Practical information

Data Policy/GDPR

Kolding Hotel Apartments

Our Data Policy

GDPR

1. Privacy Policy

Kolding Hotel Apartments is the data controller for the processing of personal data described in this policy.

You can contact us at:

Kolding Hotel Apartments

Kedelsmedgangen 2

6000 Kolding

Denmark

Phone: +45 75541800

E-mail: [email protected]

Kolding Hotel Apartments processes personal data regarding guests, customers, suppliers, and their contact persons in connection with our services, agreements, website, and other activities. The purposes and legal bases are set out in sections 5, 6, and 9.

When you book a stay or other services, or request a quote, Kolding Hotel Apartments processes the data necessary to conclude or perform the agreement with you. This processing is not based on consent. Consent for newsletters, website services, or the processing of sensitive data is obtained separately and does not form part of your acceptance of the booking terms.

2. Collection of Personal Data by Kolding Hotel Apartments

Personal data is collected by Kolding Hotel Apartments in the following ways:

When a guest, customer, or a representative of such chooses to request a quote for and/or purchase one of Kolding Hotel Apartments' services or products, or when a supplier submits a quote or sells products or services to Kolding Hotel Apartments.
From the B2B market.
Through browser cookies and web beacons.
In connection with the use of Kolding Hotel Apartments' digital services.
By participating in Kolding Hotel Apartments' customer or loyalty programme and by subscribing to the Kolding Hotel Apartments newsletter.
From social media, advertising and analytics providers, and public registers.
Via video and CCTV surveillance.
When suppliers enter into agreements with Kolding Hotel Apartments or submit quotes.

The collection and processing of personal data, cf. the above, will always take place in accordance with applicable data protection legislation.

CCTV surveillance installed on the premises of Kolding Hotel Apartments is used as part of crime prevention and also acts as a reassuring security measure for employees and guests.

3. Information Collected by Kolding Hotel Apartments

Depending on your relationship with us and the services you use, Kolding Hotel Apartments processes the following categories of personal data:

Name, address, phone number, e-mail address, date of birth, passport number, or other identification, to the extent necessary for the relevant processing.
Demographic information.
Booking information and purchase history, including the use of our app and other digital services.
Information regarding participation in our customer or loyalty programme.
Information from customer surveys and competitions.
Information from our social media and other digital platforms.
Browser information, online identifiers, and information regarding visits and interactions on the website.
Information concerning the businesses of guests, customers, and suppliers, as well as relevant contact persons and key personnel.
Images from CCTV surveillance.

You may voluntarily provide us with information regarding special requests or considerations. If this information relates to, for example, a disability, health condition, medication, or religious belief (sensitive personal data), and if the information is necessary for the performance of the contract with you (to deliver the reservation), this data is processed pursuant to Article 6(1)(b) of the General Data Protection Regulation (GDPR).

If the information is provided to Kolding Hotel Apartments for other purposes, e.g., to accommodate your wishes, the data is processed on the basis of a separate, explicit consent, cf. GDPR Article 6(1)(a). Sending or telling us about these matters does not in itself constitute consent. Consent is obtained before Kolding Hotel Apartments registers or otherwise uses the data for this purpose.

Kolding Hotel Apartments also receives information from travel agencies, other booking intermediaries, your employer, or the person booking on your behalf. This information typically includes name, contact details, booking information, and details of ordered services. Kolding Hotel Apartments may also receive information from social media, advertising and analytics providers, and public registers. In connection with the specific processing, Kolding Hotel Apartments will inform you of the source and the relevant data, if this is not already clear from this policy.

When Kolding Hotel Apartments receives information about you from third parties, Kolding Hotel Apartments is responsible for fulfilling our duty to provide information pursuant to GDPR Article 14. Kolding Hotel Apartments may allow the intermediary to pass our information on to you, but this does not alter our responsibility. You will receive the information within a reasonable timeframe and no later than one month after receipt, or at the latest upon our first communication with you or first disclosure, if this occurs earlier. This applies unless an exception to the duty to provide information applies, for example because you already have the information.

4. Payment by Payment Card

Kolding Hotel Apartments uses Nets for the processing of debit and credit card payments. Nets and Kolding Hotel Apartments are approved and certified by the Danish Payments Council (Pengeinstitutternes Betalingssystem).

Once your card payment has been completed, your card details are deleted immediately afterwards.

5. What is the Purpose of Collection and Processing?

Kolding Hotel Apartments processes personal data for the following purposes, to the extent that the activity in question is relevant to you:

To answer enquiries and prepare quotes.
To administer bookings, payments, and delivery of stays, meetings, events, conferences, and other ordered services.
To communicate with you regarding your booking and stay.
To handle supplier quotes, purchases, and partnership agreements.
To administer customer and loyalty programmes as well as competitions.
To conduct customer surveys and improve our services.
To send newsletters and conduct marketing, statistics, and analysis as described in section 9.
To accommodate special requests and considerations that you have asked us to take into account.
To prevent crime and protect guests, employees, and property through CCTV surveillance.
To comply with statutory requirements regarding guest registration and other relevant legal requirements.

When booking, you must provide the information necessary to conclude and perform the agreement, including name, contact details, and the information regarding the stay and payment required by the booking. If you do not provide the necessary information, Kolding Hotel Apartments cannot complete the booking or deliver the service in question.

For statutory guest registration, Kolding Hotel Apartments collects the full name, date of birth, and address of overnight guests aged 16 and over, and requires presentation of photo identification, cf. Section 31 of the Danish Passport Executive Order and Section 36 of the Aliens Executive Order, respectively. This information is a legal requirement. If you do not provide the statutory information or present the required identification, Kolding Hotel Apartments cannot complete the statutory registration and therefore cannot offer the stay on this basis.

Signing up for newsletters, consenting to statistics and marketing on the website, or providing sensitive data regarding special considerations is voluntary. If you do not give consent, it does not affect your ability to book a standard stay. However, without the necessary information regarding a special consideration, Kolding Hotel Apartments may be unable to accommodate that specific request. Consent-based embedded content is not available until the relevant consent has been given.

6. Legal Basis – The Legal Ground for Processing

Booking, Quotes, Payment, and Delivery of Services

Kolding Hotel Apartments processes information necessary to conclude or perform an agreement with you pursuant to GDPR Article 6(1)(b). This covers your requests for quotes, booking, payment, delivery of ordered services, and necessary communication regarding the agreement before, during, and after the stay. The same basis is used when you, as an individual, are a party to a supplier or partnership agreement with us. This processing is not based on consent.

Emails are stored for a maximum of 1 year after they have been processed and/or the booking has taken place.

Corporate Contacts and Guests Who Are Not Themselves Parties to the Agreement

If you are a contact person at a customer, supplier, or partner, Kolding Hotel Apartments processes necessary contact and agreement data pursuant to GDPR Article 6(1)(f). Our legitimate interest is to communicate with the business and administer the contractual relationship.

If, for example, your employer books the stay and you are not personally a party to the agreement, Kolding Hotel Apartments processes the necessary guest and booking information pursuant to Article 6(1)(f). Our legitimate interest is to administer the company's booking and deliver the agreed services to you. If, on the other hand, an intermediary enters into the agreement on your behalf and you are personally a party to the agreement, Kolding Hotel Apartments uses Article 6(1)(b). Guest data is stored for a maximum of 2 years unless consent has been given for data retention. In the event of consent, personal data is stored until the individual requests its deletion.

Customer Surveys and Improvement of Our Services

Kolding Hotel Apartments processes ordinary personal data for customer surveys and limited analysis of our service pursuant to GDPR Article 6(1)(f). Our legitimate interest is to investigate customer satisfaction and improve our services. Processing via statistics and marketing technologies requiring consent is conducted pursuant to section 9 instead. This data is stored for a maximum of two years unless consent has been given for longer data retention.

Customer and Loyalty Programmes and Competitions

Information necessary to administer your membership and deliver agreed membership benefits is processed pursuant to GDPR Article 6(1)(b). The same applies to information necessary to administer your participation in competitions, find the winner, and deliver the prize when participation constitutes an agreement under the competition terms. Any newsletter sign-up and other consent-based processing requires separate consent. In the event of consent, personal data is stored indefinitely until the individual requests its deletion.

CCTV Surveillance

Kolding Hotel Apartments processes images from CCTV surveillance pursuant to GDPR Article 6(1)(f). Our legitimate interest is to prevent crime and protect guests, employees, and hotel property. Surveillance is limited to what is necessary for these purposes.

When processing is based on legitimate interests, Kolding Hotel Apartments carries out a balancing test of our interest against your interests and fundamental rights. Kolding Hotel Apartments only uses this basis if the processing is necessary and your interests and rights do not override ours. All CCTV footage is deleted after 30 days.

Sensitive Data Regarding Special Considerations

If you wish Kolding Hotel Apartments to take account of, for example, a disability, allergies, other health conditions, or religious beliefs, Kolding Hotel Apartments processes the necessary sensitive data on the basis of GDPR Article 6(1)(b), if the information is necessary for the performance of the contract with you (to deliver the reservation).

If the information has been provided to Kolding Hotel Apartments for other purposes, e.g. to accommodate your wishes, the data is processed on the basis of a separate, explicit consent, cf. GDPR Article 6(1)(a) and Article 9(2)(a), cf. Section 7(1) of the Danish Data Protection Act. Sending or telling us about these matters does not in itself constitute consent. Consent is obtained before Kolding Hotel Apartments registers or otherwise uses the data for this purpose.

The information is used solely for the purpose covered by the consent. If it is to be disclosed to, for example, a restaurant or a spa centre, explicit consent for the specific disclosure is also obtained.

Statutory Registration

Kolding Hotel Apartments processes information for statutory guest registration pursuant to GDPR Article 6(1)(c), cf. Section 31 of the Passport Executive Order and Section 36 of the Aliens Executive Order. Any other statutory processing is carried out pursuant to Article 6(1)(c), cf. the relevant legal obligation.

This data is stored for a maximum of two years unless consent has been given for data retention.

Website Services and Newsletters

The legal basis for each of the website services used and for newsletters is set out in section 9. Consent for these purposes is separate from the processing of data for your booking.

7. Your Rights

Under the GDPR, you have certain rights, provided that the conditions for the individual right are met:

Right of access: You have the right to be informed whether Kolding Hotel Apartments processes data about you, gain access to the data, and receive a copy.
Right to rectification: You have the right to have incorrect data corrected and incomplete data completed.
Right to erasure: In certain cases, you have the right to have data deleted. This right does not apply, for example, if continued processing is necessary to comply with a legal obligation or to establish, exercise, or defend legal claims.
Right to restriction: In certain cases, you have the right to restrict processing, for example while Kolding Hotel Apartments investigates whether data you dispute is correct.
Right to data portability: When processing is automated and based on consent or a contract, you can receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and transfer it to another data controller. You can have the data transferred directly if technically feasible.
Right to withdraw consent: You have the right to withdraw your consent at any time. This does not affect the lawfulness of processing based on consent before its withdrawal. Kolding Hotel Apartments will cease the consent-based processing. However, data may continue to be processed to the extent that another independent legal basis applies, such as a statutory retention obligation.

Right to Object

You have the right to object at any time to processing based on legitimate interests for reasons relating to your particular personal situation. Kolding Hotel Apartments will then cease processing unless Kolding Hotel Apartments can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary to establish, exercise, or defend legal claims.

If Kolding Hotel Apartments processes your data for direct marketing purposes, you have the right to object at any time, including to profiling to the extent that it is related to such direct marketing. Kolding Hotel Apartments will subsequently cease processing your data for this purpose.

How to Exercise Your Rights

You can contact us via the contact details in section 1, for example at [email protected]. There is no general requirement for a written request or signature. If Kolding Hotel Apartments has reasonable doubts regarding your identity, Kolding Hotel Apartments may ask for additional information necessary to verify it.

Kolding Hotel Apartments will respond to your request without undue delay and no later than one month after receipt. The deadline may be extended by a further two months if necessary, taking into account the complexity and number of requests. If so, Kolding Hotel Apartments will inform you of the extension and the reasons within the first month. Electronic requests will be answered electronically where possible, unless you request otherwise.

As a rule, exercising your rights is free of charge. In the case of manifestly unfounded or excessive requests, particularly if repeated, Kolding Hotel Apartments may charge a reasonable fee or refuse the request pursuant to GDPR Article 12(5). Kolding Hotel Apartments must be able to demonstrate that the conditions are met. Resource consumption or technical complexity does not in itself constitute grounds for refusal.

In specific cases, rights may be restricted under the GDPR and the Danish Data Protection Act, including with regard to the rights of others. Kolding Hotel Apartments always assesses whether the conditions for a restriction are met. If Kolding Hotel Apartments does not comply with your request, Kolding Hotel Apartments will provide justification and information on the possibility of lodging a complaint with the Danish Data Protection Agency (Datatilsynet) and taking legal action no later than one month after receipt.

You can lodge a complaint regarding our processing of personal data with the Danish Data Protection Agency. See also section 10.

8. Security and Sharing of Personal Data

Kolding Hotel Apartments protects your personal data against unauthorised disclosure and access by unauthorized persons. Kolding Hotel Apartments has established guidelines for data protection.

Only employees who have a work-related need have access to the data.

Kolding Hotel Apartments regularly checks access, creates backups, and reviews and updates our security procedures in line with technological developments. In the event of a security breach that is likely to result in a high risk to your rights and freedoms, Kolding Hotel Apartments will notify you without undue delay in accordance with the rules of GDPR Article 34.

Kolding Hotel Apartments uses external suppliers of IT services, IT systems, and payment solutions.

When suppliers process personal data on our behalf, Kolding Hotel Apartments enters into data processing agreements with them. Other recipients may be independent data controllers for their own processing.

To deliver the services you have ordered, Kolding Hotel Apartments shares necessary information with relevant external suppliers, for example restaurants for table reservations and spa centres for spa stays. Ordinary data is shared pursuant to GDPR Article 6(1)(b) when necessary for our contract with you, or pursuant to Article 6(1)(f) when you are not personally a party to the agreement. In the latter case, our legitimate interest is to deliver the agreed services to the guests covered by the agreement. Sensitive data, such as information regarding allergies, is disclosed for these purposes solely on the basis of your separate, explicit consent.

Kolding Hotel Apartments also discloses information to public authorities when Kolding Hotel Apartments is legally obliged to do so. The legal basis is then GDPR Article 6(1)(c), cf. the relevant legal obligation.

External website services and any transfers to countries outside the EU/EEA are described in section 9.

Kolding Hotel Apartments deletes your personal data when Kolding Hotel Apartments' legal obligation ceases, or when the purpose of collecting and processing the data no longer exists. Section 6 specifies when personal data is deleted.

9. Third-Party Systems and External Services

Kolding Hotel Apartments uses external services for consent management, statistics, marketing, communication, and content display. The purposes and legal bases for our processing through each service are described below.

Cookiebot

Kolding Hotel Apartments uses Cookiebot from Usercentrics A/S to obtain, manage, and document your choices regarding cookies and similar technologies. The service records, among other things, the categories you have accepted or rejected and the time of your choice.

Processing necessary to document your consent takes place pursuant to GDPR Article 6(1)(c), cf. Article 7(1). Processing to remember and respect your choices takes place pursuant to Article 6(1)(f). Our legitimate interest is to manage your privacy choices and avoid activating consent-requiring services in violation of them.

Google

We use various Google services, including Google Analytics and Google Tag Manager, as well as services related to advertising and measurement. Depending on your consent choices, Google may process information about your use of the website, including online identifiers, visit and interaction data, and information used for statistics, advertising, and campaign measurement. Our processing is based on your consent, cf. GDPR Article 6(1)(a).

10. Complaints

Complaints regarding Kolding Hotel Apartments' processing of personal data can be submitted to the Danish Data Protection Agency (Datatilsynet):

Datatilsynet

Carl Jacobsens Vej 35

2500 Valby