5. What Do We Use Your Personal Data For?
Greenland Travel processes your personal data to fulfill the purposes set out below. Please note that not all of the stated purposes, categories of information, recipients of information, or types of processing apply to you in all cases.
Greenland Travel processes your personal data only to the extent necessary in connection with your customer, supplier, or cooperation relationship (taking into account any relevant interests in each individual case) or as required by applicable law.
5.1 Customer Administration
Greenland Travel processes your personal data in connection with the establishment and ongoing administration of your customer relationship with Greenland Travel as part of the operation of our business, including the booking of travel and the delivery of our other products and services (such as visa applications, travel insurance, transfer services, etc.), maintaining our customer records, credit assessments, invoicing, debt collection, marketing, statistics, etc.
All statistics and analyses are prepared in anonymized form and therefore do not contain information that can be directly attributed to you as an individual.
5.2 Administration of Supplier and Cooperation Relationships
Greenland Travel processes your personal data in connection with the administration of supplier and/or cooperation relationships where you are a supplier or business partner, or a contact person at a supplier or business partner with whom Greenland Travel cooperates as part of operating our business, including maintaining our CRM register containing information about our contact persons at suppliers and business partners.
5.3 Compliance with Applicable Laws and Regulations
Greenland Travel processes your personal data in connection with compliance with laws and regulations to which Greenland Travel is subject in connection with the operation of the business, or to fulfill various reporting or disclosure obligations under applicable laws and regulations.
Greenland Travel does not use your personal data to make decisions based solely on automated processing, including profiling.
Greenland Travel strives to ensure that all personal data we process is accurate and up to date. We therefore ask you to inform us of any changes to your personal circumstances (for example, changes to your address or payment information) so that we can ensure your personal data remains accurate and up to date. If you have created a travel profile with us, we ask that you log in to your profile and update it if there are any changes.
6. Sharing of Personal Data
Greenland Travel only discloses information to the extent necessary to operate our business, including to deliver your trip and the other products and services you have purchased from us in connection with the trip.
In connection with booking a trip and related products, Greenland Travel will typically disclose personal data to the following recipients:
6.1 Global Distribution Systems (GDS)
A GDS is an IT network system owned or operated by a company that enables transactions between travel industry service providers, primarily airlines, hotels, car rental companies, and travel agencies. A GDS connects services, prices, and bookings by consolidating products across the three travel sectors: airline reservations, hotel reservations, and car rentals.
Greenland Travel uses the following GDS as part of our business operations: Amadeus.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and on our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the agreement for those services.
If special categories of personal data are disclosed, for example, in connection with special assistance requirements during the trip, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
6.2 Airlines
Greenland Travel discloses personal data to airlines in connection with booking your trip. For the purpose of booking your flight, we will typically disclose information such as first name, middle name(s), surname, departure airport, destination, departure and return travel dates, loyalty card number, special requests relating to your trip, including requests for special meals during the flight, and any need for special assistance on the aircraft or at the airport to the selected airline.
In connection with travel to certain destinations, we may also disclose your passport number to the airline.
When booking your flight, we must make the reservation in accordance with the airline’s seat reservation rules. This may mean that your flight reservation is classified as a group reservation under the airline’s rules, even if you have not booked a group trip. This may, among other things, be due to the reservation price, special cancellation terms attached to the reservation, and other factors.
If this is the case, the airline processes information about the passengers classified within the same reservation as a group. This means that, in certain cases, passengers classified as traveling in the same group may access the names of other passengers in that group through the airline’s electronic self-service solutions.
If you are classified as traveling as part of a group, the other passengers in the relevant classification group may, therefore, in certain cases, access information about your name and the fact that you are traveling on the relevant flight through the airline’s electronic self-service solutions.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and our legitimate interest in providing travel services to individuals participating in the flight who are not themselves direct parties to the agreement for the trip.
If special categories of personal data are disclosed, for example, in connection with special assistance requirements during the flight, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
6.3 Hotels
Greenland Travel discloses your personal data to the hotels you will stay at during your trip. For the purpose of booking your hotel accommodations, we will typically disclose information such as first name, middle name(s), surname, destination, arrival and departure dates, room category, loyalty card number, special requests relating to your trip, including requests for special meals during the hotel stay, and any need for special assistance during the hotel stay due to disability or illness.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and on our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the agreement for those services.
If special categories of personal data are disclosed, for example, in connection with special assistance requirements during the stay, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
In cases where the accommodation provider requires receipt of a copy of your passport, we use Section 11(2)(2) of the Danish Data Protection Act as the legal basis for disclosure, as we will request your consent for this.
6.4 Car Rental Companies
Greenland Travel discloses personal data to car rental companies if you require a vehicle during your trip. For the purpose of booking your rental car, we will typically disclose information such as first name, middle name(s), surname, pick-up location, rental period, vehicle category, loyalty card number, special requests relating to the vehicle rental, including special arrangements relating to disability or illness, child seats, etc.
Greenland Travel uses the following car rental companies in its operations: Europcar, Hertz, Avis, and Sixt.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of car rental services. Otherwise, we rely on Article 6(1)(f) of the GDPR and our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the car rental agreement.
If we disclose special categories of personal data to the car rental company, for example, in connection with ordering special equipment, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
6.5 Bus Companies
Greenland Travel discloses personal data to bus companies if you are traveling by bus as part of your trip (for example, for day tours to well-known tourist attractions). For the purpose of booking your bus trip, we will typically disclose information such as first name, middle name(s), surname, pick-up location, date and time of the bus trip, destination, and special requests relating to the bus trip, including requests for special meals during the journey and any need for special assistance during the trip due to disability or illness.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of the bus trip. Otherwise, we rely on Article 6(1)(f) of the GDPR and our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the bus trip agreement.
If we disclose special categories of personal data to bus companies, for example, in connection with special assistance requirements during the bus trip, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
6.6 Cruise Lines and Other Tour Operators at Sea
Greenland Travel discloses personal data to Cruise lines or other tour operators if you are to travel by ship as part of your trip (for example, in connection with day tours to well-known tourist attractions, cruises, etc.). For the purpose of booking your sea voyage, we will typically disclose information such as first name, middle name(s), surname, destination, itinerary, departure and return dates and times, and special requests relating to the voyage, including requests for special meals during the journey and any need for special assistance during the voyage due to disability or illness.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of the sea voyage. Otherwise, we rely on Article 6(1)(f) of the GDPR and our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the agreement regarding the sea voyage.
If we disclose special categories of personal data to shipping companies, for example, in connection with special assistance requirements during the voyage, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
In cases where the shipping company requires receipt of a copy of your passport, we use Article 6(1)(a) of the GDPR and Section 11(2)(2) of the Danish Data Protection Act as the legal basis for disclosure, as we have obtained your consent for this.
6.7 Bedbanks
A bedbank is an IT network system owned or operated by a company that enables transactions among travel industry service providers, primarily hotels and travel agencies, as well as end customers. Greenland Travel discloses personal data to bedbanks to book the hotels you will use during your trip.
For the purpose of booking your hotel accommodations through a bedbank, we will typically disclose information such as first name, middle name(s), surname, destination, arrival and departure dates, room category, loyalty card number, special requests relating to your trip, including requests for special meals during the hotel stay, and any need for special assistance during the hotel stay due to disability or illness.
Greenland Travel uses the following bedbanks as part of our business operations: Hotels.com, Booking.com, and Totalstay.com.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the hotel stay agreement.
If special categories of personal data are disclosed, for example, in connection with special assistance requirements during the hotel stay, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
6.8 Travel Agents
If, as part of your trip, you participate in excursions or require transfers, Greenland Travel may disclose your personal data to travel agents. The travel agent’s task is to arrange the relevant excursion or transfer by booking the requested services with local suppliers at the destination.
For the purpose of booking your excursions, transfers, etc., we will typically disclose information such as first name, middle name(s), surname, arrival and/or departure dates and times, type of vehicle, destination, and special requests relating to the transfer or excursion, including requests for special meals and any need for special assistance due to disability or illness.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and on our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the agreement for those services.
If special categories of personal data are disclosed, for example, in connection with special assistance requirements during accommodation, transfers, or excursions, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
In cases where the local supplier requires receipt of a copy of your passport, we use Article 6(1)(a) of the GDPR and Section 11(2)(2) of the Danish Data Protection Act as the legal basis for disclosure, as we have obtained your consent for this.
6.9 Insurance Companies
When booking your trip with us in Denmark, you can purchase travel and/or cancellation insurance. If you choose to purchase such insurance, we will disclose your personal data to the insurance company to arrange the insurance policy.
For the purpose of arranging travel insurance and/or cancellation insurance, we will typically disclose information to the insurance company such as first name, middle name(s), surname, email address, destination, departure and return dates, and type of travel.
Greenland Travel cooperates with the following insurance company as part of our business operations: Ergo.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of insurance services. Otherwise, we rely on Article 6(1)(f) of the GDPR and our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the insurance services agreement.
6.10 Equipment Rental Companies
As part of booking your trip with us, you may rent any equipment you need during your trip, such as ski or diving equipment. If you choose to rent such equipment, we will disclose your information to the company at your destination from which the equipment will be rented.
For equipment rental, we will typically disclose information to the rental company, such as first name, middle name(s), surname, type of equipment, pick-up location, rental period, height, weight, clothing size, and shoe size.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and on our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the agreement for those services.
If we disclose special categories of personal data to the equipment rental company, for example, in connection with ordering special equipment related to a disability, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
In cases where the equipment rental company requires receipt of a copy of your passport, we use Article 6(1)(a) of the GDPR and Section 11(2)(2) of the Danish Data Protection Act as the legal basis for disclosure, as we have obtained your consent for this.
6.11 Special Information Regarding Qualified Offers
When choosing Greenland Travel, you can receive a qualified travel offer. A qualified offer is an offer in which, in connection with preparing the offer, a preliminary reservation for the requested trip is made for you. This allows you to reserve a seat on your desired departure up to 3 days before deciding whether to issue a ticket for the preliminary reservation or cancel it.
To provide a qualified offer, we disclose information about you and the requested reservation to a GDS (as described above), which then makes the preliminary booking with the airline, hotel, etc.
As part of obtaining the qualified offer, information about your employees may be disclosed to several new independent data controllers (GDS providers, airlines, hotels, etc.), and your information may therefore be stored by these recipients after the expiration of the offer, including in cases where the offer is canceled.
In addition, Greenland Travel may disclose and/or transfer your personal data to other suppliers and/or service providers in connection with the ordinary operation of our business, for example, in relation to external administration of our IT systems, analytics services, marketing services, debt collection, credit assessments, auditing, legal assistance, etc.
For further information about how our suppliers and business partners process and protect your personal data, please refer to their respective privacy policies and terms and conditions.
Greenland Travel seeks to limit the disclosure of personal data in personally identifiable form to the greatest extent possible to reduce situations in which information that can be directly attributed to you personally is disclosed.
Greenland Travel does not disclose your personal data unless necessary to carry out our business operations or to fulfill your needs.
6.12 Providers of Tickets, Excursions, etc.
If, as part of your trip, you participate in excursions, receive admission tickets to attractions or experiences, or engage in similar activities, we may disclose your personal data to the providers of these services.
For the purpose of booking your excursions, admission tickets, etc., we will typically disclose information such as first name, middle name(s), surname, arrival and/or departure dates and times, type of vehicle, destination, and special requests relating to the excursion or experience, including requests for special meals and any need for special assistance due to disability or illness.
The supplier responsible for providing the requested services at the destination may also require receipt of a copy of the passports of the individuals receiving the service. If this is the case, we will request your consent to send them a copy of your passport.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and on our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the agreement for those services.
If special categories of personal data are disclosed, for example, in connection with special assistance requirements, we use Article 9(2)(a) of the GDPR in conjunction with Article 6(1)(a) of the GDPR as the legal basis for processing, as in such cases we will request your consent for this processing.
In cases where the supplier at the destination requires receipt of a copy of your passport, we use Article 6(1)(a) of the GDPR and Section 11(2)(2) of the Danish Data Protection Act as the legal basis for disclosure, as we have obtained your consent for this.
6.13 Visa Processing Agencies
If we are required to arrange a visa for you, we disclose personal data to visa processing agencies or to the embassy of the country issuing the visa. To obtain your visa, we will most often need to submit your passport. In some cases, however, it may be sufficient to submit a copy of your passport.
In addition, we typically disclose information such as your arrival and departure dates and times, contact information for your next of kin, information regarding the purpose of your trip, and your nationality. In certain cases, we may also disclose information regarding your travel insurance coverage.
We use Article 6(1)(b) of the GDPR as the legal basis for disclosure when you are a party to the agreement we have entered into regarding the provision of travel services. Otherwise, we rely on Article 6(1)(f) of the GDPR and on our legitimate interest in providing travel services to individuals participating in the trip who are not themselves direct parties to the agreement for those services.
When we are required to submit your passport or a copy of it as part of the visa application process, we disclose your date of birth. In such cases, we use Article 6(1)(a) of the GDPR and Section 11(2)(2) of the Danish Data Protection Act as the legal basis for disclosure, as we have obtained your consent for this.
6.14 Other Recipients
In addition, we may disclose and/or transfer your personal data to other suppliers and/or service providers in connection with the ordinary operation of our business, for example, in relation to external administration of our IT systems, analytics services, marketing services, debt collection, credit assessments, auditing, bookkeeping, legal assistance, disputes, etc.
As part of our marketing and website analytics, we also share digital identifiers, including your IP address and browser information, with our analytics and advertising partners. This specifically includes Google in connection with our use of Google Analytics and Google Ads, for the purpose of improving our online visibility and measuring the effectiveness of our advertising.