1. Controller

Joulupukin Juna Oy
Rautatiekatu 7, 94100 Kemi, Finland
Phone: +358 40 553 6248
Email: info@joulupukinjuna.fi

2. Contact person for privacy matters

Minna Miettunen
Rautatiekatu 7, 94100 Kemi, Finland
Phone: +358 40 553 6248
Email: minna.miettunen@laplandspirit.com

3. What personal data we collect

We may process the following categories of personal data:

• name
• email
• phone
• booking and passenger details
• information related to additional services
• payment-related information
• customer communications and feedback
• marketing permissions
• technical usage data and cookie data

FareHarbor’s data processing terms state that, when its service is used, personal data may include items such as full name, phone number, email address, payment details, browsing history and data collected by cookies or similar technologies. In that context, FareHarbor acts as the data processor and the provider acts as the data controller.

4. Purposes of processing

We process personal data for the following purposes:

• receiving and managing bookings
• processing payments
• delivering tickets, confirmations and customer communications
• customer service
• accounting and legal compliance
• service development and reporting
• marketing where the customer has given consent

5. Legal bases for processing

The legal bases for processing may include:

• performance of a contract
• compliance with a legal obligation
• legitimate interest
• consent, where applicable

6. Data sharing and processors

We may disclose or provide access to personal data to service providers who process personal data on our behalf for the purpose of delivering our services. These may include:

• FareHarbor,which we use as our booking platform
• Stripewhich we use for payment processing
• accounting and financial administration providers
• technical service providers such as website hosting and email providers

FareHarbor states in its Data Processing Agreement that it processes personal data on behalf of the provider as a data processor, while the provider remains the data controller. FareHarbor also states that payments collected through its systems are processed by PCI Level 1-certified payment service providers such as Stripe, and that FareHarbor does not store cardholder data.

7. Payment data

Payments are processed through Stripe. We do not store full payment card details in our own systems. Payment processing is also subject to Stripe’s own terms and privacy practices. FareHarbor states that payments processed through its systems are handled by PCI Level 1-certified payment service providers.

8. International transfers

Some of our service providers may be located outside the EU or EEA, or may process data outside the EU or EEA. Where this happens, we will ensure appropriate safeguards in accordance with applicable data protection law.

9. Data retention

We retain personal data only for as long as necessary for the purposes described in this policy or as required by applicable law. For example, accounting records are retained for the period required by accounting legislation.

10. Your rights

You may have the right to:

• You may have the right to:
• request correction of inaccurate data
• request erasure of your data
• request restriction of processing
• object to processing
• withdraw consent where processing is based on consent
• lodge a complaint with a supervisory authority

Requests regarding personal data can be sent to: sales@laplandspirit.com

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