Privacy Policy
Effective from 27 May 2025
Introduction
Rotovia hf. respects your privacy and is committed to protecting your Personal Data. This Policy will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how Regulation (EU) 2016/679 (GDPR) and the Data Protection Act no. 90/2018 protects you.
1. Important Information
Purpose of this Policy
This Policy aims to give you information on how Rotovia hf. collects and processes your Personal Data through your use of this website and services, including any data you may provide through this website.
This website is not intended for children under the age of 13, and we do not knowingly collect data relating to children. Should it occur, a parent or a guardian should contact us, and we will remove the data immediately.
It is important that you read this Policy together with any other privacy notice, policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
Data Controller
Rotovia hf. consists of multiple legal entities. This Policy is issued on behalf of Rotovia hf. so when we refer to “Rotovia hf.”, “we”, “us” or “our” in this Policy, we mean the specific company within Rotovia hf. that is responsible for processing your data. The relevant company within Rotovia hf., whose services you are using, acts as the data controller.
Our Compliance Officer is responsible for overseeing questions in relation to this Policy. If you have any questions, including any requests to exercise your legal rights, please contact our Compliance Officer at:
Rotovia hf.
Gunnarsbraut 12
620 Dalvik
Iceland
Changes to the privacy notice and your duty to inform us of changes
We keep this Policy under regular review. This version was last updated on 27 May 2025. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
Third-party links
Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of Personal Data about you which we have grouped together as follows:
- Identity Data includes first name, last name
- Contact data includes email addresses and telephone numbers
- Financial Data includes current and previous business, information about payment cards
- Usage Data includes information about how you use our website and services
- Marketing and communications data include your preferences in receiving marketing from us and our third parties and your communication preferences
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If you fail to provide Personal Data
Where we are required by law or under the terms of a contract to collect Personal Data, and you fail to provide it when requested, we may be unable to fulfill the contract we have with you or are attempting to establish. In such cases, we may need to cancel the relevant product or service, but we will notify you at an appropriate time if this is necessary.
3. How is your Personal Data collected?
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- Request for Contact Request for quotations.
- Subscribe to our service or publications.
- Contribute to customer service surveys.
- Request marketing to be sent to you; or
- Give us some feedback.
Automated technologies or interactions
When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this Personal Data by using cookies, server logs, and other similar technologies. We use Google Analytics, provided by Google, Inc. (‘Googleʼ), which uses cookies (text files placed on your computer) to help the website operators analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Googleʼs behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
4. How we use your Personal Data
We process your personal data for a clear purpose in accordance with the GDPR and the Data Protection Act. We rely on different legal basis to process your Personal Data:
- Legitimate interests: when processing personal data is necessary for our legitimate interest, such as improving our website and services, unless your legitimate interests outweigh our legitimate interests.
- Performance of a contract: when we process data to fulfill the contract we have with you or are attempting to establish.
- Consent: when you have explicitly consented to the processing of your data for a specific purpose, such as subscribing to our newsletter. You may withdraw your consent at any time by sending us a written request, please contact us using the information in Section 1. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
- Legal obligation: when we process personal data that is necessary for compliance with legal or regulatory obligation that we are subject to.
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your Personal Data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy in Appendix 1 to this policy.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please our Compliance Officer.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your Personal Data
We may share your Personal Data with:
- Service providers that perform certain services on our behalf, such as supporting website functionality and marketing assistance. We will only provide these service providers with information that they need to provide such services.
- Third parties to comply with laws applicable to our operations, to respond to requests from government agencies, to establish or exercise our legal rights and to defend against legal claims.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy notice
- Internal Third Parties
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your Personal Data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate technical and organizational security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How Long Will You Use My Personal Data For?
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. Your rights
Subject to certain exemptions you have the right to:
Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Right to object to the processing of personal data. Where the processing of your personal data is based on our legitimate interests you can at any time object to such processing.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request the erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to lodge a complaint. You have the right to contact the Data Protection Authority if you are in any way dissatisfied with the processing of your Personal Data at: postur@personuvernd.is.
No Fee is Usually Required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Sharing tools
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