Privacy Policy

1. Who is responsible for your data

The controller of your personal data is Daryna Klekh, 27 Ushynskoho Street, Kyiv 03151, Ukraine (“we”, “us”). You can reach us about anything in this policy at [email protected].

We have not appointed a data protection officer, because the processing described here is small in scale and does not require one. All privacy questions are handled through the address above.

The controller is established outside the European Economic Area (EEA). Because this website is aimed at people in Norway and other EEA countries, the General Data Protection Regulation (GDPR), as incorporated into Norwegian law, applies to the processing described here. Where the law requires us to appoint a representative in the EEA, we will name that representative in this policy.

2. What this policy covers

This policy covers personal data we receive through this website and through the email addresses published on it. It does not cover other websites that we link to, such as Hjelpelinjen; those sites have their own privacy notices.

Because the resort does not yet operate, there is no guest data, no payment data and no booking data. If the project goes ahead and reservations open, a separate privacy notice will explain how guest data is handled.

3. What we collect

The interest list

The interest list form asks for your name, your email address, what you are interested in (for example a room type, winter stays or gatherings) and your confirmation that you agree to this policy and are 18 or over.

The form does not send anything to a server. When you press the button, it opens your own email app with a prepared message to [email protected]. We only receive your details if you choose to send that email. We then also receive the ordinary information that comes with any email: your address, the date and time, and anything else you decide to write.

Emails you send us

If you write to any of our published addresses (info@, events@, privacy@ or legal@), we receive your email address, the content of your message and any attachments.

Technical logs

Like almost every website, this site is delivered by a hosting server that records basic technical information about each request: IP address, date and time, the page or file requested, the response status, the browser and operating system type (user agent) and, where your browser sends it, the referring page. Our referrer policy limits what other sites receive about you when you follow a link from this site.

What we do not collect

This website uses no analytics, no cookies, no tracking pixels, no advertising tags, no social media plugins and no fonts or scripts loaded from other companies. We do not build profiles and we do not use fingerprinting techniques.

Storage on your own device

On phones, the website can remember which footer sections you opened. This is kept in your browser’s local storage under the name fjellro-footer-accordion, stays on your device and is never sent to us. The Cookie Policy explains it in detail.

4. Why we use it and on what legal basis

• Interest list updates – to send you occasional news about the project. Legal basis: your consent under Article 6(1)(a) GDPR. Because these updates are sent by email, we also rely on your consent as required by section 15 of the Norwegian Marketing Control Act (markedsføringsloven).
• Answering your emails – to reply to questions and requests you send us. Legal basis: steps taken at your request (Article 6(1)(b)) and our legitimate interest in responding to people who contact us (Article 6(1)(f)).
• Technical logs – to keep the website secure, detect misuse and fix faults. Legal basis: our legitimate interest in running a safe and reliable website (Article 6(1)(f)).
• Legal obligations – where we must keep or disclose information by law. Legal basis: Article 6(1)(c).

We do not use your data for automated decision-making or profiling, and we never sell it.

5. What the interest list is for

We will write only when there is real news: a confirmed opening date, the first release of rooms, winter season dates or plans for gatherings. We expect to write rarely. Joining the list is not a booking, creates no obligation and does not guarantee availability. We will never ask you for payment through the list.

6. Withdrawing consent and leaving the list

You can withdraw your consent and leave the list at any time by writing to [email protected] from the address you want removed, or by replying to any update and asking to be removed. There is currently no automatic unsubscribe link, so removal is handled by hand. We will act on your request without undue delay and in any case within one month.

Withdrawing consent does not affect anything we did lawfully before you withdrew it.

7. Who receives your data

We share personal data only with service providers that help us run the website and our email, and only as far as they need it:

• our email and mailbox provider, which stores the messages we send and receive;
• our website hosting provider, which keeps the technical logs described above;
• professional advisers, such as lawyers or accountants, where needed;
• public authorities or courts, where we are required to disclose data by law.

Service providers act on our instructions under data processing agreements. We do not share data with advertisers or data brokers.

8. International transfers

The controller is established in Ukraine, outside the EEA. Ukraine does not have an adequacy decision from the European Commission. When personal data is transferred from the EEA to us or to a provider in a country without an adequacy decision, we use the Standard Contractual Clauses adopted by the European Commission (Decision (EU) 2021/914), together with any additional safeguards that the transfer requires. You can ask for a copy of the relevant safeguards at the address below.

9. How long we keep it

• Interest list – until you leave the list, and in any case no longer than 24 months after the resort opens or after the project is stopped.
• Emails – for as long as needed to deal with your message and for up to 24 months afterwards, unless we need to keep them longer to establish or defend legal claims.
• Technical logs – for a short period set by the hosting provider, normally not longer than 90 days, unless needed to investigate a specific security incident.

10. Your rights

Under Articles 15 to 22 GDPR you have the right to:

• access the personal data we hold about you and receive a copy (Article 15);
• have inaccurate data corrected (Article 16);
• have your data erased (Article 17);
• restrict how we use your data (Article 18), and be told of corrections, erasures or restrictions we pass on to others (Article 19);
• receive data you gave us in a portable format (Article 20);
• object to processing based on our legitimate interests (Article 21);
• not be subject to decisions based solely on automated processing (Article 22) – we make no such decisions.

You can also withdraw consent at any time (Article 7(3)). To use any of these rights, write to [email protected]. We may ask you to confirm your identity. We will answer within one month; in complex cases this can be extended by two further months, and we will tell you if that happens.

11. Complaints

If you think we have handled your data wrongly, please tell us first so we can try to put it right. You also have the right to complain to a supervisory authority:

• Datatilsynet, the Norwegian Data Protection Authority (datatilsynet.no), or the supervisory authority in the EEA country where you live or work;
• the Ukrainian Parliament Commissioner for Human Rights, which supervises personal data protection in Ukraine.

12. Age limit

This website and the interest list are intended for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a person under 18 has sent us their details, please contact us and we will delete them.

13. Security

We use reasonable technical and organisational measures to protect personal data. The website is designed to be served over an encrypted connection and loads no third-party code. Access to our mailboxes is limited to the people who need it and protected by strong authentication. No method of transmission or storage is completely secure, but we will tell you and the supervisory authority about a breach where the law requires it.

14. Changes to this policy

We may update this policy as the project develops, for example if reservations open or we start using a mailing service. The date at the top shows the latest version. If a change materially affects how we use your data, we will tell people on the interest list before it takes effect.

15. Contact

Daryna Klekh, 27 Ushynskoho Street, Kyiv 03151, Ukraine
Email: [email protected]