This Privacy Policy has been established by Stena Line Travel Group AB (hereinafter ‘Stena Line Travel Group’, ‘STG’, ‘we’, ‘us’ or ‘our’ in this Privacy Policy) and applies to all our customers, suppliers and partners.
Sembo offers hotels, vacation homes, flights, ferries and other travel-related products. We are a part of the Stena Line Travel Group, which is one of Sweden’s largest travel agencies in the fast-growing area of individual travel. Our head office is in Helsingborg, and today we have more than 100 employees in Sweden, Denmark, Germany, the Netherlands and Spain.
Stena Line Travel Group AB is a wholly owned subsidiary of Stena Line.
In the course of its business, STG collects and manages personal data for the purposes described in this Privacy Policy. STG is responsible for the processing of personal data for these purposes.
If you have any questions about our privacy policy or how we process your data, contact us at the following address:
Stena Line Travel Group - Sembo
Box 1324
251 13 Helsingborg
e-mail: sembo@sembo.com
It is important to us to ensure that we treat your personal data in a safe and legal manner. This Privacy Policy explains how your personal data is collected and managed when you are a customer, supplier, or partner of STG and how you can access your personal data.
Personal data is information about an identified or identifiable natural person. An identifiable natural person is a person who can be identified directly or indirectly though, inter alia, an ID number or one or more factors that are specific to a particular person’s identity.
The information we collect about you is used for various purposes in connection with customer relations and the management of the Stena Line Travel Group. The information that is collected can vary depending on whether you are a customer, supplier, or partner, but generally, it will concern information about customer relationship management, supplier relationship management, or information regarding STG’s rights and obligations.
If you do not disclose your personal data, that may mean that STG will be unable to fulfil its obligations regarding your customer or supplier relationships.
In general, STG collects and processes public personal data. In certain cases, however, in connection with your booking, it may be necessary for us to process, to a limited degree, sensitive personal data (e.g. information about special meals on a flight or a need for specific assistance while travelling) as well as information about personal identification numbers (e.g. when a passport copy is required for a visa application) in order to be able to supply you with your desired trip.
Normally, STG collects the following information:
Information that you provide us with when you book a trip or become a member of one of our customer clubs, e.g. online via our website or by contacting our customer service, including contact details (first name, middle name, last name, address, telephone number, e-mail address and employment/job title), personal identification number (for visa applications, etc.), passport number, bank details, credit card information, preferences you communicate to us concerning the trip (e.g. information about special meals or special assistance needed due to a possible disability or illness, etc.), height, weight and clothing and shoe size (required when ordering equipment for ski and sports trips, etc.), the purpose of the trip, information about which languages you speak, citizenship, bonus card number, information you provide about your marketing or communication requests, as well as information you provide when you contact us regarding a problem or when you otherwise approach us in the capacity of a customer.
STG may also obtain credit information from credit reporting agencies to assess your financial soundness and creditworthiness.
Information you provide us with in connection with a delivery or cooperation agreement, including contact details (work, job title, first name, middle name, last name, address, telephone number and e-mail address), information you provide regarding preferences about marketing, communication and information which you provide when you contact us regarding a problem or when you contact us as part of our cooperation.
STG processes your personal data in order to fulfil the objectives stated below. Note that not all stated objectives, types of information, recipients of information, or types of information processing apply to you in all situations.
STG only uses your personal data insofar as it is necessary for the customer relationship, supplier relationship, or cooperative relationship (taking into account any special interests in each case) or according to applicable law.
STG processes your personal data in connection with the establishment and ongoing management of your customer relationship with us as part of our normal business, including trip bookings and supplying our other products (e.g. visa applications, travel insurance, transfer services, etc.), maintenance of customer records, credit ratings, billing, debt collection, marketing, statistics, etc.
If you are a supplier, partner, or point of contact for a supplier and/or partner that STG works with, we will use your personal data when we are in contact with the supplier and/or the partner. We also process your personal data in our CRM registry, which contains information about our points of contact at suppliers and partners.
STG will process your personal data in accordance with any laws and regulations that STG is subject to in connection with the management of its business or in order to fulfil various reporting obligations under applicable laws and regulations.
When you call our customer service, your conversation may be recorded. Recordings are saved for 6 months. We do this in order to know what oral agreements we have made. We may also use the conversation for internal training purposes. We thereby collect and store all personal data that feature in the conversation. You will be informed before the conversation begins and you have the right to request that the conversation not be recorded. You also have the right to request that a recording be deleted.
If you choose to subscribe to any of STG’s newsletters, we collect your name and your e-mail address in order to be able to send the newsletter. You can choose to stop receiving newsletters via our website or directly in the newsletter at any time.
When you use any of our websites, app, or any of our other digital services, we may collect data about your use of the service. Part of this data may be personal data, such as e.g. your IP address. We also collect data about how you navigate within the service, what searches you make, and which travel products you are interested in. If you are logged in to your account or provide data which make it possible for us to identify you, we combine data about your usage habits with any other data we have collected about you.
STG strives to ensure that all personal data we process is accurate and up to date. We therefore ask you to always notify us of any changes to your personal data such as address or payment information so that we can ensure that your personal data is always accurate and up to date. If you have created a travel profile with us, we ask you to log in to your profile and update it with any changes.
STG always processes the information about you in one or more of the following ways: (1) your consent,* (2) the conclusion or execution of your contract with STG, (3) in relation to STG’s legitimate interests, that is, the purposes described above, (4) the execution of the legal obligations to which STG is subject, (5) protecting your or another natural person’s main interests, (6) processing that is necessary for a legal claim to be established, enforced or defended, or (7) processing that is necessary to comply with STG’s or your employment, health or social obligations under national or EU legislation. There may also be situations in which we use your personal data for the legitimate interests of a third party in relation to the above purposes, unless outweighed by your interests.
*Personal data consent and your rights
Personal data that are used in order to send newsletters, customisation, or for marketing are processed on the basis of your consent. At any time, you may choose to revoke your consent by contacting us using the contact details above. If you revoke your consent, we will delete any personal data and cease the processing covered by the consent. You also have the right to request that the data about you be deleted, supplemented, or corrected, as well as the right to data portability.
It may be the case that the same personal data is processed both on the basis of consent and necessity or on the basis of other regulations. This means that even if you revoke your consent and the processing that is based on that consent ceases, the personal data may still remain with us for other purposes.
STG only transmits data that are necessary in the normal course of business, including data that are necessary for your trip and other products you purchased at the same time.
STG usually sends personal data to the following recipients when ordering travel and related products:
GDS is an IT network system owned or operated by a company that enables transactions between suppliers in the travel industry, primarily airlines, hotels, car rental companies, and travel agencies. GDS combines services, prices and bookings by bringing together products across the three travel sectors, i.e. flight reservations, hotel reservations and car rentals.
STG transmits personal data to airlines when booking your trip. In order to book your flight, we usually have to provide the following information to the given airline: first name, middle name, last name, departure airport, destination, date of departure and return trip, bonus card number, and special requests for your trip, including booking special meals and any need for special assistance on the plane or at the airport.
For trips to certain destinations, we may also need to provide your passport number to the airline.
STG sends personal data to any hotels that you may stay at during your trip. In order to book your hotel stays, we usually have to provide the following information to the given hotel: first name, middle name, last name, destination, date of departure and return trip, bonus card number, and special requests for your trip, including booking special meals during your hotel stay and any need for special assistance during your hotel stay in connection with a handicap or illness.
STG normally does not process car rentals in our own booking systems, unless you book your rental car yourself directly in the car rental company’s booking portal/website, which we refer to.
In those cases in which STG needs to send personal data to car rental companies, normally we have to provide your first name, middle name, last name, pick-up site, rental period, car type, bonus card number, and any specific requests for the vehicle rental such as specific measures in the case of handicap or illness, the use of child seats, etc.
STG sends personal data to bus companies if you travel by bus as part of your trip (e.g. on a day trip to famous tourist attractions, etc.). In order to book your bus trip, we usually have to provide your first name, middle name, last name, pick-up location, the date and time of the bus trip, destination, and special requests for the bus trip, including booking special meals during the bus trip and any need for special assistance during the bus trip in connection with a handicap or illness.
STG send personal data to passenger lines if you are going to travel by ferry as a part of your trip. In order to book your ferry trip, we usually have to provide your first name, middle name, last name, your vehicle registration number, destination, route, date and time of departure and return trip, and special requests for the ferry trip, including booking special meals and any need for special assistance during the ferry trip in connection with a handicap or illness.
A bed bank is an IT network system owned or operated by a company that enables transactions between suppliers in the travel industry, mainly hotels and travel agencies. STG sends personal to bed banks that book any hotels that you will use on your trip. In order to book your hotel stays via a bed bank, we usually have to provide your first name, middle name, last name, destination, date of arrival and departure, bonus card number, and special requests for your trip such as booking special meals during your hotel stay and any need for special assistance during your hotel stay in connection with a handicap or illness.
If, as part of your trip, you participate in excursions or need a transfer, STG may disclose your personal data to the relevant supplier or partner. The supplier or partner is responsible for organising the excursion or the transfer when you order the desired services with local suppliers at your destination. In order to be able to book your excursions, transfers, etc. we normally have to provide your first name, middle name, last name, date and time of arrival and/or departure, type of vehicle, and special requests related to the excursion or transfer such as booking special meals or any need for special assistance in connection with a handicap or illness.
As a part of your travel booking with us, you have the opportunity to purchase admission tickets to events and amusement parks such as Legoland and Disneyland Paris.
STG sends personal data to suppliers/partners that book any tickets that you will use on your trip. In order to book your tickets, we usually have to provide first name, last name, age, date and time, and special requests for the tickets, such as booking special meals and any need for special assistance purchasing tickets in connection with a handicap or illness.
As a part of your travel booking with us, you have the opportunity to purchase various forms of insurance, such as luggage or travel insurance. If you want to buy such insurance, we will submit your personal data to the insurance company so that they can register the insurance. In order to purchase insurance, we normally have to provide a first name, middle name, last name, e-mail address, destination, date of departure and return trip, and mode of travel to the insurance company.
As a part of your travel booking with us, you have the opportunity to rent equipment that you need on your trip, e.g. skiing equipment, diving equipment, or similar. If you want to rent such equipment, we will submit your personal data to the company at your destination from which you will rent the equipment. In order to book your equipment, we normally have to provide a first name, middle name, last name, type of equipment, pick-up location, rental period, and information about height, weight, clothing and shoe size to the rental company.
STG may also transmit and/or send your personal data to other suppliers and/or service suppliers in connection with the general conduct of our business, e.g. in connection with external administration of our IT system, analytics, marketing, debt collection, credit assessment, auditing, legal assistance, etc.
For more information about our suppliers’ and partners’ use and protection of your personal data, see their privacy policies and conditions.
STG strives to limit to the greatest possible extent the transmission of personal data that can be associated with you personally.
STG does not transmit your personal data if it is not required to provide its services or meet your needs.
Due to STG’s business, your personal data may be transferred to countries outside the EU/EEA when you book a trip with us. In order to be able to supply our services to you, in certain cases we have to use partners and suppliers outside the EU/EEA.
If it is not possible for us to disclose your personal data to a recipient outside the EU/EEA, STG will be unable to supply the desired trip to you. This applies when you book a trip for which we have to send your personal data to recipients outside the EU/EEA in order for the trip to be able to be made, e.g. to book flights, hotels, etc.
Data protection legislation in these countries may be less strict than in the rest of the EU/EEA, as the European Commission has determined that the level of data protection is not as high in these countries as within the EU/EEA.
STG has an obligation to ensure that a good level of protection exists for your personal data, an obligation we take seriously.
Personal data are not saved any longer than is necessary for the purposes for which they are collected, provided we are not obligated to store the data in order to comply with national law, such as statutory storage periods in connection with accounting, etc.
It is STG’s policy to protect personal data by taking the appropriate technical and organisational security measures. When your personal data are no longer needed, we will ensure that they are deleted in a secure way.
At any time, you have the right to exercise your rights under applicable legislation on data protection. You can, for example, request access to the personal data about you that STG has saved, or object to the processing of the data, including with respect to automatic decisions and profiles as well as to the use of your personal data for direct marketing. You can also request correction or deletion of any incorrect data about you, withdraw your consent to the processing of your personal data, and exercise your rights regarding data transfer.
If you want to exercise one or more of your rights, please contact us by e-mail:
sembo@sembo.com
Your request will be processed in accordance with applicable data protection statutes.
STG regularly evaluates and updates its privacy policy. For this reason, you should regularly check this privacy policy for any changes that can affect the processing of your personal data.