Thule PRIVACY NOTICE – Adventure life by thule (ALT) Camping event
Introduction
It is very important to us that you feel assured that we process personal data about you in a safe and reliable manner, and in accordance with applicable privacy laws. We are committed to being as transparent as possible in relation to our processing of your personal data. We may update this privacy notice for the ALT Camping Event (“Privacy Notice”) when we, e.g., change our processing routines. When we do so, we will take all reasonable measures to inform you of such updates (unless the changes made are non-material or insignificant). If you have any questions regarding our use of your personal data, do not hesitate to contact us by using the contact details provided at the end of this Privacy Notice.
Thule Sweden AB, Reg. No. 556076-3970 (“Thule”, “we”, “our” or “us”) processes personal data about you in order to organize the ALT Camping Event. This Privacy Notice sets out what personal data Thule, in its role as data controller, collects about you and for which purposes the personal data is processed.
Throughout this Privacy Notice, the term “processing” is used to cover all activities involving your personal data, including e.g., collecting, handling, storing, sharing, accessing, using, transferring and disposing of your personal data.
“Applicable Data Protection Laws” means all legislation and regulations, including regulations issued by relevant supervisory authorities, protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data that from time to time applies to this Privacy Notice, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”), including the Data Protection Act 2018 as well as laws and regulations supplementing the GDPR.
“personal data” means any information relating to an identified or identifiable natural person.
WHO IS THE DATA CONTROLLER FOR THE PERSONAL DATA?
Thule Sweden AB, Reg. No. 556076-3970, Box 69, 330 33 Hillerstorp, Sweden is the data controller for the processing of your personal data as described in this Privacy Notice.
FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data from yourself, when you submit data to us in connection with the registration to the event or when you otherwise interact with us.
You can always choose not to provide us with voluntary information. However, some personal data is necessary for us to process in order to provide you with some of our services. Not providing such personal data may prevent us from providing some of our services to you or performing what you expect from us.
WHY DO WE PROCESS YOUR PERSONAL DATA?
Organising the ALT Camping Event
For the purpose of organising the ALT Camping Event and in order to fulfil our contractual obligations, we need to process personal data as described in this section.
Categories of personal data
Legal basis
- Contact details (address, e-mail address, phone number, country)
- Identity data (name, age)
- Information about your car (car model)
- Payment data (information regarding credit card or other payment methods)
- Purchase data (information about ordered products and/or services, including information about your Thule car tent model)
- Purchase history (information about your purchases)
- Your communication (personal data included in your communication, e.g., in e-mails and surveys)
- Food preferences
Fulfilment of contract. We process your personal data to fulfil our obligations under the contract for the ALT Camping Event.
Detailed purpose of processing
We are using your address, name, email address to be able to issue the payment invoice, your phone number and email address to communicate with you, your name to follow the registration process. Your car model information will ensure that we allocate the right amount of space at the camping site. The Thule car Tent model is necessary to be known beforehand as the event is based on owning / renting your Thule car tent. The age range of your child/children may also be processed to secure the base for the right activities.
Retention period
Your personal data is retained for as long as relevant for the marketing activity, but we will not keep it for a longer period than 1 year from when the activity was concluded.
Participation in marketing activities
When you participate in the ALT Camping Event we will also process your personal data for the purpose of marketing activities for our products.
Categories of personal data
Legal basis
- Photo, video (photos of you or other objects) and other personal data included in such photos or videos
- Public information relating to your social media account (if you have used the official hashtags)
- Your communication (personal data included in your communication, e.g., in e-mails, upon your registration and surveys)
Legitimate interest. We process your personal data based on our legitimate interest to market our products and services. Our legitimate interest is enforced by the fact that you have not objected to our use of the photos and videos which may contain your personal data for marketing activities.
Detailed purpose of processing
Thule will take photos and videos during the ALT Camping event which can be used on thule.com or Thule´s social media channels for marketing purposes or in any print, promotional, advertising or publicity material in any format whatsoever. Thule can repost your social media channel posts provided that you have included the official hashtags in your social media posts.
Retention period
Your personal data is retained for as long as relevant for the marketing activity, but we will not keep it for a longer period than 1 year from when the activity was concluded. If you sign up for a Thule Account or Thule Newsletter, the data will be retained and handled in accordance with our Privacy Notice available on www.thule.com where you will find all information on how we process your personal data.
Sending you marketing materials and similar information
When you participate in the ALT Camping Event, we will also process your personal data for the purpose of offering you Thule’s newsletter, and other marketing materials and similar information.
Categories of personal data
Legal basis
- Contact details (address, e-mail address, phone number, country)
- Identity data (name, age)
- If applicable, your communication (personal data included in your communication, e.g., in e-mails, upon your registration and surveys)
- If applicable, purchase history (information about your purchases)
Legitimate interest. We process your personal data based on our legitimate interest in promoting our business, brand and product range. We also do this in the legitimate interest of our subscribers and customers in being able to stay in touch with you, so that we can keep you advised of new products, events and special offers. You can always opt-out with future effect by using the link to unsubscribe from further marketing e-mails provided in each marketing email we send or by contacting us at events@thule.com.
Detailed purpose of processing
When signing up to the ALT Camping Event, Thule will process your personal data in order to sign you up to and sending you newsletters and similar marketing communication and advertisement.
Retention period
Two years initially (provided you do not withdraw your consent). Thereafter, you will be asked every two years whether you wish us to continue processing your personal data for this purpose. If you do not wish continued processing or if you do not answer the request within the time frame stated in the request, your personal data will be deleted.
RECIPIENTS THAT WE SHARE PERSONAL DATA WITH
Recipients that are controllers
Where necessary, we share your personal data with others. The recipient is the data controller for the processing of your personal data unless we have stated otherwise.
Recipients: Confetti
Purpose(s): To administer payment for your purchase of admission to the ALT Camping event.
Legal basis: Contract. The processing is necessary to fulfil our contract with you, i.e. to fulfil the obligations we are obliged to fulfil under the purchase contract.
Service providers
To fulfil the purposes of the processing of your personal data, we transfer personal data to external parties such as service providers that we have engaged. These parties provide services within the areas of, inter alia, IT (such as data storage, support and management services) and finance (e.g., book-keeping systems). These external parties will act as data processors of Thule and may only process your personal data in accordance with our instructions and not for their own purposes. Thule is the data controller for the processing of personal data that these external parties carry out on our behalf.
Appropriate safeguards for transfers of personal data outside the EU/EEA
Our service providers are generally processing your personal data within EU/EEA, However, on some occasions, Thule uses suppliers and third-party providers to process personal data in a manner which includes transfer of personal data to countries outside of the EU/EEA area (so called “third countries”). These transfers are necessary for providing our services.
With these suppliers and partners, Thule has entered data processing agreements including provisions safeguarding such third country transfers with appropriate safety measures.
Transfers of personal data outside of the EU/EEA area will be processed/performed in accordance with applicable data protection laws, including the GDPR. Such transfers either rely upon an adequacy decision from the European Commission or legal safeguards through the European Commission’s Standard Contractual Clauses (SSC’s) for transfer of personal data outside of the EU/EEA area, combined with supplementary technological and organisational protection measures including encryption and anonymization/pseudonymization.
Should you have any questions regarding Thule’s transfers of personal data to countries outside the EU/EEA area, please contact us by using the contact details provided at the end of this Privacy Notice. You are entitled to receive a copy of any documentation demonstrating that appropriate safeguards have been taken to protect your personal data during a transfer to a third country.
To learn more about third country transfers, please read here.
YOUR RIGHTS
Under Applicable Data Protection Laws, you have certain rights in relation to the processing of your personal data. We process your personal data to the extent necessary to fulfil your rights. Please submit requests for exercising your rights by contacting us by using the contact details set out below.
You have, under certain circumstances, the right to exercise the following rights:
Access
You may request confirmation whether personal data about you is processed by us and, if that is the case, access your personal data and additional information regarding the operation, such as the purposes of the processing. You are also entitled to receive a copy of the personal data undergoing processing.
Object to certain processing
You have the right to object to the processing of your personal data based on a legitimate interest for reasons which concern your particular situation. In such a situation, we will stop using your personal data where the processing is based on a legitimate interest, unless we can show that the interest overrides your privacy interest or that the use of your personal data is necessary to manage or defend legal claims. Please note that some processing described in this Privacy Notice is based on your consent and for such processing you do not have the right to object to the processing. However, you may withdraw your consent as described below.
Rectification
You have the right to obtain from us the rectification of inaccurate personal data concerning you.
Erasure
You may have your personal data erased under certain circumstances, such as when your personal data is no longer needed for the purposes for which it was collected.
Restriction of processing
You may ask us to restrict the processing of your personal data to only comprise storage of your personal data under certain circumstances, such as when the processing is unlawful, but you do not want your personal data erased.
Withdrawal of consent
You have the right to at any time withdraw your consent to the processing of personal data to the extent the processing is based on your consent.
Data Portability
You have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and ask for the information to be transferred to another data controller (where possible), if a) the processing is based on your consent or fulfilment of a contract with you, and b) the processing is carried out by automated means..
Click here to read more about the rights that you have in relation to the processing of your personal data.
Complaints to the supervisory authority
In case of any complaints regarding Thule’s privacy practices, you have the right to lodge a complaint with the competent supervisory authority. For more information, please visit the relevant authority’s website. In Sweden, the supervisory authority is the Swedish Authority for Privacy Protection. You can learn more about how to lodge a complaint with the Swedish Authority for Privacy Protection here.
You find the British Data Protection Authority here.
CONTACT US
If you have any questions or concerns regarding the processing of your personal data, please contact us by using the contact details below.
Thule Sweden AB
Box 69
330 33 Hillerstorp
Sweden
Tel. No.: + 46 40 635 90 00
Email: privacy@thule.com
To ask questions or make comments about our Privacy Notice and our privacy practices, contact our group privacy team at: privacy@thule.com
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is subject to change. You will be adequately notified of any changes to this Privacy Notice unless such changes are non-material or insignificant.
This Privacy Notice was last updated: 12 February 2025