1. Who is responsible for your data
The controller of personal data processed through this website is Taras Demeshko, 19 Novoselytska Street, Kyiv 02000, Ukraine (“we”, “us”). Tingholm Fjord Resort & Casino is a planned hospitality project, and the website at nobelsville-lawyer.com is its information site.
For anything to do with privacy, write to [email protected]. Every message is read and answered by a person.
Where Article 27 of the General Data Protection Regulation (GDPR) requires a controller established outside the European Economic Area (EEA) to appoint a representative in the EEA, the representative’s details will be published on this page.
2. The short version
- No cookies, no analytics, no advertising or social media trackers.
- The site makes no requests to other companies’ servers. Fonts and images are served from our own hosting, and a strict Content Security Policy blocks connections to third parties.
- The interest list form does not send anything by itself. It prepares an email in your own email app, and nothing reaches us until you press send.
- We use your details only to reply to you and, if you agree, to send occasional news about the project.
3. What we collect
Information you send us
When you join the interest list or write to us, we receive your name, your email address, what you are interested in (for example a type of room, the Summit Wing or gatherings), the fact and time of your consent to receive news as shown by your email, and anything else you choose to write in your message.
Technical data
Like almost every website, our hosting provider’s servers keep short technical logs of requests: the IP address, the date and time, the page or file requested, the browser’s user-agent string and the referring page, if any. These logs are used only to keep the site running and secure.
What we do not collect
We do not use cookies, analytics, fingerprinting, advertising pixels or social media plug-ins. We do not buy data about you from others, and we never ask for payment details or identity documents through this website.
4. Messages are not legal enquiries
Tingholm is a hospitality project. It is not a law firm, and messages sent through this website or to our addresses are not requests for legal advice and do not create any lawyer–client relationship. Please do not send us confidential documents or details of legal cases. If you do, we will not act on them, and we will delete them.
5. Why we use your data, and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Replying to your messages | Name, email address, message | Our legitimate interest in answering people who contact us (Art. 6(1)(f) GDPR) |
| Sending news to the interest list | Name, email address, interests, record of consent | Your consent (Art. 6(1)(a) GDPR), and consent to electronic marketing under section 15 of the Norwegian Marketing Control Act (markedsføringsloven) |
| Keeping the website secure and working | Server logs | Our legitimate interest in running a safe website (Art. 6(1)(f) GDPR) |
| Meeting legal obligations and handling claims | Only the data needed for the purpose | Legal obligation (Art. 6(1)(c) GDPR) or legitimate interest (Art. 6(1)(f) GDPR) |
Where we rely on legitimate interests, we have weighed them against your interests and rights. You can object at any time (see your rights).
6. The interest list and your consent
Joining the interest list is voluntary. We will write only when there is real news — plans, dates, and how reservations will work — and not more than a few times a year.
You can withdraw your consent at any time, free of charge, by writing to [email protected] or simply by replying to any of our emails and asking to be removed. We will remove you promptly, and in any case within one month. Withdrawing consent does not affect anything we did with your consent before you withdrew it.
At present there is no automatic unsubscribe link and no confirmation email (“double opt-in”): requests are handled by a person. If we introduce such tools, we will update this policy.
7. How long we keep your data
- Interest list: until you withdraw your consent or ask to be removed, or until the project is abandoned, whichever comes first. We review the list at least once a year and delete entries that are no longer needed.
- Other correspondence: as long as needed to deal with your message, and normally no longer than twelve months after the conversation ends, unless we must keep it longer to meet a legal obligation or to establish or defend a legal claim.
- Server logs: only as long as needed for security and troubleshooting, after which the hosting provider deletes them.
8. Who receives your data
We do not sell or rent personal data, and we do not share it with advertisers. We use a small number of service providers who process data on our behalf under written agreements that require them to protect it (Article 28 GDPR):
- our website hosting provider, which stores the website files and server logs;
- our email provider, which stores and delivers the messages you send us and our replies.
If we start using a mailing service to send news to the interest list, it will be named here before it is used. We may also disclose data where the law requires it, for example to a court or a public authority.
9. Transfers outside the EEA
The controller is established in Ukraine, which is outside the EEA and is not covered by an adequacy decision of the European Commission. When personal data is transferred from the EEA to us, the transfer is protected by the European Commission’s standard contractual clauses (SCCs), together with any additional measures that are needed.
Some of our service providers may also process data outside the EEA. Where they do, we rely on an adequacy decision or on SCCs. You can ask for a copy of the relevant safeguards by writing to [email protected].
10. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you (Article 15);
- have inaccurate data corrected (Article 16);
- have your data erased (Article 17);
- restrict how we use it (Article 18);
- receive the data you gave us in a portable format (Article 20);
- object to processing based on legitimate interests, and object at any time to direct marketing (Article 21);
- not be subject to decisions based solely on automated processing (Article 22). We make no such decisions.
You can also withdraw your consent at any time. To use any of these rights, write to [email protected]. We will answer within one month; for complex requests this can be extended by two further months, and we will tell you if it is. We may ask for information to confirm your identity. Using your rights is free of charge.
11. Complaints
If you are unhappy with how we handle your data, please tell us first so that we can try to put it right. You also have the right to complain to a supervisory authority, in particular:
- in Norway, Datatilsynet (the Norwegian Data Protection Authority);
- in Ukraine, the Ukrainian Parliament Commissioner for Human Rights;
- or the data protection authority of the EEA country where you live, where you work, or where the alleged infringement took place.
12. Children
The website and the interest list are intended for adults. We do not knowingly collect personal data from anyone under 18. If you believe that a child has sent us personal data, write to us and we will delete it.
13. Security
We use reasonable technical and organisational measures to protect personal data. The website loads nothing from third parties and uses a strict Content Security Policy, and access to our mailboxes is limited to the people who need it. No method of transmission is completely secure, and ordinary email can be read in transit, so please do not send sensitive information by email.
14. Links to other websites
A few pages link to other websites, such as Hjelpelinjen. Those websites have their own privacy policies, and we are not responsible for them.
15. Changes to this policy
We will update this policy when our practices change — for example if we start using a mailing service. The effective date at the top of the page shows when it was last changed. If a change is significant, we will also tell people on the interest list by email.