Privacy policy for the processing of information from guests, customers and suppliers

1 - Data controller


Moltkes Palæ is the data controller.


The contact information of Moltkes Palæ is:


Moltkes Palæ, Dr. Tværgade 2, 1302 Copenhagen K.
Contact person: Gina Cornali
Tel. +45 51 91 49 11 – email: gmc@moltkes.com


Moltkes Palæ handles all personal data in compliance with the applicable personal data legislation.


Moltkes Palæ enters into agreements with guests, customers and suppliers for the delivery – purchase and sale – of various services and products.


When a guest/customer orders and purchases one or more of the services of Moltkes Palæ, and in the process provides their personal data to Moltkes Palæ, the person consents to allow Moltkes Palæ to process the personal data of the guest/customer/supplier.


The same applies as regards any personal data shared by Moltkes Palæ's suppliers with Moltkes Palæ in connection with the submission of offers or conclusion of agreements with Moltkes Palæ.



2 - Moltkes Palæ's collection of personal data


Moltkes Palæ collects personal data in the following ways:


  • When a guest/customer a representative thereof chooses to obtain an offer for and/or buy one of Moltkes Palæ's services/products, or when a supplier gives an offer or sells products or services to Moltkes Palæ.
  • Through browser cookies and web beacons.
  • From social media.
  • From video and CCTV monitoring.
  • When suppliers enter into agreements with Moltkes Palæ or submits offers to Moltkes Palæ.

Collection and processing of personal data, see the above, will always be made under the applicable personal data legislation.



3 - Information that Moltkes Palæ collects


Moltkes Palæ collects the following personal data:

  • Name, address, telephone number, email address, date of birth and other general, non-sensitive personal data.
  • Purchase history
  • Information from Moltkes Palæ's social media accounts and other digital platforms belonging to Moltkes Palæ.
  • Browser information.
  • Information about the guest's/customer's business and relevant contact persons.
  • Information about the supplier's business and information about relevant contact persons and key persons, including key accounts.

A guest/customer may, voluntarily and at their own choice, provide Moltkes Palæ with additional personal data which the person believes may be helpful to Moltkes Palæ in the provision of services to the guest/customer/supplier, or which the said person thinks should be provided for security reasons.


This may include information about:

  • Handicaps
  • Allergies
  • Special food preferences
  • Other health or medical information

If a guest/customer/supplier chooses to voluntarily provide such information, consent is automatically given to Moltkes Palæ to register and store this sensitive information about the said party.


In addition to the information that Moltkes Palæ receives directly from guests/customers/suppliers, Moltkes Palæ will, in some instances, obtain or process additional information which Moltkes Palæ has received from third parties, e.g. a travel agency, another provider or an employee in the business where the data subject is employed.


In that case, the said third party is obliged to inform the said guests/customers/suppliers about Moltkes Palæ's terms and conditions and Moltkes Palæ's privacy policy. It is also the said third party's responsibility to ensure that there is the required legal basis for collection and processing of the information in question, including obtaining any required consent for processing of any sensitive information.



4 - What is the purpose of the data collection and processing?


Moltkes Palæ only collects the personal data necessary to perform the agreements entered into with guests/customers/suppliers on the delivery of services, e.g. purchase/sale of products or services.


It is the contents of the specific agreement and the nature of the service which determine which personal data Moltkes Palæ collects and processes, and which govern the purpose of the collection.


The purpose of collecting and processing personal data will primarily be:

  • Processing of the bookings and purchases made by guests/customers of Moltkes Palæ's services.
  • Processing of suppliers' offers for, and sale of, products and services.
  • Contact to the guest/customer before, during and after a booking.
  • Performance of the request of the guest/customer for an offer for or purchase of services.
  • Improvement and development of Moltkes Palæ's services.
  • Adjustment of Moltkes Palæ's marketing and other communication.
  • Analysis of the user behaviour of guests/customers/suppliers and marketing vis-à-vis that behaviour.
  • Adjustment of the communication of Moltkes Palæ's partners and marketing towards guests/customers/suppliers.
     

5 - Authority – the legal basis of the processing


Moltkes Palæ will generally process personal data because it is necessary to perform an agreement with Moltkes Palæ to which you as a guest/customer or supplier are a party. This may e.g. be in connection with a party/dinner/conference, visit to a restaurant and/or handling and performance of collaboration and supplier agreements.


Further, Moltkes Palæ will process personal data in connection with bookings before the holding of meetings, parties, conferences etc. and before the conclusion of supplier agreements.


In some cases, Moltkes Palæ's processing of personal data will take place as an element of Moltkes Palæ's pursuing a legitimate/objective interest which overrides the interests of the guest/customer/supplier (the data subject).


Such legitimate interest may e.g. be the preparation of statistics, customer surveys, marketing and analysis of general guest/customer behaviour for the purpose of generally improving the experience at Moltkes Palæ and the quality of Moltkes Palæ's services and products.


If, in connection with a visit to Moltkes Palæ, a guest/customer provides special personal preferences or consideration, including e.g. health information, handicaps, religious beliefs or similar, Moltkes Palæ only uses that information to show consideration had to the personal preferences of the guest/customer, your health etc.


In some situations, Moltkes Palæ receives personal data from a third party, e.g. a travel agency, agent or the like, e.g. in connection with group bookings. When this happens, the said third party is obliged to inform the said guests/customers/suppliers of Moltkes Palæ's terms and conditions and the contents of this privacy policy.



6 - The rights of the data subject


Under the rules of EU's General Data Protection Regulation, the data subjects (customers/guests/suppliers) have different rights.


  • A data subject is always entitled to get access to which personal data Moltkes Palæ processes about the data subject.
  • A data subject is always entitled to demand that the personal data which Moltkes Palæ stores about the data subject be rectified and updated.
  • A data subject is always entitled to demand that the personal data that Moltkes Palæ stores about the data subject be deleted. If a data subject requests deletion, all the information that Moltkes Palæ is not obliged to store according to the current legislation, is deleted. Deletion of the data subject's information may, in some cases, entail that Moltkes Palæ cannot perform any concluded agreements or deliver certain services to the data subject.

If any of the information that Moltkes Palæ has about the data subject was obtained with the data subject's consent, the data subject is always entitled to withdraw their consent, which means that the information is deleted or is no longer used by Moltkes Palæ. This does not apply to information, see above, which Moltkes Palæ is obliged to store according to the law.


The possibility of withdrawing the consent, request deletion etc. may, however, be limited for the purpose of protecting the privacy of other persons, business secrets and intellectual property rights, and e.g. for the purpose of the possibility of enforcing potential legal claims.


The data subject may at any time submit a request in writing to Moltkes Palæ for a list and a copy of any personal data about the data subject which Moltkes Palæ is in possession of.


A written request to that effect must be signed by the data subject and contain their name, address, telephone number and email address.


The data subject can also contact Moltkes Palæ if the data subject believes that their personal data is being processed contrary to the legislation or contrary to other legal obligations, e.g. the agreement/contract which the data subject has entered into with Moltkes Palæ.


Any written request should be sent to Moltkes Palæ, see contact information above under clause 1.

Moltkes Palæ will, to the extent possible within one month after receipt of the data subject's written request, send the information to the data subject's postal address.


If the data subject requests rectification and/or deletion of their personal data, Moltkes Palæ will assess if the conditions for the request have been met, and in such case Moltkes Palæ will implement the changes or deletion as soon as possible.


Moltkes Palæ reserves the right to deny requests that are in the nature of unfair repetition or which require disproportionate technical measures (e.g. the development of a new IT system) or which influence the protection of other data subjects' personal data, or in other situations which make it disproportionately resource-demanding or very complicated to meet the request.



7 - Security and sharing of personal data


Moltkes Palæ protects the data subject's personal data and has set guidelines that protect the data subject's personal data against any unauthorised publication and against any third parties gaining access to it or knowledge thereof.


Only the persons/employees of Moltkes Palæ, who by virtue of their job function need the data subjects' personal data, have access to it.


Moltkes Palæ checks on an ongoing basis that no unauthorised access is made to the data subjects' personal data.


Moltkes Palæ performs backup on an ongoing basis of all registered personal data.


In case of a security breach where there is a high risk of misuse of the data subjects' personal data, including e.g. identity theft, financial loss, loss of reputation and other types of misuse, Moltkes Palæ will inform the data subjects of the security breach as soon as possible.


Moltkes Palæ's security procedures are reassessed on an ongoing basis and updated in relation to technological developments.


Moltkes Palæ uses a number of external suppliers of IT services, IT systems, payment solutions etc.


Moltkes Palæ enters into continuous data processing agreements with all of Moltkes Palæ's suppliers whereby it is ensured, also in relation to external data processors, that they maintain a required and high protection level as regards the data subjects' personal data.


In some cases, Moltkes Palæ is legally obliged to disclose personal data or obliged thereto as a consequence of a decision from a public authority.


Moltkes Palæ deletes your personal data once Moltkes Palæ's legal obligation ceases or when the purpose of collecting and processing the information is no longer present.



8 - Cookies


Moltkes Palæ uses cookies. Further information about Moltkes Palæ's cookie policy can be obtained here: http://www.moltkes.com/page1983.aspx



9 - Complaints


A complaint about Moltkes Palæ's processing of personal data may be filed with the Danish Data Protection Agency, Borgergade 28, 5. 1300 Copenhagen K, Telephone: + 45 3319 3200 – Email: dt@datatilsynet.dk.



Moltkes Palæ · Dronningens Tværgade 2 · 1302 København K

Telefon +4533148066 · info@moltkes.com · CVR nr. 28477163

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