REGISTER

The processing of personal data is based on the proper execution of information sharing, the provision and delivery of products and services, the conduct of studies and campaigns, competitions, advertising and marketing through websites maintained by the Registrar. Personal data will be processed for the purposes of establishing, implementing and enforcing a customer relationship or other contractual relationship, proper identification of a person participating in a contest or other campaign, information, analysis, statistics, maintenance and development required for membership, contractual, direct marketing, opinion polling, and market research, to the extent and to the extent permitted by law, unless the User prohibits such collection and storage of personal data, and for the purposes for which he or she has explicitly consented.

1. THE REGISTER HOLDER

Aurora Estate

Tirroniementie 4

95980 Ylläsjärvi

pp. +358 10 579 4080

2. THE CONTACT POINT ON THE REGISTER

Janne Pasma, janne@louru.fi +358 400 833354

3. NAME OF THE REGISTER

Aurora Estate Customer Registry

4. PURPOSE OF THE PROCESSING OF PERSONAL DATA AND LEGAL BASIS

Personal information is collected for a specific, explicit and legitimate purpose in order to fulfill the contractual obligations of the customer. The register gathers information from sources of customers and stakeholders.

Personal data will be collected in accordance with this Privacy Policy and will under no circumstances be used, altered or transmitted in any way other than as described in this Privacy Policy.

5. CONTENTS OF THE REGISTER

The register contains personal information of Aurora Estate Oy’s customers, such as name, address, telephone number, e-mail address, personal identification number, language, customer group and other customer relationship management information, for example food allergies.

6. REGULAR SOURCES OF INFORMATION

The personal data of the customer register is collected from the registered person and obtained from partners.

7. REGULAR DISCLOSURE OF DATA

Information will be provided to the authorities in cases required by law. The information may also be transferred to the marketing register of Aurora Estate Oy. Aurora Estate Oy will, on an individual basis, disclose customer or stakeholder information to a designated party if the person in question requests Aurora Estate Oy to do so or if, pursuant to law, the hotel is required by law to disclose individually identified information from a database held.

8. DATA TRANSFER TO THIRD COUNTRY OR INTERNATIONAL ORGANIZATION

The company’s web services are located on Finnish servers. However, website user information is stored in the Google Cloud Visitor Tracking Google Cloud Platform, which may also be located outside the EEA (Privacy Shield countries). Otherwise, personal data will not be transferred outside the EU or the EEA.

More information https://privacy.google.com/businesses/adsservices/

9. RIGHTS OF THE REGISTERED / SUBSCRIBER

The data subject has the following rights under Articles 12 to 22 of the General Data Protection Regulation:

• The data subject’s right of access

• Right of rectification

• The right to erasure (‘the right to be forgotten’)

• The right to restrict processing

• Notification obligation to correct or delete personal data or to restrict processing

• The right to transfer data between systems

• Oppose

• Prohibit the processing and disclosure of information about him / her in direct mail, distance selling and other direct marketing, market and opinion polling

• In addition, the data subject has the right to object to data processing, automatic decision making and profiling.

The request for verification must be in writing, signed by the controller contact person, and include a copy of the photo ID.

10. PRINCIPLES FOR THE PROTECTION OF THE REGISTER

The data are processed electronically in the service provider’s systems. Persons employed by Aurora Estate Oy, or otherwise employed by Aurora Estate, who have the following responsibilities include:

• Marketing and communication

• Customer communication including customer reservation management

All information is used only by the designated persons or staff of Aurora Estate Oy for the above purposes. All users are bound by a duty of confidentiality and each user has their own username and password.

The information is collected in service databases, which are protected by firewalls, passwords and other technical means. Access to the databases is restricted to necessary persons only. The machines are kept secure so that unauthorized persons do not have access to the records.

11. DATA DELETION AND STORAGE PERIOD

Aurora Estate Oy will delete customer data from the register when there is no longer any commercial basis for processing the data. Personal data will be processed for the duration of the customer relationship and thereafter for the duration of warranty and defect liability.

However, data will not be deleted unless otherwise required by law or the competent authority has initiated a process that requires Aurora Estate Oy to retain the data or other party has applied to the Finnish courts for a security decision on the information.

User-level and event-level data stored by Google Analytics will be automatically deleted from Analytics servers after 26 months.

Contacts shall be kept for a maximum of one year, after which they shall be removed from the registers, unless there are legal grounds for doing so pursuant to law or regulation.

12. Other

Guests staying at the hotel must complete the accommodation card when staying at the hotel. The accommodation declaration is a document to be filled in by the authorities for travelers and kept in accordance with official regulations.

13. ACCEPTANCE OF THE PRIVACY STATEMENT The privacy statement was approved on May 23, 2018 and updated on October 1, 2019