1 INTRODUCTION
Goto HUB ApS (CVR. no. 44247437) (“GOTO”) wants to make natural attractions, trips and experiences available in an easy and responsible way. GOTO is the licensee of a digital market Platform (the “GOTO Platform"). The activity providers (the “Activity Provider”) are suppliers of activities, tours and experiences (the "Product") that offer their Product for sale on the GOTO Platform to customers (the "Customer"). People who use the GOTO Platform, whether an Activity Provider, Customer or otherwise, are referred to in the following as “Users”.
GOTO values your privacy rights and has taken reasonable steps to protect your privacy, including by implementation of physical, technical and organizational measures, to prevent loss, alterations, theft and unauthorized access to information stored and otherwise processed.
This Privacy Policy provides you with information about how GOTO collects, processes and discloses your personal data as a data controller and for what purpose, as well as your rights in this context. GOTO will process personal data in accordance with the applicable data protection legislation at all times.
If you have any questions related to GOTO's processing of your personal data or this Privacy Policy, you can contact us by sending an email to: support@gotohub.no
2 ROLES IN THE PROCESSING OF PERSONAL DATA
1.1 Introduction
The data controller is the one who determines the purpose and means for the processing of personal data. A data processor is someone who processes personal data on behalf of the data controller.
GOTO is the data controller for the processing of personal data when GOTO determines the purpose of the processing and which funds to use. GOTO is the data controller for the processing of personal data about Users of the GOTO Platform for the purpose of being able to respond to inquiries from Users, enter into agreements with Activity Providers regarding the advertising of the Product on the GOTO Platform. GOTO is also the data controller for the processing of personal data about Customers for the purpose of managing the sale and payment of the Product and associated administration, including the registration and communication with customers.
GOTO and the Activity Provider have a separate processing responsibility for the processing of personal data because GOTO determines for itself the purpose of the processing of the Users of the GOTO Platform and the Activity Provider decides for itself the purpose of the processing of personal data for its Customers.
GOTO will not be a data processor in its processing of personal data because GOTO itself determines the purpose of the personal data and does not collect information on behalf of the Activity Provider that GOTO does not itself need in order to provide the GOTO Platform to the Activity Provider and the Customer.
1.2 GOTO as data controller
GOTO processes personal data in connection with you as a User registering as a user on the GOTO Platform, sending us an inquiry via the GOTO Platform or otherwise contacting us, entering into an agreement with us about advertising, or if you as a Customer make a purchase and payment of a Product on the GOTO Platform, as well as by other follow-up of the Activity Provider, the Customer or the User.
This means that GOTO is the data controller for the processing of personal data about:
3 PERSONAL DATA PROCESSED, PURPOSE AND LEGAL BASIS
As data controller, GOTO collects your personal data in various ways, such as when you register as a User or purchase a Product, as well as by your other use of our website or by phone/email or other contact.
GOTO may process your personal data in connection with the following processing activities:
Cookie Policy
GOTO uses cookies and similar technologies for various purposes, including enhancing your experience on our platform and understanding how our services are used. Here are the systems and their descriptions along with their average expiry time:
By using our website, you consent to the use of these cookies unless you have disabled them. However, disabling cookies may affect the functionality of our website and your user experience.
2 MINORS
The age limit for Users or Customers is 18 years.
Minors aged 15 years or older can consent to the use of personal data themselves. This privacy policy therefore also applies to those who are 15 years of age or older. You can withdraw your consent yourself. Guardians of minors may also withdraw the consent of minors.
We do not knowingly process personal data of minors under the age of 15.
3 RETENTION PERIOD
GOTO will not store your personal data for longer than is necessary to achieve the purposes for which the personal data was collected. If the processing relies on consent, the processing will cease when you withdraw your consent. You can withdraw your consent at any time.
As a general rule, GOTO will delete personal data about Users who have created user profiles when the user profile is deleted on the GOTO-Platform.
The personal data will nevertheless be retained for as long as is necessary for GOTO to fulfil statutory and legal obligations, including requirements for continued storage under accounting legislation, as well as to the extent necessary to safeguard GOTO's rights.
4 DISCLOSURE TO THIRD PARTIES
GOTO will only disclose personal data to third parties to the extent we have a legal basis for this.
If you have purchased a Product or have a question about a Product, we will share your personal data with the Activity Provider who has sold you or is a seller of the Product, ref. section 3 above. In such cases, the processing will be subject to this Activity Provider's Privacy Policy. GOTO assumes no responsibility for Activity Provider or how it processes your personal data. We therefore recommend that you familiarize yourself with the privacy statement and the Purchase Agreement with the Activity Provider.
GOTO may use data processors to collect, store or otherwise process personal data on our behalf. The relationship with such data processors will be regulated through a data processing agreement, which ensures, among other things, confidentiality and safeguarding information security at all levels. Your personal data may be subject to processing or storage outside the EU/EEA. GOTO will ensure that your personal data is subject to adequate security guarantees, including through the use of the EU Standard Terms and Conditions for such transfer or when transferring to countries pre-approved by the European Commission. Please contact us if you would like more information about this.
GOTO may in some cases disclose personal data to public authorities in order to comply with statutory requirements or comply with government orders, for example to comply with obligations under accounting or tax legislation. Public authorities will be the data controller for any personal data we disclosed by us in such cases.
5 LINKS TO OTHER WEBSITES AND SOCIAL MEDIA
The GOTO Platform may contain links to other websites. These websites have their own privacy policies that describe how personal data is collected and processed. If you provide personal data to such third-party website, the processing will be subject to that website's privacy policy. GOTO assumes no responsibility for such third party websites or how they process your personal data. We therefore recommend that you familiarize yourself with the privacy policies and terms of use of such third-party websites when you visit and use those websites.
When you "like" or become a member of GOTO's Facebook page or GOTO's pages on other social media sites, this will be shared with the Platform in question. The same goes for other activity on GOTO's social media pages, such as content you post and posts you like. The relevant Platform will be responsible for the personal data it collects and processes. More information about this processing and your rights follows from the individual platform's privacy policy.
6 YOUR RIGHTS
As a data subject, you are entitled to request access to the personal data we process about you, request that GOTO updates or corrects your personal data and/or withdraw any consent to processing. In some circumstances, you are also entitled to request that your personal data is erased, request restriction of processing or object to processing and/or request data portability (the right to have personal data disclosed or transferred in an appropriate format). If the processing is based on your consent, you can withdraw it at any time.
If you wish to exercise your rights, you can contact us using the contact details provided above in section 1. You also have the opportunity to correct your contact information in the GOTO Platform if you have registered as a User.
You have the right to complain about our processing of your personal data to the Norwegian Data Protection Authority. We encourage you to raise any objections to GOTO's processing of personal data with us first.
6 CHANGES TO THE PRIVACY STATEMENT
The current privacy policy will be available on our website at any time. In the event of changes to GOTO's processing of personal data, this Privacy Policy will be updated on the website.
If we make changes to the processing of personal data that requires your consent, we will obtain your consent before we initiate such a change in processing.
Last updated: 2024-01-10