PRIVACY POLICY

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1 INTRODUCTION
 

AS PARKS with its subsidiaries, including Skimore AS, TryvannWyller AS, Drammen Skisenter AS, Kongsberg Skisenter AS (Skimore Oslo, Skimore Drammen and Skimore Kongsberg), is concerned with handling your personal data in a safe and secure manner, in line with current regulations.

 

Below you will find information on how Skimore AS, as data controller, handles personal data that we collect from users of the Skimore app, as well as the use and rental of our other services (ski rental, ski school, bike rental, use of climbing parks, etc.).

 This declaration also covers Skimore's processing of personal data in the currently applicable partner facilities with which Skimore has entered cooperation.
 

2 WHAT PERSONAL INFORMATION DO WE COLLECT AND WHY?
 

2.1 Conclusion of agreement and delivery of services

When you enter into a membership agreement with us, or register with us to use our services, we collect personal data from you to complete your order and fulfill our obligations under the agreement with you. These obligations will, among other things, consist of giving you access to the application, identifying you as a valid member, providing you with correctly adapted rental equipment, the correct level at the ski school, as well as contacting you regarding matters relating to your membership. In this context, we process the following personal data: Name, e-mail, mobile number, user picture, date of birth, account details, skill level, size, and height.

 

The legal basis for this processing is GDPR art. 6 no. 1 letter b (agreement). This is because the information is necessary to fulfill the agreement with you.

 

If the order includes persons who are not of legal age, we will also collect this information, if this is necessary to fulfill the agreement with you. The legal basis for this processing will be GDPR art. 6 no. 1 letter b (agreement).

 

2.2 Registration of activity

We will be able to process information about your visiting activity in the facilities of AS PARKS to ensure that your use is in accordance with what has been agreed. The legal basis for this processing is GDPR art. 6 no. 1 letter f (legitimate interest).
 

Furthermore, we will be able to process information about your purchase and visit history to adapt which offers we communicate with you. From time to time, for example, we offer the conversion of a guest pass to membership at a favorable price, and we will then adapt our marketing based on who has purchased a guest pass. The legal basis for this processing is Section 15 (1) of the Marketing Act and GDPR Article 6 No. 1 letter a) (consent).

 

In addition, we will be able to process anonymized activity data for internal business purposes, for example to (i) distribute income between the group companies in AS PARKS, (ii) prepare reports and statistics that we can use to improve our services, as well as (iii) other types of analysis that is carried out with the aim of giving you a better user experience via the app. This processing will, as far as possible, be based on anonymized data that cannot be traced back to you as a person. This type of processing is based on a balancing of interests, as we believe that this processing contributes to the efficient operation of the company and the best possible conditions and services for our customers, cf. GDPR article 6 no. 1 letter f) (legitimate interest).

 

2.3 Marketing to existing customers and members

Skimore strives for our members and customers to receive up-to-date and good information about various updates and other matters we believe are relevant for our customers and members to benefit from the services we offer. From time to time, we will therefore send out newsletters and other relevant information to all our customers, either via email, push notifications or SMS. These inquiries may contain information about products and offers that are relevant in connection with your membership or the service you have purchased.

 

This type of marketing is sent without prior consent to existing customers and members. The communication will be sent to the contact address you have provided in connection with entering the membership. The marketing is based on an existing customer relationship, cf. the Marketing Act § 15 (3), and is based on a balance of interests, cf. GDPR article 6 no. 1 letter f). In cases where you are not an existing customer and member of Skimore, such marketing described above will be based on Section 15 (1) of the Marketing Act and GDPR Article 6 No. 1 letter a) (consent).

 

If you have consented to this, we will also be able to send you electronic marketing and newsletters containing information about products and services from companies in the same group as Skimore, or about products and services from our commercial partners. The basis for this type of marketing is laid down in the Marketing Act § 15 (1) and GDPR article 6 no. 1 letter a) (consent).

2.4 Visits to our websites – Log data and Cookies

When you visit our service or our websites, we collect information that the browser sends to us. It is called log data. This log data may contain information such as your computer's IP (Internet Protocol) address, Geo location, browser version, which pages of our service you visited, time and date of the visit, the time spent on these pages and other statistics.

 

Cookies are files with a small amount of data, which are usually used as an anonymous unique identifier. These are sent to your browser from the website you visit and stored on your computer's hard drive.
Our website uses these "cookies" to collect information and to improve the user experience on our service. Our purpose with this use of cookies is to gain insight into user interactions on our website, through anonymous reporting, measurement, and statistics. The information processed in this connection is Cookie ID, type of device, type of browser and IP address.

 

You have the option to delete these cookies in your browser after a cookie is sent to your computer. If you choose to refuse our cookies, you may miss out on good user experiences and not be able to use certain parts of our service.

 

Our use of cookies will be based on GDPR art. 6 no. 1 letter a (consent).

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3 SHARING OF PERSONAL INFORMATION

To complete your order with us, we may need to share your personal data with our suppliers and partners. We only share personal data with them to the extent necessary for them to be able to complete their services to you and us, and they only get access to the personal data that is necessary.

 

We will also hand over personal data to other companies in the same group where this is necessary for internal administration purposes or it is necessary to satisfy group-based management, control and/or reporting requirements laid down in law. The legal basis for this processing is GDPR art. 6 no. 1 letter f (legitimate interest).

 

We use the following subcontractors and individuals to:
 

• assist our services; Google Tag Manager, Google Analytics.

• deliver services and make payments on our behalf; Skidata, NETS.

• perform Service-related services; or help us analyze how our Service is used or analyze your performance; MailGun, Firebase, Teletopia.

• internal group administration; AS PARKS with subsidiaries, including TryvannWyller AS, Drammen Skisenter AS, Kongsberg Skisenter AS and other relevant companies in the group to the controller.

 

These subcontractors process personal data on our behalf and only in accordance with our instructions. In accordance with GDPR Article 28, data processing agreements have been concluded with all recipients of your personal data.

 

4 HOW LONG YOUR PERSONAL DATA IS STORED

We never store personal data longer than is necessary to fulfill our membership agreement or to deliver other services with you. Personal data we no longer need will be permanently anonymized or securely deleted.

 

When you cancel your membership with Skimore, your personal data will be deleted after 2 years, or when they are no longer necessary for the purpose for which they were collected.

 

Certain information must also be stored for a specified period in accordance with Norwegian law. This period depends on the type of information and why it is to be stored:

• The Bookkeeping Act (Bokføringsloven) requires us to store transaction data for five years.

• The Limitation Act (Foreldelsesloven) means that we have to keep certain personal information about your customer relationship.

 

5 YOUR RIGHTS

You also have rights regarding how your personal data is used, including:

 

• The right to object to us processing your data. Here it is important to emphasize that in those cases where personal data is requested, such an objection will mean that it is not possible to buy or rent the service. The exception is the purchase of "Guest card" cards on the internet. In this case, it is possible to buy a card at the checkout without providing personal information.
   

• The right to request that your information be deleted or that further use of it be restricted.
   

• The right to request a copy of the information we hold about you.
   

• The right to correct, change or update the information you have provided to us.
   

• The right to contest any automated decision we make about you. An automated decision is a decision that is made without human intervention and that has legal consequences (e.g., credit check). We do not usually use automated decision making, but if we do, we will inform you about it when such decisions are made.

 

6 HOW YOUR INFORMATION is stored

Your information is stored in Skimore's database and Skidata, Wintersteiger (Easy Rent) and Walthard (Ski School). All our solutions are also secured by Cloudfare's CDN and all data here is stored in Google Cloud, except for Wintersteiger and Walthard which are stored locally. There is a limited number of service administrators who have access to this data, and all of them have signed a data processing agreement.

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7 HOW TO ACCESS AND CHECK THE INFORMATION

You can access your personal data in the Skimore app under Profile -> Edit profile.

 If you have other questions about the content of this declaration, wish to exercise your rights in accordance with point 5 or have other inquiries, you are welcome to contact us at personvern@skimoreoslo.no. You also have the right to complain to a supervisory authority, in Norway the Data Protection Authority, in accordance with GDPR article 13 (2) letter d.

Updated November 1st 2023.