With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation.
Responsible: Gabriela Abado
Phone: +43 (0) 699 13441033
(hereinafter referred to as “Provider”, “Responsible”, “We” or “Us”) )
Types of processed data:
– Inventory data (eg, names, addresses)
– Contact data (eg, e-mail, telephone numbers)
– Content data (eg, text input, photographs, videos)
– Usage data (eg, websites visited, interest in content, access times)
– Meta / communication data (eg, device information, IP addresses)
Processing of special categories of data (Article 9 (1) GDPR):
No special categories of data are processed.
Categories of persons affected by the processing:
– Customers, prospects, visitors and users of the online offer, business partners
– Visitors and users of the online offer. In the following, we also refer to the affected persons as “users”.
Purpose of processing:
– Provision of the online offer, its contents and booking functions.
– Provision of contractual services, service and customer care.
– Answering contact requests and communicating with users.
– Marketing, advertising and market research.
– Safety measures.
As of: June 2019
1. Terms used
1.1. “Personal data ” means any information relating to an identified or identifiable natural person (hereinafter the” data subject “); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, which are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
1.2. “Processing “means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
1.3. “Responsible person” means the natural or legal person, public authority, or other entity which, alone or in concert with others, decides on the purposes and means of processing personal data.
2. Substantive legal basis
In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the case, that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as legal basis.
4. Security measures
4.1. We take appropriate technical measures in accordance with Art. 32 DSGVO, 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 likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection commensurate with the risk; Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and segregation. In addition, we have established procedures to ensure the enjoyment of data subject rights, the erasure of data and the response to data threats. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection by technology design and by privacy-friendly default settings considered (Article 25 DSGVO).
4.2. The security measures include in particular the encrypted transmission of data between your browser and our server.
5. Disclosure and transmission of data
5.1. If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant access to the data, this is done only on the basis of a legal permission (eg if a transmission of the data to third parties, as to payment service providers, in accordance with article 6 paragraph 1 letter b DSGVO is necessary for the fulfillment of the contract), you have consented to a legal obligation or based on our legitimate interests (eg in the use of agents, hosting providers, tax, economic and legal advisers, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual, administrative and other duties).
5.2. Insofar as we commission third parties to process data on the basis of a so-called “processing contract”, this is done on the basis of Art. 28 DSGVO.
6. Transfers to third countries If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure, or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special requirements of Art. 44 et seq. DSGVO. This means that the processing takes place eg on the basis of special guarantees, such as the officially recognized statement of a data protection level corresponding to the EU (eg the „Privacy Shield“ in the US) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
7. Rights of the persons concerned
7.1. You have the right to request a confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 DSGVO.
7.2. You have according to Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
7.3. In accordance with Art. 17 DSGVO, you have the right to demand that the relevant data be deleted without delay, or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 DSGVO.
7.4. You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 DSGVO and request their transmission to other responsible persons.
7.5. You have according to Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
8. Right of withdrawal You have the right to revoke given permissions according to. Art. 7 para. 3 DSGVO with effect for the future.
9. Right to object You may at any time object to the future processing of your data in accordance with Art. 21 DSGVO. The objection may in particular be made against processing for direct marketing purposes.
10. Cookies and right to object to direct mail
10.1. “Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. “Persistent” or “persistent” refers to cookies that remain stored even after the browser has been closed. So can eg the login status be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. As a third-party cookie, cookies are referred to by providers other than the person responsible for the online offer (otherwise, if it is only their cookies, this is called first-party cookies).
11. Deletion of data
11.1. The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 DSGVO. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements. In case the data is not deleted because it is required for other and legally permitted purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
11.2. According to legal requirements, the storage takes place in particular for 7 years in accordance with § 132 para 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with land and for 10 years of records related to electronic services, telecommunications, broadcasting and television services provided to non-EU companies in EU Member States for which the Mini-One-Stop-Shop (MOSS) is used.
12. Contact and customer service
12.1. When contacting us (via contact form, e-mail, WhatsApp or SMS), the information provided by the user will be used for processing the contact request acc. Art. 6 para. 1 lit. b) DSGVO.
12.2. User information can be stored in our Customer Relationship Management System (“CRM System”) or similar organization system.
12.3. We delete the requests, if they are no longer required. We check the requirement every two years; Inquiries from customers who have a customer account, we store permanently and refer to the deletion on the details of the customer account. Furthermore, the legal archiving obligations apply.
13. Collection of access data and logfiles
13.1. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO we track data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider ,
13.2. Logfile information is stored for security reasons (eg to investigate abusive or fraudulent activities) for a maximum of seven days and then deleted. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.
14. Online presence in social media
14.1. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO we maintain online presence within social networks and platforms in order to communicate with the active customers, prospects and users and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
15. Google Analytics
15.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).
15.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offering and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.
15.4. We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
15.5. The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of such data by Google by downloading and installing the browser plug-in available under the following link: https: // tools .google.com / dlpage / gaoptout? hl = DE .
15.6. For more information about Google’s data usage, hiring and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Google’s use of your data when you use websites or apps our partners “), https://policies.google.com/technologies/ads (” Use of data for promotional purposes “), https://adssettings.google.com/authenticated (” Manage information that Google uses to show you advertising “).
16. Facebook social plugins
16.1. On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO) we use social plugins (“plugins”) of the social network facebook.com, which operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). The plugins can represent interaction elements or content (eg videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on blue tile, the terms “Like”, “Like” or a “thumbs up” sign ) or are marked with the addition “Facebook Social Plugin”. The list and the look of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ .
16.2. Facebook is certified under the Privacy Shield Agreement, providing a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ).
16.3. When a user invokes a feature of this online offering that includes such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the device of the user and incorporated by him into the online offer. In the process, user profiles of the processed data can be created. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore informs users according to our level of knowledge.
16.4. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example, press the Like button or leave a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymous IP address is stored in Germany.
16.6. If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Other settings and inconsistencies regarding the use of data for promotional purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American site http://www.aboutads.info / choices / or the EU page http://www.youronlinechoices.com/ . The settings are platform-independent, ie they are adopted for all devices, such as desktop computers or mobile devices.
17. Communication via post, e-mail, fax or telephone
17.1 We use means of remote communication, such as mail, telephone or e-mail, Skype, FaceTime and WhatsApp for business transactions and marketing purposes. We process stock data, address and contact data as well as contract data of customers, participants, interested parties and communication partners. 17.2 Processing takes place on the basis of Art. 6 para. 1 lit. a, Art. 7 DSGVO, Art. 6 para. 1 lit. f DSGVO in connection with legal requirements for advertising communications. The contact takes place only with the consent of the contact partners or within the scope of the legal permissions and the processed data are deleted as soon as they are not required and otherwise with opposition / revocation or elimination of the authorization basis or legal archiving obligations.
18. Integration of services and content of third parties
18.1. Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services, integrate services such as videos or fonts (collectively referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate 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 include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer. how traffic is evaluated on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer. how traffic is evaluated on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.
18.2. The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, sometimes already mentioned here, possibilities of contradiction (so-called opt-out)