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Privacy Policy

1.     Introduction

We, Stena Line Scandinavia AB, registration number 556231-7825 ("Stena Line"), are the data controller for the processing of your personal data. All references to "we", "us" or "our" in this privacy policy refer to Stena Line. Our contact details can be found at the end of this privacy policy. We respect your privacy and are committed to protecting your personal data.

 

The following websites are referred to as our "Websites":

 

stenaline.se, stenaline.dk, stenaline.no, stenaline.fi, stenaline.pl, stenaline.lv, stenaline.lt, stenaline.ee, stenaline.ru, stenaline.pl, stenaline.cz, stenaline.de, stenaline.nl, stenaline.fr, stenaline.co.uk, stenaline.ie, stenaline.it, stenaline. es, stenalinetravel.com, wyjazdygrupowe.pl, szwecjazklasa.pl, blog.stenaline.se, blog.stenaline.dk, blog.stenaline.no, blog.stenaline.pl, blog.stenaline.co.uk, blog.stenaline.ie, blog.stenaline.nl, blog.stenaline.de.

 

Our Websites and other means of communication (email, telephone, support contact, social media, chat and paper forms) and Stena Line's services are hereinafter referred to as our "Services".

 

2.     Scope of privacy policy?

 

This privacy policy applies to our processing of your personal data when you as a customer and/or visitor to the Website use our Services, or if we receive your personal data from a person or organisation making a reservation in your name (e.g. the company where you are employed) or a travel agency that you or a person or organisation making a reservation in your name have hired. This policy contains, among other things, information about the purposes of our processing of your personal data, with whom we share your personal data and what rights you have with respect to your personal data.

 

If you wish to obtain information on our processing of personal data for members of our Loyalty Clubs (Extra Blue, Extra Gold or Business Traveller), see  Stena Line’s Loyalty Club Privacy Policy.

 

For information on how we handle cookies, see our Cookie Policy.

 

For information on camera surveillance onboard our ships, in our ports, terminals and offices and the processing of personal data in connection with it, see Stena Line’s CCTV-policy.

 

3.     What categories of personal data do we process?

 

Stena Line processes the following categories of personal data for customers and/or visitors to the Website who use our services:

 

(a)   Name

(b)   Date of birth

(c)   Age group (children 0-3 years and 4-15 years)

(d)   Gender

(e)   Contact details (address, telephone and/or mobile number, email address)

(f)    Payment details (Card type (American Express, Mastercard or VISA), Card number, Security code (CID/CVC/CVV), Validity period, IBAN, BIC, gift card/ bank cheques, etc. and payment type)

(g)   Possible number of accompanying children

(h)   Booking reference number

(i)    Itinerary information for the trip(s): destination, crossing times, arrival and departure dates, number of passengers, choice of cabin or reclining seat, cabin number, pre-orders (meals, drinks, snacks), any borrowed bedding or cots, pets (to the extent that you inform us), special requests to the extent that we are informed of them and any required cancellation insurance

(j)    Vehicle information: type of vehicle (car, motorhome, bicycle and/or trailer) and vehicle registration number

(k)   Your orders/purchase lists in terminal and ship shops

(l)    Booking history

(m) Promotional codes and security codes used (used to verify promotional codes)

(n)  Nationality

(o)   Passport or ID document details

(p)   Guest list (reserving customer and fellow travellers)

(q)   Your pet's ID number

(r)    Information on anyone declaring to be the parent of a minor

(s)   Date of suspension (if a passenger violates onboard security rules)

(t)    Disability or mobility impairment information (to the extent provided to us if you require assistance, have impaired hearing or vision, or require medication or a wheelchair or are visually impaired)

(u)   Information about special care or assistance that may be needed in an emergency (to the extent provided to us if you need special care or assistance)

(v)   Contact number in case of an emergency (to the extent provided to us)

(w)  Site information based on your IP address

(x)   Browser information (browser version)

(y)   Loyalty Club membership number

(z)   Responses to customer satisfaction surveys to the extent provided by you (booking reference number, telephone number and email)

(aa)                    Your employer and position (for business travellers)

(bb)                   Voice recordings (if the telephone call is recorded)

 

4.     Where do we obtain your personal data?

 

Stena Line obtains personal data from you when you reserve a trip with us, directly or through a travel agent. This also occurs when you sign up for our newsletters, use the contact form or our chat.

Stena Line also collects personal data from travel agencies whom you have instructed to provide your personal data to us. .

 

In addition, Stena Line collects your personal data from a person or organisation that makes a reservation in your name (e.g. the company where you are employed).

 

Stena Line may also obtain your personal data from other Stena AB companies that act as our data processors and collect your personal data on our behalf.

 

5.     What happens if you do not provide us with your personal data?

 

In order to make a reservation or use our other services, we need to have access to the personal data listed in section 3.

 

We are also required by law to process certain personal data about our passengers, and in particular: name, gender, nationality, date of birth, passport or ID document details. If you do not provide this information, we cannot allow you onboard our vessel. In other cases, the provision of personal data is voluntary, but refusal to provide the relevant data may result in your inability to exercise any rights you may have or to receive the assistance you need from us.

 

6.     For what purposes do we process your personal data and what is the legal basis for these processing activities?

 

Stena Line processes your personal data for the purposes set out below. We must have a legal basis for each purpose. Such legal grounds may be (i) that we have your consent to the processing activity in question, (ii) that the processing is necessary for the performance of a contract we have entered into with you, or (iii) that Stena Line or a third party has a legitimate interest in processing the personal data, which is not overridden by your interest in not having the personal data processed. The legal basis on which Stena Line relies is stated under each purpose below.

 

If your consent is specified as the legal basis for a purpose listed below, we may not process your personal data for that purpose without first obtaining your consent. You have the right to withdraw your consent at any time. However, this does not change the lawful status of consent-based processing that took place before the consent was withdrawn.

 

(a) Providing travel, accommodations and other contracted Services

 

Stena Line uses name, date of birth, age group, gender, contact details, payment details, number of accompanying children, booking reference number, itinerary, vehicle information, order/purchase lists in terminal and ship shops, booking history, promotional codes and security codes used in order to administer and provide your reserved journeys, accommodations, any pre-orders and Services in accordance with the Terms and Conditions of Carriage.

 

This processing of your personal data is based on our contractual obligations towards you. 

 

(b) Providing our Services

 

Stena Line uses names and contact details to communicate with you when you use our Services.

This processing of your personal data is based on our legitimate interests.

 

(c) Administration

 

Stena Line uses guest lists to administer refunds, insurance matters and customer complaints regarding your reservations.

 

This processing of your personal data is based on our legitimate interests.  

 

(d) The following processing is based on legal obligations:

 

-        information on disability / reduced mobility you provide to us in order to arrange for any assistance needed during the trip in accordance with EU Regulation 1177/2010 concerning the rights of passengers when travelling by sea and inland waterway

 

-        your payment details for the purpose of storing payment details, name, Loyalty Club membership number, contact details and, if applicable, tax identification number in accordance with the Swedish Accounting Act (1999:1078)) and/or regulations applicable in the relevant local market

 

-        name, gender, age group, nationality, date of birth and disability information and a contact number in case of an emergency (to the extent you provide such information to us) for the purpose of establishing passenger lists in accordance with Directive 2017/2109 amending Council Directive 1998/41/EC on the registration of persons sailing onboard passenger ships operating to or from ports of the Member States of the Community

 

-        name, gender, date of birth, age group, nationality and passport or ID details, for the purpose of maintaining passenger lists and conducting ID checks in accordance with the Swedish Sea Safety Ordinance (2003:438) and/or laws and regulations applicable in the relevant local market

 

-        where applicable: name, date of birth and passport or ID details, to the extent that this information is included on barred passenger lists received from police authorities. We use the lists to prevent barred passengers from travelling with Stena Line in order to comply with currently applicable laws and regulations.

 

-        Where applicable, depending on the route chosen: name, gender, date of birth, nationality, passport or ID details, vehicle registration number for the purpose of informing of entry into the UK in accordance with the UK Immigration Act (1971), Requirement for Passenger, Crew and Service Information.

 

(e) Improving our Services

 

We use your name, contact information, website information based on your IP address, browser information, booking reference number and itinerary to collect statistics about how you use our Services, in order to improve our Services by fixing bugs, quickly and easily identifying and resolving Website conversion issues, modifying the interface so that you can quickly find the information you are looking for, or highlighting relevant offers on the Website. We do this by conducting customer satisfaction surveys and market research or by analysing your use of the Services. Personal data that we use to improve our Services is aggregated as far as possible.

 

This processing of your personal data is based on our legitimate interests.

 

(f) Preventing misuse of Services

 

Your name, address and IP address may be used (as relevant in each specific case) to enable us to prevent misuse and credit card fraud. This processing of your personal data is based on our legitimate interests.

 

(g) Preventing suspended persons from reserving trips

 

Stena Line stores the suspension date, name, date of birth (personal ID number for Swedish citizens), passport or ID details and booking reference number of passengers who have violated our security rules onboard, in ports or at terminals, so that we can prevent these people from reserving trips. This processing of your personal data is based on our legitimate interests.

 

(h) Providing offers, discounts and upgrades based on your purchases

 

We use your name, contact information and itinerary to provide you with offers, discounts and upgrades based on your purchases. This processing of your personal data is based on our legitimate interests.

 

(i) Direct marketing and information

 

We use your name, contact details, itinerary and booking history, to the extent that you have (a) actively consented to direct marketing (opt-in), (b) signed up for our newsletter or Loyalty Club, and/or (c) have purchased Stena Line products and services and thereby provided this personal data to us when using our Services, to send newsletters, offers, relevant information about our Services 

We use your name, contact details, itinerary, to the extent that you have (a) actively consented to direct marketing (opt-in), (b) signed up to our newsletter or Loyalty Club, and/or (c) have purchased Stena Line products and services and thereby provided this personal data to us when using our Services, to send reminders about reservations and payments initiated but not completed.

 

We will send these to you by post, text message, email and other forms of electronic communication. 

These processing activities of your personal data are based on our legitimate interests.

 

You have the right to opt-out of direct marketing as described in section 6 (h)-(i) at any time via opt-out links in emails or in the settings in the My Pages section of our website.  If you do so, Stena Line will no longer send you such direct marketing.

 

(j) Handling customer complaints and defending and/or establishing legal claims

 

We use personal data only to the extent relevant in each specific case to handle customer complaints and to defend and/or establish legal claims. This processing of your personal data is based on our legitimate interests.

 

(k) Demonstrating compliance with legal requirements

 

Stena Line keeps documentation of passport and ID details, as well as information on anyone declaring to be the parent of a minor during ID checks, in order to demonstrate to the applicable authorities that we comply with the requirements for ID checks in the Swedish  Sea Safety Ordinance (2003:438) and/or laws and regulations applicable in the relevant local market. This processing of your personal data is based on our legitimate interests.

 

7.     Who do we share your personal data with?

 

In order to fulfil the purposes set out above, Stena Line may share your personal data with the following recipients:

a)     Stena AB (publ)

b)     Stena Rederi AB

c)     Stena Line Travel Group AB

d)     External payment providers

e)     Stena Line Ltd.

f)      Stena Line Irish Sea Ferries Ltd.

g)     Stena Line BV

h)     Stena Line GmbH & Co.KG .

i)      Stena Line Danmark A/S

j)      Stena Line Polska Sp.z o.o

k)     UAB Stena Line

l)      SIA Stena Line

m)   Retail & Food Services in Sweden AB

n)     Baltic RoRo Services GmbH & Co.KG .  

o)     Other shipping companies, bus companies, tour guides, organisations providing accommodation services and other subcontractors (where this is needed to provide your reserved trip)

p)     Police, customs and other authorities

q)     Insurance companies (e.g. Allianz, Axa/Uniqa)

r)      Scandinfo, Origo Group (for the purpose of conducting customer satisfaction surveys)

s)      Our external call centres: Moranti in Denmark, Sweden and Norway, and Transcom in Lithuania

t)      Our external check-in teams: e.g. Sartori & Berger

u)     Service providers that we engage in order to provide services, such as web hosts, mailing vendors, analytics providers, IT providers, event hosting services, etc.

v)     Assa Abloy for digital cabin keys

w)    Google (see further below in section 8)

x)     Facebook (see further below in section 9)

 

8.      The following applies to our partnership with Google and the use of their services for ‘remarketing’ and ‘lookalike audiences’:

 

On our website, we use the remarketing or "lookalike audiences" function provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). This function is intended to analyse the behaviour and interests of visitors.

 

Google uses cookies in order to carry out the analysis of the use of the website, which forms the basis for the creation of interest-based advertising. These cookies record the visits to the website and anonymous data on the use of the website. No personal data of the visitor to the website is stored. If you go to another website in the Google Display network after your visit, you will see advertising that is most likely to be related to the products and information you visited and displayed before.

 

The processing of personal data is carried out on the basis of Art. 6(1)(a) of the GDPR, whereby we display targeted advertising to the website visitor with the consent of the website visitor, in order to offer the website visitor personalised advertisements according to interest when they visit other websites in the Google Display network. You may object to this at any time.

 

You can find more information about Google Remarketing and the associated privacy statement at: https://www.google.com/privacy/ads/

 

On our website, we also use the online advertising programme Google AdWords and, as part of this, the conversion tracking function (evaluation of visits). Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). When you click on a Google ad, a conversion tracking cookie is placed on your computer. These cookies have a limited validity, they do not contain any personal data and can therefore not be used for personal identification. When you visit certain pages on our website and the cookie is active, Google and we may record that you have clicked on the ad and arrived at this page. All Google AdWords customers receive different cookies. So there is no risk that cookies can be tracked across the website from AdWords customers.

 

The information collected by this conversion cookie is used for conversion statistics. We get information about the total number of users who click on one of our ads and who have arrived at a page with a conversion tracking tag. However, we do not receive any information that can be used for personal identification of the user. The processing is done under Art. 6(1)(a) of the GDPR with your consent for targeted advertising and analysis of the effectiveness and impact of this advertising. You may object to this at any time.

 

For this purpose, you can prevent the storage of cookies on your computer by making the corresponding technical settings in your browser. However, we would like to inform you that in this case you may not be able to take full advantage of all features of this website. You will then not be recorded in the conversion statistics.

 

In addition, you can deactivate the settings for personalised advertising from Google.

More information and the Google privacy statement can be found at:

https://www.google.com/policies/privacy/

 

9.       The following applies to our cooperation with Facebook and the use of their services such as advertising, 'lookalike audiences' and 'custom audiences':

 

Stena Line uses Facebook's services to find new customers. This is done by using data collected from your use of our site to find similar prospective customers through Facebook. This data is anonymised and cannot be traced back to you.

 

Stena Line also uses Facebook for advertising purposes.

 

Facebook Ireland is the joint data controller with Stena Line for the joint processing of data in the context of Facebook's services, including 'lookalike audiences' and 'custom audiences'. Please see the information required under Article 13(1)(a) and (b) of the GDPR in the Facebook Ireland data policy at https://www.facebook.com/about/privacy

 

For information on how Facebook Ireland processes personal data, including the legal basis on which Facebook Ireland relies and the means by which the data subject may exercise rights against Facebook Ireland, please refer to the Facebook Ireland data policy at https://www.facebook.com/about/privacy.

 

Stena Line's processing is carried out on the basis of Art. 6(1)(a) of the GDPR, where Stena Line uses the 'lookalike audiences' as well as the 'custom audiences' services with the consent of the website visitor. You may object to this at any time.

 

You may also object at any time to the processing of personal data by Stena Line and/or Facebook Ireland insofar as the joint processing is based on Art. 6(1)(f) of the GDPR.

Stena Line and Facebook Ireland have: 

 

·        concluded a personal data control supplement in order to set out the respective parties' responsibilities to comply with the requirements of the GDPR in respect of the joint processing (as set out in the applicable product terms and conditions),

 

·        agreed that Stena Line is responsible for providing data subjects with at least the information set out in this section 9,

 

·        agreed that Facebook Ireland, between the parties, is responsible for enabling the rights of data subjects under Articles 15-20 of the GDPR in respect of the personal data stored by Facebook Ireland following the joint processing.

 

10.  Do we transfer your personal data outside the EU/EEA area?

 

Stena Line may transfer some of your personal data to the countries listed below which are outside the EU/EEA area. Where the European Commission has not determined that any of the countries below ensure an adequate level of protection for personal data, we will provide a description of the safeguards we take or the legal basis we rely on to ensure that the transfer of your personal data is in accordance with EU data protection laws.

 

Country: UK

Safeguard: adequacy decision (28 June 2021)

 

Country: USA 

Safeguard: The European Commission's Standard Contractual Clauses for the Transfer of Personal Data (2010/87/EU) and (2021/915/EU)

 

Please feel free to contact our Data Protection Officer if you would like more information on the above safeguards. The contact details can be found in section 14 of this privacy policy.

 

11.  How long do we keep your personal data?

 

Purpose

Type of personal data

Retention period

Providing offers, discounts and upgrades based on your purchases 

 

Name, contact details, itinerary and booking history

 

Up to two years after the customer relationship has ended

Improving our Services

Site information based on your IP address and browser information

 

For 26 months after you have used our Services

Direct marketing

Email address, name and previous destinations

 

As long as you subscribe to our newsletter

Providing travel, accommodations and contracted services

Name, date of birth, age group, gender, contact details, payment details, number of accompanying children, booking reference number, itinerary, vehicle information, your pet's ID number, orders and shopping lists in our terminal and ship shops, promotional codes and security codes used

 

Up to 14 months after the end of the trip

 

 

 

Demonstrating compliance with legal obligations

Passport and ID details and information on anyone declaring to be the parent of a minor

For three months to demonstrate to applicable authorities that we are in compliance with the Swedish Sea Safety Ordinance (2003:438) and/or laws and regulations applicable in the relevant local market

 

Complying with legal obligations

Name, date of birth and passport or ID details (for barred passengers)

Up to six months after a barred passenger list has been replaced by an updated version from the police authorities.

 

Prevent barred persons from reserving trips

Name, date of suspension, date of birth (personal identity number for Swedish citizens), passport or ID details and booking reference number

 

Up to three years after suspension

Administration

Guest list

Up to six months after completed travel

 

Complying with legal obligations

Information on disability / reduced mobility

One month after completion of the trip, in order for us to provide the necessary assistance in relation to reserved trips, accommodations and any orders/purchases in accordance with our contractual obligations to you and EU Regulation 1177/2010 concerning the rights of passengers when travelling by sea and inland waterways

 

Complying with legal obligations

Payment details, contact details, booking reference number, itinerary and vehicle information as well as Loyalty Club membership number and, if applicable, tax identification number

 

Up to ten years in accordance with the Swedish Accounting Act (1999:1078) and/or regulations applicable in the relevant local market

Complying with legal obligations

name, gender, age group, nationality, date of birth and disability information and a contact number in case of an emergency (to the extent you provide such information to us)

Until the ship reaches its destination and then for further 24 hours, in accordance with the Swedish Sea Safety Ordinance (2003:438) and/or laws applicable in the relevant local market and Directive 2017/2109 amending Council Directive 1998/41/EC on the registration of persons sailing onboard passenger ships operating to or from ports of the Member States of the Community

 

Handling customer complaints and defending and/or establishing legal claims

Only relevant personal data

For as long as your personal data is reasonably necessary for Stena Line to handle customer complaints and/or defend and/or establish legal claims (normally as long as the relevant legal limitation period)

 

12.  What rights do you have?

 

Below is a summary of your rights under EU data protection law. There is no cost to exercise these rights, and you can do so by sending an email or letter to the addresses listed at the end of this document. You can also use the contact form on the website.

 

When you receive an email regarding a reservation you have made through our Services, it will contain a link to the reservation so that you can update it. Please do not hesitate to contact us if you have any questions regarding your rights (see contact details at the end of this document).

 

Stena Line will always assess whether a request to exercise these rights is valid. Not all rights set out below are absolute. There may be exceptions.

 

In addition to the rights set out below, you always have the right to lodge a complaint about Stena Line's processing of your personal data with a supervisory authority.

 

(a)        Right of access. You have the right to obtain, upon request, a copy of your personal data processed by Stena Line and also to obtain additional information about Stena Line's processing of your personal data.

 

(b)        Right to rectification. You have the right to have your personal data corrected and/or completed if it is inaccurate or incomplete.

 

(c)        Right to erasure. You have the right to request Stena Line to delete your personal data without undue delay in any of the following circumstances:

 

-       The personal data is no longer needed for the purpose for which it was originally collected or otherwise processed

-       You withdraw your consent to a processing activity for which there is no other legal basis

-       You raise a valid objection to the processing of your personal data

-       The personal data has been processed unlawfully

-       The personal data must be deleted to comply with a legal requirement

 

(d)        Right to restrict processing. You have the right to request restriction of the processing of your personal data in any of the following circumstances:

 

-       The accuracy of the personal data is under investigation

-       The processing is unlawful or no longer necessary for its purposes, but you object to the deletion of your personal data and request restriction instead

-       Stena Line no longer needs the personal data, but you need the personal data to establish, exercise or defend a legal claim

-       You have objected to the processing of your personal data and your objection is under investigation

 

(e)        Right to data portability. In certain circumstances, you have the right to receive the personal data about you that you have provided to Stena Line for the purpose of transferring it to another service provider, if the processing of the personal data is based on your consent or the performance of a contract.

 

(f)         General right to object. You have a general right to object at any time to the processing of your personal data based on Stena Line's legitimate interests. We must then show that we have a compelling legal basis for the processing or that we need the personal data to establish, exercise or defend legal claims.

 

(g)        Right to object to direct marketing. You have the right to object at any time to the processing of your personal data for direct marketing purposes. Stena Line may then no longer process your personal data for this purpose.

 

13.  Information about recording telephone calls

 

Stena Line may record telephone calls with customers based on our legitimate interest for various business purposes. We do so, among other things, to improve the quality of customer service and information provided, for training purposes of our employees, to report the type and number of telephone inquiries, information in the telephone call that may be used in the event of a dispute about the content of the call and/or to confirm any arrangements made during the call, and to demonstrate compliance with applicable laws and regulations.

 

You will be informed in advance that the call will be recorded. You have the opportunity to object to the recording by ending the call. Alternative ways of communicating with us can be found on our website under Contact.

 

Recordings will be saved for a limited period of time (no longer than required or permitted by applicable law, including applicable statutes of limitations for claims).

Personal data collected during a telephone call will be processed in accordance with the above provisions of Stena Line's privacy policy for customers making reservations and using our websites.

 

14.  How can you contact us?

 

You can contact us through the following communication channels:

 

Head Office:

Address: Stena Line Scandinavia AB, 405 19 Gothenburg, Sweden

Telephone: + 46 770-57 57 00

Email: info.se@stenaline.com

 

We have a Data Protection Officer whom you can contact if you have any questions about the processing of your personal data. Please feel free to contact our Data Protection Officer at dpo@stenaline.com.