from us (i.e. perform our contract), we use your personal data in various ways. The data is used to produce your booking confirmation and other travel documents, to book your accommodation and make payment for the products you have ordered. Depending on what you have ordered the data is used accordingly to deliver these products.
Administration of your booking also includes the use of your data for the purposes of accounting, settlement and audit, credit or other payment card verification and customs controls (i.e. satisfying legal obligations).
In order to provide customer service
We use your personal data in order to be able to provide you with service if you contact us with questions, comments or complaints, etc. We use your name and booking number to identify you and your booking. We use your contact information, such as your email address and telephone number, to be able to contact you in connection with questions and issues. We do this in order to be able to fulfil our contract with you and on the basis of our legitimate interest in providing you with good service. We may also use the other personal data we have collected about you to handle your question or your case, as is relevant in the particular case in question.
When you have made a reservation with us, we use your personal data to send you a booking confirmation, important information about your upcoming stay and offers related to your chosen product (i.e. in order to perform our contract and on the basis of our legitimate interest in marketing our products and services).
Marketing and personalisation
We would love to send you relevant offers and news about our products and services. Data such as information about your previous purchases, browsing habits and search settings may be used by Lapoint in order to contact you by post, email or telephone in a marketing context. In this way, we can tailor our communications so that they are more relevant to you. We may also send you information about products and services from our partners that we believe may be of interest to you.
If you do not want to receive marketing material from us, you may decline it at any time through the newsletter unsubscribe link.
Development of services and customer service
We use the data we collect about our customers to develop and improve our products and services. This applies to our digital services, where we analyse user behavior in order to develop how we present information and offers and design features.
We predominantly use anonymous or anonymised data on an aggregate level to perform this type of analysis. However, it can happen that we also use the personal data we have collected if relevant. We do this in order to fulfill our contract with you and on the basis of our legitimate interest in improving our services and our customer service.
Finally, your personal data may also be processed in order to satisfy obligations under laws and regulations, for example regarding security and reporting.
We never save data longer than we need to and only use your personal data for the purposes set out in this policy. After this time, we will safely remove your personal data. The same personal data may be stored in several different places for different purposes. This means that we may delete data from one system when it is no longer needed there, while the same data may continue to be stored in a different system where its purpose is still valid for that specific system. If data is needed after this period for analytical, historical or other legitimate commercial purposes, we will take appropriate steps to anonymise the data so that it no longer constitutes personal data.
The personal data we collect via a booking is stored in our customer database for five years. If you make a new booking within five years of your return date from the trip in question, information about previous bookings/products will be saved for another five years. Personal data is stored as a basis for market and customer analyses, for statistical purposes and in order to provide you with a better booking offer and better customer service. The personal data is also stored in order to enable us to comply with the legal requirements with respect to the supervision in place for package tours and in order to ensure that there is documentation of booking in the event of a complaint. In the event of complaints, some data may be saved for ten years in order for us to be able to defend ourselves against legal claims.
If you have registered to receive our newsletter, we will retain the data necessary to administer this until or unless you unsubscribe from the newsletter or notify us that you no longer wish to receive it. You can you opt out of receiving the newsletter at any time via the letters unsubscribe link.
By law, we are required to record and retain certain information that constitutes accounting information. We, therefore, have to store this information for roughly seven years.
3. Disclosure of personal data
In order to be able to fulfill the booking you have made with us, we may need to share your personal data with our sub-suppliers and partners. We only share personal data with them to the extent necessary for them to be able to provide their services to you and us, and they only have access to the personal data that is necessary.
In order to meet the objectives of our processing of your personal data, we share your personal data with companies that provide services to Lapoint, for example in order to manage airport transfers, tours or accomodation. These companies may only process your personal data in accordance with our explicit instructions and must not use your data for their own purposes. They are also required by law and contracts to protect your personal data.
Contractual partners and IT suppliers
We use a number of different IT services and IT systems in our business. Personal data is stored and handled in some of these. We care about your privacy and the security of your data during any such handling. Some systems are cloud solutions or installed by the provider, which means that we transfer personal data to the provider. In such cases, the provider is our data processor and handles the data on our behalf and under our instructions.
Agents and digital partners
When you book a trip with Lapoint via a travel agent or website (digital partner) with which we cooperate in the marketing of our trips, it may be that you yourself provide personal data to the travel agency or website. This personal data is the responsibility of and is managed by the operator in question in accordance with its data protection policy.
When you book through an agent, you yourself provide your personal data to the agent and consent to the agent handling that data in its business. The agent can therefore identify you, e.g. with the aid of your booking number. We are not responsible for the agent’s handling of the personal data you have directly provided the travel agency with.
Providers of travel-related services
In order to provide some of the services you have ordered from us, we use sub-suppliers and contractual partners. It is often necessary to provide them with personal data in order for the service in question to be performed.
If you book other travel-related services through us the personal data needed to deliver the service ordered may, where appropriate, be passed on to the party that will perform the service in question. This may involve, for example, data about the names and national ID numbers of all persons on the booking, and contact information for the person who made the booking.
Transfer to a third country
Because we arrange trips to many countries. This means that personal data may be transferred to partners in these countries for the same purposes as described above. These companies may only process your personal data in accordance with our explicit instructions and must not use your data for their own purposes. They are also required by law and contracts to protect your personal data.
4. Your rights
Necessary handling of personal data and handling based on consent
Such processing of personal data as is necessary for us to be able to perform a contract with you or to fulfil a legal obligation is permitted without consent. However, your consent to processing is required in order for us to collect and handle your personal data for any other purpose.
Withdrawal of consent
You can choose to withdraw your consent at any time by contacting us via the contact details given below. If you withdraw your consent, we will anonymise the personal data we hold about you, and discontinue any processing on the basis of that consent, e.g. in connection with profiling. It may be that the same personal data is being processed both on the basis of your consent and on the basis that it is necessary or under other regulations. This means that, even if you revoke your consent and such processing as is based on that consent ceases, it may still be necessary for us to retain your personal data for other purposes.
Right to information about the personal data we have stored about you
In addition to the online access you have to the personal data related to your booking, you also have a right to a copy of the personal data that we hold about you.
Right to control your personal data
You have the right to request that data about you be deleted, supplemented or corrected. You also have the right to request that the processing of your personal data is limited to specific purposes and that it not be used, for example, for direct marketing or profiling.