Privacy Policy

1 INTRODUCTION

Goto HUB AS (org. no. 925 038 555) (“GOTO”) wants to make natural attractions, trips and experiences available in an easy and responsible way. GOTO is the licensee of a digital market platform (the “GOTO Platform”). The activity providers (the “Activity Provider”) are suppliers of activities, tours and experiences (the "Product") that offer their Product for sale on the GOTO Platform to customers (the "Customer"). In some cases, Customers may purchase Products via a third-party reseller or channel (a “Sales Partner”). People who use the GOTO Platform, whether an Activity Provider, Sales Partner, Customer or otherwise, are referred to in the following as “Users”.

GOTO values your privacy rights and has taken reasonable steps to protect your privacy, including by implementation of physical, technical and organizational measures to prevent loss, alterations, theft and unauthorized access to information stored and otherwise processed.

This Privacy Policy provides you with information about how GOTO collects, processes and discloses your personal data as a data controller and for what purpose, as well as your rights in this context. GOTO will process personal data in accordance with the applicable data protection legislation at all times.

If you have any questions related to GOTO's processing of your personal data or this Privacy Policy, you can contact us by sending an email to: support@gotohub.no

2 ROLES IN THE PROCESSING OF PERSONAL DATA

2.1 Introduction

The data controller is the one who determines the purpose and means for the processing of personal data. A data processor is someone who processes personal data on behalf of the data controller.

GOTO is the data controller for the processing of personal data when GOTO determines the purpose of the processing and which means to use. GOTO is the data controller for the processing of personal data about Users of the GOTO Platform for the purpose of being able to respond to inquiries from Users and enter into agreements with Activity Providers and Sales Partners. GOTO is also the data controller for the processing of personal data about Customers for the purpose of managing the sale and payment of the Product and associated administration, including registration and communication with Customers.

GOTO and the Activity Provider have a separate processing responsibility for the processing of personal data because GOTO determines for itself the purpose of the processing of the Users of the GOTO Platform, and the Activity Provider decides for itself the purpose of the processing of personal data for its Customers.

GOTO will not be a data processor in its processing of personal data because GOTO itself determines the purpose of the personal data and does not collect information on behalf of the Activity Provider or Sales Partner that GOTO does not itself need in order to provide the GOTO Platform to the Activity Provider, the Sales Partner, and the Customer.

2.2 GOTO as data controller

GOTO processes personal data in connection with you as a User registering on the GOTO Platform, sending us an inquiry via the Platform or otherwise contacting us, entering into an agreement with us about advertising or sales, or if you as a Customer make a purchase and payment of a Product on the GOTO Platform.

This means that GOTO is the data controller for the processing of personal data about:

GOTO Platform Users
Customers purchasing Products via the GOTO Platform
Customers purchasing via a Sales Partner
Persons who contact GOTO
Visitors to GOTO's website
Contact persons of customers, suppliers and other partners
Individuals signed up for GOTO's newsletter

3 PERSONAL DATA PROCESSED, PURPOSE AND LEGAL BASIS

GOTO may process your personal data in connection with the following activities:

To provide our service and manage you as a User or Customer, including registering you as a User, and completing your purchase of a Product. Your name, contact information, and payment details are processed for this purpose. This is necessary to fulfil an agreement entered into with you.
To allow you to use the Product you have purchased, where we process your name, contact information, age, and any relevant health or accessibility information. We share this data with the Activity Provider so they can deliver the Product. This processing is based on our legitimate interest in facilitating your participation.
To provide support and assistance related to your booking, we may share relevant booking and contact data with the Sales Partner you purchased from. This sharing is based on our legitimate interest in enabling the Sales Partner to assist you with inquiries or issues.
To implement or maintain security on the Platform and handle any security breaches. Our legitimate interest is to ensure a safe and stable service.
To obtain usage insights through cookies, including visitor statistics and user behavior. These are anonymized and used for service improvement.
To respond to inquiries from you, where we process your name, phone number, email, and content of the inquiry.
To send newsletters, if you have consented. You can manage this via your profile.
To administer relationships with suppliers and partners, including processing names and contact details.
To comply with legal obligations, such as accounting and tax requirements.
To establish, enforce, or defend legal claims from or against GOTO or third parties.
To facilitate a business sale, merger, or acquisition, where anonymized data may be disclosed under a confidentiality agreement.

4 DISCLOSURE TO THIRD PARTIES

GOTO will only disclose personal data to third parties when we have a legal basis for doing so.

Activity Providers: If you have purchased a Product, we share relevant personal data with the Activity Provider responsible for delivering it. This includes your name, contact information, and information necessary for participation. The Activity Provider is an independent data controller, and its own privacy policy will apply.
Sales Partners: If you purchase a Product via a Sales Partner, we may share your name, contact details, and relevant booking information with that Sales Partner. This allows them to support you in connection with your booking and manage related inquiries. The Sales Partner is also an independent data controller and processes your data according to their own privacy policy.
Data Processors: GOTO may use data processors for services such as payment handling, analytics, or IT support. These processors act under a data processing agreement with GOTO to ensure confidentiality and security. Some data may be stored or processed outside the EU/EEA with adequate safeguards in place.
Public Authorities: GOTO may disclose data when legally required, for example to comply with tax regulations. These authorities act as independent data controllers.

5 COOKIES AND THIRD-PARTY SYSTEMS

GOTO uses cookies and similar technologies for platform functionality and performance insights. A full overview of cookies, their purposes, and expiry times is provided in our Cookie Policy.

Examples include:

GoTo HUB – language settings (1 year)
Stripe – payment processing (3 months–1 year)
Google Analytics – web traffic insights (3 months)
Hotjar – user behavior (1 month–1 year)
elfsight.com – review and rating tool (7 months–1 year)

6 MINORS

The minimum age for Users or Customers is 18 years.

7 RETENTION PERIOD

GOTO only retains personal data as long as necessary to fulfil the purpose for which it was collected, or as required by law. Data related to user accounts is deleted upon deletion of the profile, unless retention is needed to meet legal obligations or protect GOTO’s rights.

8 YOUR RIGHTS

You have the right to:

Access your personal data
Correct or update your data
Withdraw consent
Request deletion of your data
Restrict or object to processing
Request data portability

To exercise your rights, contact us via support@gotohub.no. You may also edit your data in your GOTO profile.

If you believe your rights are being violated, you can lodge a complaint with the Norwegian Data Protection Authority. We encourage you to contact us first.

9 CHANGES TO THE PRIVACY POLICY

The current privacy policy is always available on our website. We will notify you of material changes or where your consent is required for new data uses.

Last updated: 2024-01-10

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