Privacy policy
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). The terms used are not gender-specific.
Privacy / Cookie Settings
Table of contents
- Responsible
- Contact data protection officer
- Processing overview
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- Data deletion
- Rights of the data subjects
- Cookies use
- Business services
- Providers and services used in the course of business
- Payment method
- Provision of the online offer and web hosting
- Contact and request management
- Communication via messenger
- Application procedure
- Cloud services
- Newsletter and electronic notifications
- Promotional communication via e-mail, mail, fax or telephone
- Web analysis, monitoring and optimization
- Online marketing
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Modification and update of the privacy policy
Responsible
Hotel Diedrich OHG
Nuhnestraße 2
59969 Hallenberg
Germany
Benjamin Diedrich, Leander Diedrich
E-mail address:datenschutz@hotel-diedrich.de
Phone:+49 (0)2984 9330
Imprint:https://www.hotel-diedrich.de/impressum/
Contact data protection officer
Dieter Grohmann | Datenschutz & privacy
Beethovenstr. 23
87435 Kempten
Germany
Phone: +49 (0) 831 / 5209 8680
E-Mail: info@datenschutzprivacy.de
Relevant legal bases
Relevant legal bases according to the GDPR: The following is an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 (1) p. 1 lit. a) DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
- Contract performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) - Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request.
- Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
- Application procedure as a pre-contractual or contractual relationship (Art. 6 (1) p. 1 lit. b) DSGVO) - Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the data controller or the data subject can exercise the rights accruing to him or her under labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. DSGVO.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Note on applicability DSGVO and Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (DSGVO). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR have been replaced by Swiss terms. In particular, instead of the terms "processing" of "personal data" (or "data" for short), and "legitimate interest" used in the GDPR, the terms "processing" of "personal data" and "overriding interest" used in the Swiss GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
Processing overview
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Payment data.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Applicant Data.
- Event Data (Facebook).
Special categories of data
- Health data.
- Religious or ideological beliefs.
Categories of affected persons
- Customers.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Applicants.
- Business and Contractual Partners.
Processing purposes
- Provision of contractual services and customer service.
- Contact requests and communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion measurement.
- Click tracking.
- Target group formation.
- Managing and responding to inquiries.
- Application Procedure.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offer and user-friendliness.
- Information Technology Infrastructure.
Security measures
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
IP address shortening: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not required, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.
TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
International data transfers
Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Data deletion
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.
As part of our privacy notices, we may provide users with additional information regarding the deletion as well as the retention of data that is specific to each processing operation.
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
- Right of revocation for consents: You have the right to revoke any consent you have given at any time.
- Right of access: You have the right to request confirmation as to whether data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
- Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another responsible party.
- Complaint to supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Cookies use
Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.
Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the telemedia service (i.e., our online offering) expressly requested by users. The strictly necessary cookies usually include cookies with functions related to the display and operability of the online offer , load balancing, security, storage of users' preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by the users. The revocable consent will be clearly communicated to the users and will contain the information regarding the respective cookie use.
Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process the cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: In terms of storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile app).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (so-called "opt-out"): Users can revoke the consents they have given at any time and object to processing in accordance with the legal requirements. For this purpose, users can, among other things, restrict the use of cookies in the settings of their browser (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Types of data processed: meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: provision of our online offer and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Real Cookie Banner: Cookie Consent Management; Service provider: devowl.io GmbH, Tannet 12, 94539 Grafling, Germany; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://devowl.io/de/wordpress-real-cookie-banner/; Privacy policy: https: //devowl.io/de/datenschutzerklaerung/.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period shall commence at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the recording was made or the other documents were created.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
- Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., e-mail, telephone numbers); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and process data (e.g., IP addresses, time information, identification numbers, consent status).
- Special categories of personal data: Health data (Art. 9 (1) DGSVO); Religious or philosophical beliefs (Art. 9 (1) DGSVO).
- Affected persons: Customers; prospective customers; business and contractual partners.
- Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communication; office and organizational procedures; management and response to requests.
- Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery, or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable purchase process and includes the information needed for delivery, or provision and billing, as well as contact information in order to be able to consult; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Hotel and accommodation services: We process the data of our guests, visitors and interested parties (uniformly referred to as "guests") in order to provide our accommodation and related services of a tourist or gastronomic nature as well as to bill for the services provided. In the context of our commissioning, it may be necessary for us to process special categories of data within the meaning of Art. 9 (1) DSGVO, in particular information on the health of a person or information relating to their religious beliefs. The processing is carried out to protect the health interests of visitors (e.g. in the case of information on allergies) or otherwise to meet their physical or mental needs at their request and with their consent. If required for the fulfillment of the contract or required by law, or consented to by guests or it is based on our legitimate interests, we disclose or transfer the data of guests, for example, to the service providers involved in the performance of our services or from authorities, billing agencies, as well as in the field of IT, office or similar services; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Providers and services used in the course of business
As part of our business operations, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, "services") in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.
- Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of contract, term, customer category).
- Data subjects: Customers; prospective customers; users (e.g., website visitors, users of online services); business and contractual partners; employees (e.g., employees, applicants, former employees).
- Purposes of processing: provision of contractual services and customer service; office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- DATEV: Software for accounting, communication with tax advisors and authorities and with document storage; Service provider: DATEV eG, Paumgartnerstr. 6 - 14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //www.datev.de/web/de/mydatev/online-anwendungen/; Privacy policy: https: //www.datev.de/web/de/m/ueber-datev/datenschutz/; Order processing contract: Provided by the service provider.
- HotelNet Solutions: Software for requesting, making and managing bookings (online booking system) and the sale of multi-purpose vouchers; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Service provider: HotelNetSolutions GmbH, Genthiner Str. 8, 10785 Berlin, Germany; Website: https://hotelnetsolutions.de/; Privacy policy: https: //hotelnetsolutions.de/datenschutz/.
Payment method
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions for this purpose (collectively, "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy policy of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.
- Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status).
- Affected persons: Customers; prospective customers; business and contractual partners.
- Purposes of processing: provision of contractual services and customer service; office and organizational procedures.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://www.paypal.com/de; privacy policy: https: //www.paypal.com/de/webapps/mpp/ua/privacy-full.
- SOFORT: Payment services (technical connection of online payment methods); Service provider: Sofort GmbH, Theresienhöhe 12, 80339 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.sofort.com/; Privacy policy: https: //www.sofort.com/de/datenschutzhinweise/.
Provision of the online offer and web hosting
We process the users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).); security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
- ALL-INKL: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM - Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //all-inkl.com/; Privacy policy: https: //all-inkl.com/datenschutzinformationen/; Order processing agreement: Provided by the service provider.
Contact and request management
When contacting us (e.g. by mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
- Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partners.
- Purposes of processing: contact inquiries and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offer and user friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
- Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).
- ReGuest: ReGuest is a software application that ensures that all non-binding inquiries and reservations are answered in the best possible way. For this purpose, ReGuest supports the reservation department in the hotel with a number of (semi-)automated messages. These are among others emails about reminder, deposit, waiting list, arrival and departure. For this purpose, data of the request and reservation (title, first name, last name, email, phone, address, date of birth, correspondence) are stored in ReGuest. To keep the number of service emails as low as possible, it is recorded whether a message was read. As soon as a reservation is made, your data is transferred to the hotel software (PMS system) so that the hotel can take all measures for your stay. The processing of your data is based on Art. 6 para. 1 lit. b DSGVO and serves the fulfillment of a contract or the implementation of pre-contractual measures; service provider: ReGuest GmbH (subsidiary of Zeppelin Group GmbH), Kuperionstr. 34, 39012 Merano, Italy; Website: https://www.reguest.io/; Privacy Policy: https: //www.reguest.io/de/information/datenschutzerkl%C3%A4rung/5-0.html.
Communication via messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.
However, we additionally point out to our communication partners that the providers of the messengers cannot view the content, but can learn that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use Messenger in the relationship with our contractual partners as well as in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messenger for the first time without your consent.
Revocation, objection and deletion: You can revoke any consent given and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer inquiries via Messenger. This is the case if, for example, contractual internals require special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels.
- Types of data processed: contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partners.
- Purposes of processing: contact requests and communication; direct marketing (e.g. by e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Instagram: Messaging via the social network Instagram; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https: //instagram.com/about/legal/privacy.
- Facebook Messenger: Facebook Messenger with end-to-end encryption (Facebook Messenger end-to-end encryption requires activation if it should not be activated by default); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https: //www.facebook.com/about/privacy; Order processing agreement: https: //www.facebook.com/legal/terms/dataprocessing; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
- WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.whatsapp.com/; Privacy policy: https: //www.whatsapp.com/legal.
Application procedure
The application process requires applicants to provide us with the data required for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.
Basically, the required information includes personal information such as the name, address, a means of contact and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information about which details are required.
If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the application between the sender and the reception on our server.
For the purposes of applicant search, submission of applications and selection of applicants, we may use applicant management or recruitment software and platforms and services of third-party providers in compliance with the legal requirements.
Applicants are welcome to contact us regarding the method of application submission or to send us the application by mail.
Processing of special categories of data: If special categories of personal data (Art. 9(1) GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, their processing is carried out so that the controller or the data subject can exercise the rights accruing to him or her under labor law and social security and social protection law and fulfill his or her obligations in this regard. in this regard, in the case of the protection of vital interests of applicants or other persons, or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, for health or social care or treatment, or for the management of health or social care systems and services (Art. 9(2)(b), (c) and (h) GDPR).
Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, the deletion will take place at the latest after the expiry of a period of six months so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.
Duration of data retention in the applicant pool in months:6
- Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
- Affected Persons: Applicants.
- Purposes of the processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
- Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Stepstone: Services related to employee acquisition/recruitment (employee search, communication, application process, contract negotiations); Service provider: StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.stepstone.de; Privacy policy: https: //www.stepstone.de/Ueber-StepStone/Rechtliche-Hinweise/datenschutzerklaerung/.
Cloud services
We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).
In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimization.
If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users' devices for the purposes of web analytics or to remember users' settings (e.g., in the case of media control).
- Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Customers; employees (e.g., employees, applicants, former employees); prospective customers; communication partners.
- Purposes of processing: office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Microsoft Cloud Services: cloud storage, cloud infrastructure services and cloud-based application software; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; Parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //microsoft.com/de-de; Privacy policy: https: //privacy.microsoft.com/de-de/privacystatement, Security notices: https: //www.microsoft.com/de-de/trustcenter; Order processing agreement: https: //www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called "block list") for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Contents:Information about us, our services, promotions and offers.
- Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., e-mail, telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status); usage data (e.g., websites visited, interest in content, access times).
- Affected persons: Communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- Option to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.
Further guidance on processing operations, procedures and services:
- Measurement of opening and click-through rates: The newsletters contain a so-called "web beacon", i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the analyses to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open rates and click rates as well as the storage of the measurement results in the users' profiles and their further processing are based on the users' consent. Unfortunately, a separate revocation of the performance measurement is not possible, in which case the entire newsletter subscription must be cancelled, or it must be contradicted. In this case, the stored profile information will be deleted; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Service provider: undefined; Website: undefined; Privacy policy: undefined.
- ADDITIVE+ NEWSLETTER: You have the possibility to subscribe to our newsletter via our website. For this we need your e-mail address and your declaration that you agree to receive the newsletter via ADDITIVE GmbH. In order to provide you with targeted information, we also collect and process voluntarily provided information on areas of interest, name, birthday and region/country of origin with our newsletter system. Once you have registered for the newsletter, we will send you a confirmation e-mail with a link to confirm your registration. You can cancel your subscription to the newsletter at any time via the unsubscribe link in the respective newsletter. To process your subscription and to deliver the newsletter to your e-mail address, we use software from ADDITIVE GmbH. By means of these services and systems, your data is also processed and stored, at least in part, outside the EU or the EEA. The appropriate level of data protection results from the concluded order processing agreement; service provider: ADDITIVE GmbH, Industriezone 1/5 - Eurocenter, 39011 Lana, Italy; Website: https://www.additive.eu/; Privacy Policy: https: //www.additive.eu/rechtliches/datenschutz.html.
Promotional communication via e-mail, mail, fax or telephone
We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.
After revocation or objection, we store the data required to prove the previous authorization to contact or send up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation or objection of the users, we further store the data required to avoid a renewed contact (e.g., depending on the communication channel, the e-mail address, telephone number, name).
- Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
- Affected persons: Communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Web analysis, monitoring and optimization
Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas require optimization.
In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures and services:
- Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Google Analytics, geographic location data is processed at a higher level by collecting the following metadata based on IP search: "city" (and the derived latitude and longitude of the city), "continent", "country", "region", "subcontinent" (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users' IP addresses are not logged and are truncated by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Grounds: Legitimate Interests (Art. 6 (1) p. 1 lit. f) DSGVO); Website: https: //marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https: //policies.google.com/privacy; Order Processing Agreement: https: //business.safety.google/adsprocessorterms/; Standard Contractual Clauses (ensuring level of data protection for processing in third countries): https: //business.safety.google/adsprocessorterms; Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing as well as data processed).
- Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 (1) p. 1 lit. a) DSGVO); website: https://marketingplatform.google.com; privacy policy: https: //policies.google.com/privacy; order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring level of data protection for processing in third countries): https: //business.safety.google/adsprocessorterms.
- Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and in which the recognition of returning users takes place with the help of a so-called "digital fingerprint", which is stored anonymously and changed every 24 hours; With the "digital fingerprint", user movements within our online offering are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected as part of the use of Matomo is only processed by us and is not shared with third parties; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://matomo.org/.
Online marketing
We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, "Content") based on users' potential interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users' profiles with the aforementioned data. We ask that you note that users can make additional agreements with the providers, e.g., by giving their consent as part of the registration process.
In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
- Types of data processed: Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, time data, identification numbers, consent status); Event data (Facebook) ("Event data" is data that can be transmitted by us to Facebook, e.g., via Facebook Pixel (via apps or in other ways), and relates to individuals or their actions; The data includes, e.g., information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; The event data is used for the purpose of forming target groups for content and advertising information. For example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of forming target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavior-based profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); targeting; marketing; profiling with user-related information (creation of user profiles); provision of our online offering and user experience; remarketing; click tracking.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called "opt-out") specified for the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Inter-territory: https://optout.aboutads.info.
Further guidance on processing operations, procedures and services:
- Facebook pixel and targeting (Custom Audiences): With the help of the Facebook pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https: //www.facebook.com/about/privacy; Further information: Event data of users, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building based on the Joint Responsibility Agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and conversion measurement: Online marketing method for the purpose of placing content and ads within the service provider's advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https: //policies.google.com/privacy; Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
- Google Ads Remarketing: Google Remarketing, also known as Retargeting, is a technology that adds users who use an online service to a pseudonymous remarketing list, so that users can be shown ads on other online offers based on their visit to the online service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 (1) p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https: //policies.google.com/privacy; Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
- Enhanced conversions for Google Ads: When customers click on our Google ads and subsequently use the advertised service (so-called "conversion"), the data entered by the user, such as the e-mail address, name, residential address or telephone number, may be transmitted to Google. The hash values are then matched with existing Google accounts of the users in order to better evaluate and improve the interaction of the users with the ads (e.g. clicks or views) and thus their performance; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://support.google.com/google-ads/answer/9888656.
- Microsoft Advertising: Online marketing method for the purpose of placing content and ads within the service provider's advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO); Website: https://about.ads.microsoft.com/; Privacy policy: https: //privacy.microsoft.com/de-de/privacystatement; Opt-out: https: //account.microsoft.com/privacy/ad-settings/; Further information: https: //about.ads.microsoft.com/de-de/policies/legal-privacy-and-security.
- UTM parameter: Analysis of sources and user actions based on an extension of web addresses referring to us with an additional parameter, the "UTM" parameter. For example, a UTM parameter "utm_source=platformX &utm_medium=video" can tell us that a person clicked the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. posting, link, image and video). With the help of this information, we can, for example, check our visibility on the Internet or the effectiveness of our campaigns; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- ADDITIVE+ LANDINGPAGE - Online marketing and landing pages: In addition to our website, we also operate optimized sales landing pages in the area of online hotel marketing. To process your inquiry, booking, order, activation, registration or other submission of a form on such a landing page and to store and retain your data, we use common cloud services and CRM systems as well as software from ADDITIVE GmbH, 39011 Lana (BZ), Italy ("ADDITIVE". The appropriate level of data protection results from the concluded order processing agreements with the respective companies. Our landing pages use functions of the Google Analytics web analytics service provided by Google Inc ("Google"). Google Analytics enables the analysis of the use of the website by its users. The information thus generated about your user behavior is transferred to the provider's server and stored there. Your IP address is recorded, but anonymized immediately (e.g. by deleting the last 8 bits). This means that only a rough localization is possible. You can prevent the transfer of data related to your use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh ADDITIVE has insight into the data collected by means of Google Analytics. This data is not used for purposes other than analyzing the use of our websites and evaluating our marketing and sales activities. Our websites and landing pages also use ADDITIVE functions for cross-channel recording of the use of our websites and marketing and sales measures such as landing pages, newsletters and social media presences. Information about your visits and submitted forms on our websites is also transferred to ADDITIVE in order to evaluate and optimize our marketing and sales measures. The data processing is carried out on the basis of the legal provisions of Art 6 para 1 lit f (legitimate interest) of the DSGVO. Our concern in terms of the DSGVO (legitimate interest) is the improvement of our offer and our web presence by analyzing the use of our website as well as sales and marketing measures. In addition, our landing pages as well as our website use remarketing functions of Google Inc ("Google") as well as Meta Platforms Inc ("Meta"). In doing so, it is transmitted to Meta and Google that you have visited this website. These functions are used to present visitors to the landing pages with interest-based advertisements in the Google advertising network or in the Facebook and Instagram social networks. The data processing in connection with these remarketing functions is based on the legal provisions of Art 6 para 1 lit a (consent) of the DSGVO. You will be informed of the use of cookies for these remarketing functions by means of a banner when visiting our landing pages. By continuing to use them or by clicking on the corresponding button, you consent to their use. You can object to the consent at any time by calling up the page with the cookie information on the respective landing page and rejecting the cookie use in the banner that appears; service provider: ADDITIVE GmbH, Industriezone 1/5 - Eurocenter, 39011 Lana, Italy; website: https://www.additive.eu/; privacy policy: https: //www.additive.eu/rechtliches/datenschutz.html.
- ADDITIVE+ MARKETING AUTOMATION - Direct Marketing: To increase customer loyalty and to sell services and additional services, we use hotel marketing automation software from ADDITIVE GmbH. In this context, data that we collect and process in connection with your inquiry, booking, order, activation, registration or other submission of a form on the website is analyzed and used to provide you with automated offers for services and additional services via ADDITIVE+ MARKETING AUTOMATION. The appropriate level of data protection results from the concluded order processing agreement. You can object to the use of your data for this purpose at any time via the unsubscribe link in the respective message. The data processing is carried out on the basis of the legal provisions of Art 6 para 1 lit f (legitimate interest) of the DSGVO. Our concern in terms of the DSGVO (legitimate interest) is the avoidance of disadvantages compared to our competitors, the improvement of our brand awareness as well as the maximization of our economic success through the best possible sales use of the contacts gained; Service provider: ADDITIVE GmbH, Industriezone 1/5 - Eurocenter, 39011 Lana, Italy; Website: https://www.additive.eu/; Privacy Policy: https: //www.additive.eu/rechtliches/datenschutz.html.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, the enforcement of the users' rights could be made more difficult.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https: //instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the Facebook social network - We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (known as a "Fan Page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things You and Others Do and Provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy: https: //www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Page Insights," to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information," https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct information or deletion requests to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights"(https://www.facebook.com/legal/terms/information_about_page_insights_data); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https: //www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint accountability is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.pinterest.com; Privacy policy: https: //policy.pinterest.com/de/privacy-policy; Further information: Pinterest Data Sharing Annex (ANNEX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
- TikTok: Social network / video platform; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.tiktok.com; Privacy policy: https: //www.tiktok.com/de/privacy-policy.
- Vimeo: Social network and video platform; Service provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https: //policies.google.com/privacy; Opt-out: https: //adssettings.google.com/authenticated.
- Social Media Wall / Social Media Newsroom: A "social media wall" or "social media newsroom" is a compilation of posts from various social networks in which we are mentioned or which contain a hashtag with our name or the name of a campaign. This includes mentions of posts we publish on social networks and posts published by users. The content of the posts is automatically obtained from the respective social networks in accordance with the terms and permissions of the authors, and users may object to the display at any time. The authors are generally responsible for the content of the posts. The providers of the respective social networks are responsible for the processing of data in connection with the display of the posts and their content. We refer to the information on the respective social networks within the scope of this privacy policy. Without prejudice to the data subject rights of users, we recommend that users (also) contact the respective authors or providers of the respective social networks in the event of requests for information and complaints about posts that were not written by us, in order to remove the posts at the source or to assert your data protection rights; Legal basis: Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO).
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); location data (information on the geographical position of a device or a person).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: provision of our online offer and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g., function libraries that we use for the purpose of displaying or making our online offering user-friendly). In doing so, the respective providers collect the IP address of the user and may process this for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offer. - We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of display or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the users and may process this for the purpose of transmitting the software to the users' browser and for security purposes, as well as for the evaluation and optimization of their offer; legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Google Maps: We integrate the maps of the service "Google Maps" of the provider Google. The processed data may include, in particular, IP addresses and location data of the users; service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //mapsplatform.google.com/; Privacy policy: https: //policies.google.com/privacy.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //www.youtube.com; Privacy policy: https: //policies.google.com/privacy; Opt-out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Ad Display Settings: https://adssettings.google.com/authenticated.
Modification and update of the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.