Privacy Statement

1. Introduction

We are Stena Line Scandinavia AB with company registration number 556231-7825 (“Stena Line”) and are responsible as data controller for the processing of your personal data. All references in this privacy statement to “we”, “us” or “our” should be considered a reference to Stena Line. Our contact information is included in the end of this privacy statement. We respect your privacy and are committed to protecting your personal data.

The following site is referred to as our “Website”: https://www.stenalinefreight.com/

Our Website and other communication interfaces (e-mail, telephone, support contact, dedicated Stena Line Internet applications, mobile apps, social media, chat and paper forms) are referred to below as our “Services”.

2. Scope of privacy statement

This privacy statement applies to our processing of your personal data when you as a customer and/or visitor to the Website use our Services including if we obtain your personal data from a booking Freight customer that you or the company that you are employed by has contracted. This privacy statement, inter alia, contains information about the purposes for which we process your personal data, with whom we share it, and what rights you have in relation to your personal data.

For information regarding how we handle Cookies, please see https://www.stenalinefreight.com/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 | Stena Line (stenalinetravel.com).Our privacy statement does not apply to your activities on the websites of social networks. Please read the data protection provisions on the websites of those providers.

3. What categories of your personal data do we process?

3.1 Freight customer contacts:

Stena Line processes the following categories of personal data:

(a) First name and surname;
(b) Business contact details (address, telephone and/or mobile phone number and email address);
(c) Account name;
(d) Your employer, place of work, position or function
(e) Data disclosed in relevant commercial register
(f) Booking reference number;
(g) Itinerary information about booked transport(s): (destination, travel times, arrival and departure date, number of travellers, cabin number;
(h) Vehicle Information (type of vehicle (car, camper, bicycle and/or trailer) and vehicle registration number);
(i) Booking history;
(j) Site information based on your IP address;
(k) Browser information (browser version);
(l) Answers to customer satisfaction surveys to the extent provided by you (name, telephone number and e-mail);

3.2 Freight drivers travelling onboard our Stena Line ships (incl. travelling companions):

Stena Line processes the following categories of personal data:

(a) First name and surname;
(b) Birth date;
(c) Age group (children between the age of 0 – 3 and 4 – 15);
(d) Gender;
(e) Contact details (mobile phone number and email address);
(f) Number of travelling children (if any);
(g) Booking reference number;
(h) Itinerary information about booked transport(s): (destination, travel times, arrival and departure date, number of travellers, choice of cabin or lounge chair, cabin number, any borrowed bed side covers or baby cribs, pet ownership (to the extent you provide us with such data), special requests to the extent provided to us);
(i) Vehicle Information (type of vehicle (car, camper, bicycle and/or trailer) and vehicle registration number) (if any);
(j) Booking history;
(k) Nationality;
(l) Passport or Identification document details;
(m) Your pet’s identification number
(n) Information about who claims to be a parent of a minor;
(o) Date of suspension (if a passenger violates the security and safety regulations onboard, in ports or at terminals.  );
(p) Disability information (to the extent provided to us if you require assistance, have impaired hearing, require medication, require a wheelchair or are visually impaired);
(q) Contact number in case of an emergency (to the extent provided to us)
(r) Site information based on your IP address;
(s) Browser information (browser version);
(t) Answers to customer satisfaction surveys to the extent provided by you (name, telephone number and e-mail);
(u) Your employer and position; and
(v) Photo of vehicle taken at the gate when entering port area (where applicable)

3.3 Freight drivers dropping off or picking up a trailer at a Stena Line terminal (where applicable):

(a) First name and surname
(b) Birth date
(c) Nationality
(d) Mobile phone number
(e) Photo of the driver’s face taken at the gate (in case of picking up)
(f) Vehicle registration number
(g) Photo of vehicle taken at the gate

4. From where do we obtain your personal data?

Stena Line collects your personal data directly from you when you make any kind of reservation or purchase or in any other way use our Services (by visiting our Website, using our Internet application or by contacting us). Stena Line also collects personal data from freight customers that have performed bookings with us (because you are employed, or you are a sub-contractor or work for a sub-contractor).

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

In order for you to book a transport through our Services it is necessary that you provide us with the personal data as specified above in Section 3.1 (a) – (f) as a Freight customer contact. As a Freight driver travelling onboard a Stena Line ship, it is necessary that you provide us with the personal data as specified above in Section 3.2 (a) – (n). If you are a Freight driver dropping off or picking up a trailer at a Stena Line terminal it is necessary that you provide us with the personal data as specified above in Section 3.3 (a) – (g). If not, we will not be able to fulfil our contractual obligations towards you or the freight company and you or the freight company will consequently not be able to book any transports through the use of our Services or drop off or pick up a trailer from our terminal.

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

Stena Line processes your personal data for the purposes described below. For each purpose Stena Line must have a legal basis. A legal basis could e.g. be (i) your consent to the relevant processing activity, (ii) that the processing is necessary in order for the performance of a contract to which you are a party, or (iii) that Stena Line or a third party has a legitimate interest to process the personal data which is not overridden by your interest of not having the personal data processed. Under each purpose listed below, the legal basis that Stena Line relies on will be identified.

(a) Provide transports, accommodation and contractual Services Stena Line uses name, birth date, age group, gender, contact details, payment details, number of travelling children, booking reference number, itinerary information about your transport(s), vehicle information and booking history to administrate and provide your booked transports, any pre-orders and Services in accordance with the Terms and Conditions on https://www.stenalinefreight.com/general-terms. This processing of your personal data is based on our contractual obligations towards you.

(b) Provide our Services (Freight customer contacts)

Stena Line uses the above mentioned personal data under 3.1 (a) – (i) in order to:

• communicate with you as a Freight customer contact when you use our Services.
• conclude a contract with you and implement the agreed provisions
• administrate operations related to the contract (e.g. processing invoices and payments, accounting, archiving related documentation, etc.)
• fulfil compliance with legal regulations, in particular tax, accounting and anti-money laundering and anti-bribery regulations
• defend against claims and / or pursuing claims related to the contract concluded with the contractor – in the event any dispute regarding the contract arises
• maintain good working relations with the contractor

The legal basis for these processing activities are:

• performance of a contract concluded with the contractor or in order to take steps at the request of the contractor prior to entering into a contract
• legitimate interest of Stena Line which consist in the necessity of processing to ensure effective communication with the contractor, to maintain good working relationships with the contractor, to enter into and fulfil the contract with the contractor and to handle related documentation
• legitimate interest of Stena Line which consist in the necessity of processing to defend against claims and / or pursue claims arising from or in relation with the contract
• performance of legal obligations

(c) Provide our Services (Direct customers)

Stena Line uses name and contact details to communicate with you when you use our Services. This processing of your personal data is based on our legitimate interest.

(d) Administration Stena Line uses guest list information in order to administrate refunds, insurance errands and customer complaints related to your booking(s). This processing of your personal data is based on our legitimate interest.

(e) Comply with legal obligations

Stena Line processes:

• the disability information you provide to us in order for us to provide you with any required assistance during your transport in accordance with Regulation (EU) No 1177/2010 of the European Parliament and of the Council of 24th November 2010 concerning the rights of passengers when travelling by sea and inland waterway.
• where applicable, your payment details in order for us to store payment details, name and contact details in accordance with the Accounting Act (Sw. Bokföringslag (1999:1078)) and/or with laws and regulations applicable at relevant local market .
• your name, gender, age group and disability information (to the extent you provide us with such information) in order for us to keep passenger lists in accordance with Directive (EU) 2017/2109 on the registration of persons sailing on board passenger ships operating to or from ports of the Member States of the Community.
• your name, gender, birth date, age group, nationality and passport or identification document details in order for us to keep passenger lists and to conduct identity checks in accordance with the Safety on Ships Ordinance (Sw. Fartygssäkerhetsförordningen (2003:438)) and/or with laws and regulations applicable at relevant local market.
• where applicable, your name, birth date and passport or identification document details to the extent such information is included in lists of prohibited passengers that we receive from police authorities. We use such lists to prevent persons from travelling with Stena Line in order to comply with at each time applicable laws and regulations.
• Where applicable, depending on the route chosen: name, gender, date of birth, nationality, passport or ID details, vehicle registration number, emergency contact 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.

These processing activities of your personal data are based on our legal obligations.

(f) Provide assistance to passengers with disabilities

Stena Line processes the disability information you provide to us in order for us to provide you with any required assistance in relation to booked transports, accommodation and our Services. This processing of your personal data is based on your explicit consent.

(g) Improve our Services

In order to improve our Services (in order to fix bugs, quickly and easily identify and solve Website conversion problems, change the interface so you easily can access the information you search for or to highlight relevant offers on the Website), we will use name, contact details, site information based on your IP address, browser information, booking reference number and itinerary information about your transport(s) to obtain statistics on how you use our Services. We do this by the performance of customer satisfaction surveys and market research or by analysing your use of our Services. When we use your personal data to improve our Services, we use it in an aggregated form to the extent possible. This processing of your personal data is based on our legitimate interest.

(h) Prevent abuse of Services

To the extent necessary, your name, address and IP address (as relevant in each specific case) may be used in order for us to prevent abuse and credit card fraud. This processing of your personal data is based on our legitimate interest.

(i) Prevent suspended persons from booking journeys

Stena Line stores date of suspension, name, birth date (personal identity number for Swedish citizens), identification document ID and booking reference number of passengers who have violated our safety and security regulations onboard, in ports or at terminals in order for us to prevent that such individual from booking reservations and travelling on our ships. This processing of your personal data is based on our legitimate interest.

(j) Direct marketing

We use name, contact details, itinerary information about your transport(s) and booking history to the extent you have provided us with such personal data when using our Services to send newsletters, offers, relevant information about our Services. We send you these by mail, text message, e-mail and other forms of electronic communication. This processing of your personal data is based on our legitimate interest.

You have a right to, at any time, opt-out from receiving direct marketing by contacting us. If you do this, Stena Line will no longer send such direct marketing to you.

(k) Handling of customer complaints and defend and/or establish legal claims

We solely use personal data as relevant in each specific case in order to handle any customer complaints or defend and/or establish legal claims. This processing of your personal data is based on our legitimate interest.

(l) Demonstrate compliance with a legal obligation

Stena Line stores documentation of passport and identification details and information about who claims to be a parent of a minor when performing identification checks in order to demonstrate for relevant authorities that we comply with the identity check requirement in the Safety on Ships Ordinance (Sw. Fartygssäkerhetsförordningen (2003:438)) and/or with laws and regulations applicable at relevant local market. This processing of your personal data is based on our legitimate interest.

(m) Enable drop off or pick up of a trailer from our terminal

We use first name, surname, birth date, nationality and mobile phone number of Freight drivers and vehicle registration number in order to fulfil our contractual obligations towards our Freight customer by facilitating drop off or pick up of a trailer from our terminal. We also take picture of the vehicle and picture of the Freight driver’s face (the latter only in case of pick up) for the purpose of protecting our Freight customers’ property and ensuring that the trailer is picked up by an authorized person only, as well as for the effective investigation of complaints and security incidents, where appropriate. This processing of your personal data is based on our legitimate interest.

7. With whom do we share your personal data?

In order to fulfil the purposes listed above, Stena Line may share your personal data with the following recipients.

(a) Stena AB (publ)
(b) Stena Rederi AB
(c) External payment providers
(d) Stena Line Ltd.
(e) Stena Line BV
(f) Stena Line GmbH & Co. KG
(g) Stena Line Danmark A/S
(h) Stena Line Norge AS
(i) Stena Line Polska Sp.z o.o
(j) UAB Stena Line
(k) SIA Stena Line
(l) Stena Line PTE Ltd.
(m) Stena Line PTE International Ltd.
(n) Baltic RoRo Services GmbH
(o) Stena Line Stevedoring BV
(p) Retail & Food Services in Sweden AB
(q) CustomsLink Ltd. (in order to support with customs declaration for Freight Portal users)
(r) Other ferry companies, bus carriers, entities providing accommodation services and other contractors (where this is necessary to fulfil your booked transport)
(s) The Police, Customs or other competent state authorities
(t) Our external Check in Teams in the ports
(u) Analytics and marketing platforms like Google Analytics, and LinkedIn.
(v) Service suppliers who we engage in order to provide you services such as web-hosting companies, mailing vendors, analytics providers, information technology providers, event hosting services, etc.

8. Will we transfer your personal data outside of the EU/EEA and UK?

Stena Line generally tries to avoid transfers of data outside the EU/EEA and the UK.

All data transfers between the EU/EEA and the UK are subject to the respective adequacy decisions of the UK Government and the EU commission allowing a free flow of data.

Due to the current legal situation, there is currently no adequate data protection level in the United States of America (USA) that would be comparable to the data protection level within the EU/EEA and the UK. The background is that US security authorities are allowed to read and evaluate all data reaching the USA without there being any possibility of legal protection in favour of non-US citizens. In the case of data transmissions to the USA, it can therefore neither be ensured nor guaranteed that transmitted personal data will not be accessed by security authorities in the USA.

Stena Line selects its service providers and Processors very carefully and pays particular attention to the processing of data within the EU/UK, even for companies based in the USA. In some cases, the selected Processors themselves use Sub-Processors in the USA. In such cases the Processors have implemented safeguards by using the New European Commission’s Standard Contractual Clauses for the Transfer of Personal Data (as per EU commission’s decision 4^th June 2021) with their sub-processors.

If you would like more information on the above described safeguard(s), please  contact our Data Protection Officer. Please see section 11 in this privacy statement for contact details.

9. For how long will we store your personal data?

10. What rights do you have?

Below is a summary of the rights you have under European data protection legislation. The exercise of these rights is free of charge and you may exercise the rights by sending an email or mail to the contacts listed at the end of this document

Note that Stena Line will always assess a request to exercise a right to determine whether the request is valid. All rights listed below are not absolute and exceptions may apply. In addition to the rights set forth below, you always have the right to lodge a complaint with a supervisory authority regarding Stena Line’s processing of your personal data. You can find a list of all European supervisory authorities here: Our Members | European Data Protection Board (europa.eu). The contact details of the UK supervisory authority can be found here: Information Commissioner’s Office (ICO).

(a) Right of access. You are upon request entitled to receive a copy of your personal data that Stena Line processes and also to obtain supplementary information about Stena Line’s processing of your personal data.

(b) Right to rectification. You are upon request entitled to receive a copy of your personal data that Stena Line processes and also to obtain supplementary information about Stena Line’s processing of your personal data.

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

• the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw your consent to a processing activity and there is no other legal basis for the processing;
• you make a valid objection to the processing of your personal data;
• the personal data has been unlawfully processed; or
• the personal data has to be erased for compliance with a legal obligation.

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

• the accuracy of the personal data is under examination;
• the processing is unlawful or is no longer needed for the purposes of the processing, but you oppose the erasure of personal data and request restriction instead;
• Stena Line no longer needs the personal data, but you need the personal data for the establishment, exercise or defence of legal claims; or
• you have objected to the processing of your personal data and such objection is under verification.

(e) Right to data portability. Under certain circumstances you have the right to receive the personal data concerning you which you have provided to Stena Line in order to transmit these 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 the general right to, at any time, object to the processing of your personal data that is based on Stena Line’s legitimate interests. If you object, we have to demonstrate that we have compelling legitimate grounds for such processing or that we need the personal data for the establishment, exercise or defence of legal claims.

(g) Right to object to direct marketing. You have a right to, at any time, object to the processing of your personal data for direct marketing purposes. If you do this, Stena Line may no longer process your personal data for such purposes.

11. How can you contact us?

You may come in contact with us through the following communication channels:

Headquarters:
Address: Stena Line Scandinavia AB, 405 19 Gothenburg, Sweden
Telephone: (+46) 770 – 57 57 00

Contact details to our local area teams can be found here: https://www.stenalinefreight.com/contact

Please note that we have appointed a so-called Data Protection Officer that you may contact if you have any questions about the processing of your personal data. Our Data Protection Officer may be contacted at dpo@stenaline.com.

Last update: February 2023