Privacy Policy

Norwegian Hospitality Group

At Norwegian Hospitality Group, we process your personal data in various contexts — for example, when you book our services, stay at our hotels, use our facilities, or in certain other interactions. In our Privacy Policy, you will find more information about how we handle your personal data. Below, you will also find contact details if you have questions or wish to request access. We process your personal data in accordance with the applicable Norwegian Personal Data Act, including the GDPR.

Data Controller
Our company, Norwegian Hospitality Group (NHG), org. no. 989 467 395, Strandveien 50, 1366 Lysaker, Norway, phone +47 67 10 20 11, is the data controller for personal data processed in our systems for booking, billing, and hotel operations. We are also the data controller for our marketing activities and for emails sent to our customers and contacts.

Processing of Personal Data Related to Booking and Stays
In connection with bookings made by you or on your behalf, we process the personal data necessary to fulfil the agreement for booking and purchasing our services. This includes data you have provided directly or through a travel agency or agent. We may process information such as your identity, contact details, and payment information. In some cases, we also store your passport number.

Additionally, we process other information you provide that is relevant to your stay — such as allergies or special requests. We record all purchases and orders made during your stay (e.g., transport, restaurant, room service) to deliver these services and enable payment. We process this information as long as necessary to fulfil the booking agreement and for as long as required by applicable law or regulatory obligations.

Processing of Personal Data for Marketing Purposes
If you subscribe to our newsletter, we will store and use your email address to send you news and offers from us. We may also use your email address or phone number to send news and offers in accordance with marketing laws governing existing customer relationships.

We may contact you on social media with your consent or within an existing customer relationship. To use social media as a communication channel, we may provide your email address or phone number to the platform. Our legal basis for doing so is consent or legitimate interest.

You may withdraw your consent at any time or opt out of receiving marketing within an existing customer relationship by emailing hello@nhg.no.

Processing for Development, Troubleshooting, and Security
We process data, including personal data, to troubleshoot and fix issues, improve our services and technology, and analyse usage and user behaviour. We also process personal data to verify your identity, including in connection with your use of our digital services.

Where possible, we anonymize or aggregate data for statistical purposes, but some personal data processing may still be necessary for development, troubleshooting, analytics, and security.

Other Processing of Personal Data
If you contact our customer service or reach out to us with inquiries, we will process the personal data you provide as necessary to respond and log your request. The legal basis for this is legitimate interest or to fulfil agreements with you or respond to your inquiries.

Beyond the processing described in this Privacy Policy or based on your consent, we may also process personal data when required or permitted by applicable law, including the GDPR, lawful authority orders, or court rulings.

Disclosure and Statutory Processing
We do not share your personal data with third parties unless you have consented, or unless required or permitted by law, regulatory order, or court decision.

For clarity, our use of data processors acting on our behalf does not constitute third-party disclosure.

Your Rights
Under data protection legislation, you have several rights.
You have the right to request access, correction, or deletion of your personal data. You also have the right to request restriction of processing, object to processing, and request data portability.

To exercise your rights, please visit www.nhg.no.
We will respond as soon as possible, and no later than 30 days.

We may ask you to confirm your identity or provide additional information to ensure we only grant access to your personal data to you — and not to anyone impersonating you.

Cookies
We use cookies to improve the user experience on our website.

A cookie is a small text file stored on your device (such as a smartphone, computer, or tablet). Cookies help recognize what type of content and pages are visited on our site. Information stored via cookies may include how you use the website, your browser type, and which pages you visit.

A persistent cookie remains on your device for a set period, while a session cookie is temporarily stored and deleted when you close your browser. We use both persistent and session cookies.

If you do not want cookies placed on your device, you can disable them in your browser settings. However, this may reduce the functionality of our website.

Personalized Stays
Norwegian Hospitality Group aims to offer our guests the best possible hotel experience, tailored to individual preferences and purchase history. Based on legitimate interest, we may use information provided by you (e.g., room preferences such as “garden view” or “quiet room”) and your purchase history (e.g., “sparkling water” instead of “still water”) to personalize your stay.

This data is collected from your interactions with us and from requests made to our staff. We may also occasionally collect information from public sources such as the internet and social media — limited to data relevant to customizing your stay.

You may opt out of personalization at any time by emailing hello@nhg.no.
This information will not be shared with others.

Changes to the Privacy Policy
We continuously work to develop and improve our services, which may change how or to what extent we process personal data. Accordingly, this Privacy Policy will be updated from time to time.

We will also update the policy whenever new laws or regulatory practices make it necessary.

Whistleblowing Channel

The right to report (whistleblow) concerning censurable conditions in the workplace is regulated by Chapter 2 A of the Norwegian Working Environment Act. All employees and hired workers who have reason to believe that censurable conditions exist within the company are encouraged to report them. This procedure does not limit your legal right to report such matters.

This whistleblowing policy has been developed in collaboration with employees and their representatives to help uncover any censurable conditions within the company.

Who Has the Right to Report
All employees and hired workers may report censurable conditions. In addition, the following persons working in the company also have the right to report:

Students at institutions with educational or research purposes
Conscripts
Civil service or civil defence personnel
Patients in health or rehabilitation institutions, etc.
Persons placed in enterprises for training or employment purposes
Persons participating in labour market schemes without being employees

The right to report applies to “censurable conditions in the employer’s business.” According to Section 2 A-1 (2) of the Working Environment Act, censurable conditions are defined as “circumstances that are in breach of legal rules, written ethical guidelines in the enterprise, or ethical norms widely accepted in society.” Examples include:

Danger to life or health
Risk to the climate or environment
Corruption or other financial crime
Abuse of authority
Unsafe working environment
Breach of personal data protection

Statements concerning only an employee’s own working conditions are normally not considered whistleblowing. Examples include personal conflicts, professional or political opinions, or general dissatisfaction with the workplace. However, a report is covered if it concerns censurable conditions, such as harassment.

In some cases, employees are obliged to report — for example, harassment, discrimination, or situations that may endanger life or health (Working Environment Act § 2-3).
See also the safety representative’s duty to report under § 6-2 (3).

Who to Report To
Reports should generally be made internally — usually to your immediate supervisor. Other possible recipients include:

Your supervisor’s manager
The safety representative
Elected union representatives
A lawyer

Reports concerning the company’s CEO should be sent to the Chairman of the Board:
Thor Morten Halvorsen
Norwegian Hospitality Group AS
Strandveien 50, 1366 Lysaker
thor@nhg.no

Reporting Procedure
A report should preferably be in writing and include an objective, factual, and specific description of the censurable condition.

It should include:

What happened (violation of laws, regulations, ethical norms, or internal guidelines)?
Where did it occur?
When did it occur?
What is the scope?
Are there witnesses or documentation to support the claim?

For Norwegian Hospitality Group AS to handle the report effectively, it should ideally be written and include examples and supporting evidence. It is also helpful to include contact information so we can reach you for further details if necessary.

Anonymous Reporting
Reports may be made anonymously. You may choose not to provide your name or request anonymity during the handling of the case. However, if your identity becomes known, the employer cannot guarantee full anonymity unless exceptions apply under data protection regulations.

We encourage identified reporting, as anonymous cases can be more difficult to investigate and follow up.

Reporting to Public Authorities
An employee may always report externally to a public authority.

Reporting to the Media or the Public
External reporting to the media or the general public is permitted if the employee is in good faith regarding the content, the issue is of public interest, and internal reporting has first been attempted — unless internal reporting is deemed inappropriate.

NHG also has an agreement with an internal lawyer for external reporting. This lawyer is bound by confidentiality regarding the identity of the whistleblower and will agree with the reporter on how the report should be presented to NHG’s management or board.

Reports may be sent to:
Ole Andresen, Attorney-at-law (H), admitted to the Supreme Court
ole.andresen@nhg.no

Protection Against Retaliation
Whistleblowers must not be subjected to retaliation. The same applies to workers or contractors who state their intent to report. Any unfavourable act, practice, or omission resulting from or in reaction to whistleblowing is considered retaliation.

Employer’s Handling of Reports
All reports are taken seriously

The whistleblower will receive confirmation and an outline of the process and estimated timeline

The subject of the report will normally be informed and given the opportunity to respond

The employer will handle the report confidentially, revealing the whistleblower’s identity only when necessary or legally required

Data protection rights of both the reporter and the reported party will be respected

The employer will conduct appropriate investigations to ensure the case is properly clarified before making a decision

Measures may be taken to protect involved parties during the investigation

The case will be documented in writing, and a conclusion reached on whether censurable conditions occurred

Parties will be informed of the outcome as soon as possible

The employer will take corrective action if necessary

On Harassment
Our company has zero tolerance for harassment. Harassment is prohibited by law (Equality and Anti-Discrimination Act § 13 and Working Environment Act § 4-3 (3)). The term covers all forms of harassment, including bullying and sexual harassment.

If we become aware of allegations of harassment — whether through a complaint, a report, a workplace survey, or otherwise — the matter will be investigated and handled responsibly in line with our whistleblowing procedures.

Lysaker, June 1, 2024
Thor Filip Halvorsen
CEO

Operating Companies – Norwegian Hospitality Group AS

Norwegian Hospitality Group AS – 989 467 395

Dalen Hotelldrift AS – 932 934 868 – Dalen Hotel

Hotelldrift Halden AS – 989 466 917 – Thon Hotel Halden

Hotelldrift Park Halden AS – 914 416 329 – Clarion Collection Hotel Park

NHG Respons AS – 996 605 531

Norwegian Travel Group AS – 991 875 794

Riviera Hotelldrift AS – 921 624 182 – Hotel Riviera

Son Spa AS – 991 377 891 – Son Spa

Strömstad Spa AB – 556672-8274 – Strömstad Spa & Resort

Telemarkskanalen Skipsselskap AS – 991 737 561 – M/S Henrik Ibsen