Privacy Policy
We are very pleased about your interest in our company. Data protection has a particularly high priority for the management of Hotel Silbertal Betriebsgesellschaft mbH. In principle, the website pages of Hotel Silbertal Betriebsgesellschaft mbH can be used without providing any personal data. However, if a data subject wishes to use special services of our company via our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data—such as the name, address, e-mail address, or telephone number of a data subject—shall always be carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Hotel Silbertal Betriebsgesellschaft mbH. By means of this privacy policy, our company would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of the rights to which they are entitled by means of this privacy policy.

As the controller, Hotel Silbertal Betriebsgesellschaft mbH has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed through this website. Nevertheless, internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

  1. Definitions
    The privacy policy of Hotel Silbertal Betriebsgesellschaft mbH is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy, we use, inter alia, the following terms:

a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject
Data subject is any identified or identifiable natural person whose personal data are processed by the controller.

c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymization
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for processing
Controller or controller responsible for processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

  1. Name and address of the controller
    Controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions related to data protection is:

Hotel Silbertal Betriebsgesellschaft mbH
Gaislach 7
6450 Sölden
Austria
Tel.: 0043-52542987
E-mail: info@silbertal-soelden.at
Website: www.hotel-soelden-silbertal.com

  1. Cookies
    The website pages of Hotel Silbertal Betriebsgesellschaft mbH use cookies. Cookies are text files that are stored on a computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified by the unique cookie ID.

Through the use of cookies, Hotel Silbertal Betriebsgesellschaft mbH can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies enable us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. For example, the user of a website that uses cookies does not need to enter access data each time they visit the website, because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies by our website by means of a corresponding setting of the internet browser used and may thus permanently deny the setting of cookies. Furthermore, cookies already set may be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

  1. Collection of general data and information
    The website of Hotel Silbertal Betriebsgesellschaft mbH collects a series of general data and information when a data subject or an automated system calls up the website. This general data and information are stored in the server log files. Collected may be: (1) the types and versions of the browser used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-pages which are accessed on our website by an accessing system, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using these general data and information, Hotel Silbertal Betriebsgesellschaft mbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term operability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. These anonymously collected data and information are therefore evaluated by Hotel Silbertal Betriebsgesellschaft mbH both statistically and with the aim of increasing data protection and data security in our company, in order ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

  1. Subscription to our newsletter
    On the website of Hotel Silbertal Betriebsgesellschaft mbH, users are given the opportunity to subscribe to our company’s newsletter. Which personal data are transmitted to the controller when ordering the newsletter is determined by the input mask used for this purpose.

Hotel Silbertal Betriebsgesellschaft mbH informs its customers and business partners at regular intervals by means of a newsletter about company offers. The newsletter can, as a rule, only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter mailing. For legal reasons, a confirmation e-mail will be sent to the e-mail address first entered by a data subject for the newsletter mailing in a double opt-in procedure. This confirmation e-mail serves to verify whether the owner of the e-mail address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the internet service provider (ISP) of the computer system used by the data subject at the time of registration as well as the date and time of registration. The collection of this data is necessary to trace any (possible) misuse of a data subject’s e-mail address at a later date and therefore serves the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will be used exclusively for sending our newsletter. Furthermore, newsletter subscribers may be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as might be the case in the event of changes to the newsletter offering or changes in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data which the data subject has given us for the newsletter mailing may be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to communicate this to the controller in another way.

  1. Newsletter tracking
    The newsletters of Hotel Silbertal Betriebsgesellschaft mbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Hotel Silbertal Betriebsgesellschaft mbH can see whether and when an e-mail was opened by a data subject and which links in the e-mail were called up by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the controller in order to optimize the newsletter mailing and to better adapt the content of future newsletters to the interests of the data subject. These personal data are not passed on to third parties. Data subjects are entitled at any time to revoke the separate consent given via the double opt-in procedure. After a revocation, these personal data will be deleted by the controller. Unsubscribing from receiving the newsletter is automatically interpreted by Hotel Silbertal Betriebsgesellschaft mbH as a revocation.

  1. Contact possibility via the website
    Due to legal provisions, the website of Hotel Silbertal Betriebsgesellschaft mbH contains information that enables a quick electronic contact to our company as well as direct communication with us, which also includes a general address of so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no transfer of these personal data to third parties.

  2. Routine erasure and blocking of personal data
    The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the storage purpose ceases to apply, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

  1. Rights of the data subject
    a) Right to confirmation
    Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to exercise the right to confirmation, he or she may contact any employee of the controller at any time.

b) Right of access
Every data subject has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about his or her personal data stored and a copy of this information. Furthermore, the European legislator has granted access to the following information:

  • the purposes of the processing;

  • the categories of personal data concerned;

  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

  • the existence of the right to lodge a complaint with a supervisory authority;

  • where the personal data are not collected from the data subject, any available information as to their source;

  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.

Furthermore, the data subject has the right to be informed whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, he or she may contact any employee of the controller at any time.

c) Right to rectification
Every data subject has the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may contact any employee of the controller at any time.

d) Right to erasure (right to be forgotten)
Every data subject has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the following grounds applies and insofar as processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

  • The data subject withdraws consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and where there is no other legal ground for the processing.

  • The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.

  • The personal data have been unlawfully processed.

  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by Hotel Silbertal Betriebsgesellschaft mbH, he or she may contact any employee of the controller at any time. The employee of Hotel Silbertal Betriebsgesellschaft mbH shall ensure that the erasure request is complied with without delay.

Where Hotel Silbertal Betriebsgesellschaft mbH has made personal data public and our company as controller is obliged pursuant to Article 17(1) GDPR to erase the personal data, Hotel Silbertal Betriebsgesellschaft mbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data, insofar as processing is not required. The employee of Hotel Silbertal Betriebsgesellschaft mbH will arrange what is necessary in the individual case.

e) Right to restriction of processing
Every data subject has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.

  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.

  • The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Hotel Silbertal Betriebsgesellschaft mbH, he or she may contact any employee of the controller at any time. The employee of Hotel Silbertal Betriebsgesellschaft mbH will arrange for the restriction of processing.

f) Right to data portability
Every data subject has the right granted by the European legislator to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

In exercising his or her right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may contact an employee of Hotel Silbertal Betriebsgesellschaft mbH at any time.

g) Right to object
Every data subject has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

Hotel Silbertal Betriebsgesellschaft mbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims.

Where Hotel Silbertal Betriebsgesellschaft mbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Hotel Silbertal Betriebsgesellschaft mbH to the processing for direct marketing purposes, Hotel Silbertal Betriebsgesellschaft mbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Hotel Silbertal Betriebsgesellschaft mbH for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of Hotel Silbertal Betriebsgesellschaft mbH directly or another employee. The data subject is also free, in the context of the use of information society services and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling
Every data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing—including profiling—which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and a controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Hotel Silbertal Betriebsgesellschaft mbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise rights concerning automated decision-making, he or she may contact an employee of the controller at any time.

i) Right to withdraw data protection consent
Every data subject has the right granted by the European legislator to withdraw consent to processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may contact an employee of the controller at any time.

  1. Data protection for applications and in the application procedure
    The controller collects and processes the personal data of applicants for the purpose of handling the application procedure. Processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents to the controller by electronic means, for example by e-mail or via a web form on the website. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller conflict with such deletion. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).

  2. Data protection provisions about the application and use of Facebook
    The controller has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is an internet-based social meeting place, an online community that usually allows users to communicate with each other and interact in a virtual space. A social network can serve as a platform for exchanging opinions and experiences or allows the internet community to provide personal or company-related information. Facebook enables users of the social network, among other things, to create private profiles, upload photos, and network via friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the USA or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up of one of the individual pages of this website, which is operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Facebook component to download a display of the corresponding Facebook component from Facebook. An overview of all Facebook plug-ins can be retrieved at developers.facebook.com/docs/plugins/. As part of this technical procedure, Facebook gains knowledge of which specific sub-page of our website is visited by the data subject.

If the data subject is logged in at Facebook at the same time, Facebook recognizes with each call-up to our website by the data subject—and for the entire duration of their stay on our website— which specific sub-page of our website the data subject visits. This information is collected by the Facebook component and associated by Facebook with the respective Facebook account of the data subject. If the data subject clicks one of the Facebook buttons integrated on our website, such as the “Like” button, or submits a comment, Facebook assigns this information to the data subject’s personal Facebook user account and stores these personal data.

Facebook always receives, via the Facebook component, information that the data subject has visited our website if the data subject is logged in at Facebook at the time of calling up our website; this occurs regardless of whether the data subject clicks the Facebook component or not. If such transmission of information to Facebook is not desired by the data subject, he or she can prevent this by logging out of their Facebook account before calling up our website.

The data policy published by Facebook, which is available at de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains what setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

  1. Data protection provisions about the application and use of Google Analytics (with anonymization function)
    The controller has integrated the component Google Analytics (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, compilation and evaluation of data regarding the behavior of visitors to websites. Among other things, a web analysis service collects data on which website a data subject came from (so-called referrer), which sub-pages of the website were accessed, or how often and for what dwell time a sub-page was viewed. A web analysis is mainly used for the optimization of a website and for the cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

By using Google Analytics 4, IP anonymization is automatically active. In this case, the IP address of the data subject’s internet connection is shortened and anonymized by Google when access to our websites is made from a Member State of the European Union or from another contracting state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website in order to compile online reports for us that show the activities on our website pages and to provide other services related to the use of our website.

Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this website operated by the controller and on which a Google Analytics component has been integrated, the internet browser on the data subject’s information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for online analysis purposes. As part of this technical procedure, Google gains knowledge of personal data, such as the IP address of the data subject, which serves Google, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

By means of the cookie, personal information—such as the access time, the location from which access originated, and the frequency of visits to our website by the data subject—is stored. Each time our websites are visited, these personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as already stated above, at any time prevent the setting of cookies by our website by means of a corresponding setting of the internet browser used and thus permanently deny the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility of objecting to a collection of data generated by Google Analytics relating to the use of this website as well as to the processing of this data by Google and to prevent such processing. To do this, the data subject must download and install a browser add-on under the link tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google to be an objection. If the data subject’s information technology system is later deleted, formatted or reinstalled, the data subject must perform a new installation of the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person attributable to their sphere of control, there is the possibility of reinstallation or reactivation of the browser add-on.

Further information and Google’s applicable data protection provisions may be retrieved at www.google.de/intl/de/policies/privacy/ and at www.google.com/analytics/terms/de.html. Google Analytics is further explained under the following link: www.google.com/intl/de_de/analytics/.

  1. Data protection provisions about the application and use of Google Remarketing
    The controller has integrated Google Remarketing services on this website. Google Remarketing is a function of Google AdWords that enables a company to display advertising to internet users who have previously stayed on the company’s website. The integration of Google Remarketing therefore enables a company to create user-related advertising and to display ads that are relevant to the interests of internet users.

The operating company of Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Remarketing is the display of interest-based advertising. Google Remarketing enables us to display advertising via the Google advertising network or to have it displayed on other websites which are tailored to the individual needs and interests of internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. With the setting of the cookie, Google is enabled to recognize a visitor to our website when that visitor subsequently calls up websites that are also members of the Google advertising network. With each call-up of a website on which the Google Remarketing service has been integrated, the internet browser of the data subject automatically identifies itself to Google. As part of this technical procedure, Google gains knowledge of personal data, such as the IP address or the user’s browsing behavior, which Google uses, among other things, to display interest-relevant advertising.

By means of the cookie, personal information—such as the websites visited by the data subject—is stored. Each time our websites are visited, personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as already stated above, at any time prevent the setting of cookies by our website by means of a corresponding setting of the internet browser used and thus permanently deny the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility to object to interest-based advertising by Google. To do this, the data subject must call up the link www.google.de/settings/ads from each of the internet browsers used and make the desired settings there.

Further information and Google’s applicable data protection provisions may be retrieved at www.google.de/intl/de/policies/privacy/.

  1. Data protection provisions about the application and use of Google AdWords
    The controller has integrated Google AdWords on this website. Google AdWords is a service for internet advertising that allows advertisers to place ads in Google’s search engine results as well as in the Google advertising network. Google AdWords allows an advertiser to predefine certain keywords by means of which an ad will be displayed in Google’s search engine results only then when the user retrieves a keyword-relevant search result with the search engine. In the Google advertising network, the ads are distributed to topic-relevant websites using an automatic algorithm and in accordance with the previously defined keywords.

The operating company of Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google AdWords is to promote our website by displaying interest-based advertising on third-party websites and in the search engine results of Google and to display third-party advertising on our website.

If a data subject accesses our website via a Google ad, a so-called conversion cookie is placed on the data subject’s information technology system by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. As long as the conversion cookie has not expired, it is used to track whether certain sub-pages, such as the shopping cart of an online shop system, were called up on our website. Both we and Google can thus track whether a data subject who accessed our website via an AdWords ad generated a revenue, i.e., completed or canceled a purchase.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. We, in turn, use these visit statistics to determine the total number of users who were referred to us via AdWords ads, i.e., to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google by which the data subject could be identified.

By means of the conversion cookie, personal information—such as the websites visited by the data subject—is stored. Each time our websites are visited, personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as already stated above, at any time prevent the setting of cookies by our website by means of a corresponding setting of the internet browser used and thus permanently deny the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a conversion cookie on the data subject’s information technology system. In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility to object to interest-based advertising by Google. To do this, the data subject must call up the link www.google.de/settings/ads from each of the internet browsers used and make the desired settings there.

Further information and Google’s applicable data protection provisions may be retrieved at www.google.de/intl/de/policies/privacy/.

  1. Data protection provisions about the application and use of Instagram
    The controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform and enables users to share photos and videos as well as to disseminate such data on other social networks.

The operating company of the Instagram services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up of one of the individual pages of this website, which is operated by the controller and on which an Instagram component (Insta button) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Instagram component to download a display of the corresponding component from Instagram. As part of this technical procedure, Instagram gains knowledge of which specific sub-page of our website is visited by the data subject.

If the data subject is logged in at Instagram at the same time, Instagram recognizes with each call-up to our website by the data subject—and for the entire duration of their stay on our website— which specific sub-page is visited. This information is collected by the Instagram component and associated by Instagram with the respective Instagram account of the data subject. If the data subject presses one of the Instagram buttons integrated on our website, the data and information thus transmitted are assigned to the data subject’s personal Instagram user account and stored and processed by Instagram.

Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is logged in at Instagram at the time of the call-up to our website; this occurs regardless of whether the data subject clicks the Instagram component or not. If such transmission of information to Instagram is not desired by the data subject, he or she can prevent this by logging out of their Instagram account before calling up our website.

Further information and the applicable data protection provisions of Instagram may be retrieved at help.instagram.com/155833707900388 and www.instagram.com/about/legal/privacy/.

  1. Data protection provisions about the application and use of Pinterest
    The controller has integrated components of Pinterest Inc. on this website. Pinterest is a so-called social network. A social network is an internet-based social meeting place, an online community that usually allows users to communicate with each other and interact in a virtual space. A social network can serve as a platform for exchanging opinions and experiences or allows the internet community to provide personal or company-related information. Pinterest enables users of the social network to publish image collections and individual images as well as descriptions on virtual pinboards (so-called pinning), which can then be shared (so-called repinning) or commented on by other users.

The operating company of Pinterest is Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

With each call-up of one of the individual pages of this website, which is operated by the controller and on which a Pinterest component (Pinterest plug-in) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Pinterest component to download a display of the corresponding Pinterest component from Pinterest. More information about Pinterest can be found at pinterest.com. As part of this technical procedure, Pinterest gains knowledge of which specific sub-page of our website is visited by the data subject.

If the data subject is logged in at Pinterest at the same time, Pinterest recognizes with each call-up to our website by the data subject—and for the entire duration of their stay on our website— which specific sub-page of our website is visited. This information is collected by the Pinterest component and associated by Pinterest with the respective Pinterest account of the data subject. If the data subject presses a Pinterest button integrated on our website, Pinterest assigns this information to the data subject’s personal Pinterest user account and stores these personal data.

Pinterest always receives information via the Pinterest component that the data subject has visited our website if the data subject is logged in at Pinterest at the time of the call-up to our website; this occurs regardless of whether the data subject clicks the Pinterest component or not. If such transmission of information to Pinterest is not desired by the data subject, he or she can prevent this by logging out of their Pinterest account before calling up our website.

The privacy policy published by Pinterest, available at policy.pinterest.com/de/privacy-policy, provides information about the collection, processing and use of personal data by Pinterest.

  1. Data protection provisions about the application and use of Twitter
    The controller has integrated components of Twitter on this website. Twitter is a multilingual publicly accessible microblogging service on which users can publish and disseminate so-called tweets, i.e., short messages limited to 280 characters. These short messages are accessible to everyone, including persons not registered with Twitter. Tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter enables the addressing of a broad audience via hashtags, links, or retweets.

Operating company: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

With each call-up of one of the individual pages of this website, which is operated by the controller and on which a Twitter component (Twitter button) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Twitter component to download a display of the corresponding Twitter component from Twitter. Further information about the Twitter buttons can be retrieved at about.twitter.com/de/resources/buttons. As part of this technical procedure, Twitter gains knowledge of which specific sub-page of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to share the contents of this website, to make this website known in the digital world and to increase our visitor numbers.

If the data subject is logged in at Twitter at the same time, Twitter recognizes with each call-up to our website by the data subject—and for the entire duration of their stay on our website— which specific sub-page of our website is visited. This information is collected by the Twitter component and associated by Twitter with the respective Twitter account of the data subject. If the data subject presses one of the Twitter buttons integrated on our website, the data and information thus transmitted are assigned to the data subject’s personal Twitter user account and stored and processed by Twitter.

Twitter always receives information via the Twitter component that the data subject has visited our website if the data subject is logged in at Twitter at the time of the call-up to our website; this occurs regardless of whether the data subject clicks the Twitter component or not. If such transmission of information to Twitter is not desired by the data subject, he or she can prevent this by logging out of their Twitter account before calling up our website.

The applicable data protection provisions of Twitter can be retrieved at twitter.com/privacy.

  1. Data protection provisions about the application and use of YouTube
    The controller has integrated components of YouTube on this website. YouTube is an internet video portal that enables video publishers to upload video clips free of charge and other users to view, rate and comment on them free of charge as well. YouTube permits the publication of all kinds of videos, which is why both complete film and TV programs, but also music videos, trailers or videos created by users themselves can be accessed via the internet portal.

The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

With each call-up of one of the individual pages of this website, which is operated by the controller and on which a YouTube component (YouTube video) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective YouTube component to download a display of the corresponding YouTube component from YouTube. Further information about YouTube can be retrieved at www.youtube.com/yt/about/de/. As part of this technical procedure, YouTube and Google gain knowledge of which specific sub-page of our website is visited by the data subject.

If the data subject is logged in at YouTube at the same time, YouTube recognizes when a sub-page containing a YouTube video is called up which specific sub-page of our website the data subject visits. This information is collected by YouTube and Google and associated with the respective YouTube account of the data subject.

YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is logged in at YouTube at the time of the call-up to our website; this occurs regardless of whether the data subject clicks a YouTube video or not. If such transmission of information to YouTube and Google is not desired by the data subject, he or she can prevent this by logging out of their YouTube account before calling up our website.

The data protection provisions published by YouTube, which are available at www.google.de/intl/de/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

  1. Legal basis for processing
    Article 6(1)(a) GDPR serves as the legal basis for our company for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party—as is the case, for example, with processing operations necessary for the delivery of goods or to provide any other service or consideration—the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our business and as a result his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Article 6(1)(d) GDPR. Ultimately, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal bases, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are particularly permitted because they have been specifically mentioned by the European legislator. In this regard, the legislator considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, sentence 2 GDPR).

  2. Legitimate interests in processing pursued by the controller or by a third party
    Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the well-being of all our employees and shareholders.

  3. Period for which the personal data are stored
    The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of the period, the corresponding data are routinely deleted, provided they are no longer necessary for the fulfillment of the contract or the initiation of a contract.

  4. Statutory or contractual requirements to provide personal data; necessity for the conclusion of a contract; obligation of the data subject to provide personal data; possible consequences of failure to provide
    We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information about the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company concludes a contract with him or her. Failure to provide personal data would result in the contract with the data subject not being concluded. Before personal data are provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or necessary for the conclusion of a contract, whether there is an obligation to provide the personal data, and what the consequences of failure to provide the personal data would be.

  5. Existence of automated decision-making
    As a responsible company, we do not use automatic decision-making or profiling.

This sample privacy policy was created by the privacy policy generator of the German Association for Data Protection (Deutsche Gesellschaft für Datenschutz) in cooperation with the media law attorneys WILDE BEUGER SOLMECKE | Rechtsanwälte.


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