1. Name and address of the person responsible
The responsible person in terms of the basic data protection regulation and other national data protection laws of the member states and other data protection regulations is the:
hotelkit GmbH, Marie-Andeßner-Platz 1, 5020 Salzburg, Austria
Phone: +43 662 238080
If you have any questions on the subject of data protection and would like to make use of your data protection rights, please send an email to: firstname.lastname@example.org
2. General use of the website
2.1 Access data
When you access the website, protocol data is stored in so-called server log files without being assigned to your person. These serve as statistical evaluations for the purpose of operating and optimizing the website. Furthermore, the data is collected for security reasons, e.g. in order to be able to recognize and clear cases of abuse. Herein lies our legitimate interest according to Art. 6 Par. 1 lit. (f) GDPR.
The following information is recorded:
- Visited website
- Date and time of access
- Amount of transmitted data in bytes
- Source / reference from which you reached the page (“Referrer”)
- Browser and operating system used
- Used IP address
The server log files are stored for a maximum of 14 days and then automatically deleted unless we have a concrete suspicion of a criminal offence. Only our server administrators have access to the log files.
2.2 Google Analytics
We use Google Analytics, a web analysis service of Google Inc. (“Google”). Google has submitted to the PrivacyShield Agreement concluded between the European Union and the USA and has been certified. In doing so, Google undertakes to comply with the standards and regulations of European data protection law. You can find more detailed information in the entry linked below:
As an alternative to the browser plug-in or within browsers on mobile devices, you can click on the following link to set an opt-out cookie that will prevent Google Analytics from collecting data within this website in the future (this opt-out cookie only works in this browser and only for this domain. If you delete the cookies in your browser, you have to click this link again): Deactivate Google Analytics
2.3 Google Tag Manager
Please note that American authorities, such as intelligence agencies, could potentially gain access to personal data that is inevitably exchanged with Google due to the Internet Protocol (TCP) when this service is integrated, due to American laws such as the Cloud Act.
2.4 LinkedIn Insight Tag
Our website uses the conversion tool “LinkedIn Insight Tag” from LinkedIn Ireland Unlimited Company. This tool creates a unique cookie in your web browser, which enables the collection of, among other things, the following data: IP address, device and browser properties, and page events (e.g. page views). This data is encrypted, removed within seven days, and the pseudonymized data is deleted within 90 days. LinkedIn does not share personal data with hotelkit, but offers anonymized reports on website audience and ad performance. In addition, LinkedIn offers the possibility of retargeting website visits via the Insight Tag, so that the website owner can use this data to display targeted advertising outside its website without identifying you as a website visitor.
You can find more information about data protection at LinkedIn in the LinkedIn privacy notices. LinkedIn members can control the use of their personal data for advertising purposes in their account settings.
2.5 Facebook Ads Conversion-Tracking (Facebook-Pixel)
Facebook Ads conversion tracking (Facebook pixel) is an analysis service provided by Facebook, Inc. that connects data from the Facebook advertising network with the actions carried out on this website. The Facebook pixel tracks conversions that can be traced back to advertisements on Facebook, Instagram and the Audience Network.
Processed personal data: cookie; Usage data.
2.6 Contact by email or contact form (“30-day free trial”)
If you contact us by email or contact form (“30-day free trial”), we will save your details for the purpose of processing your enquiry and in the event that follow-up questions arise. This is also our legitimate interest according to Art. 6 para. 1 lit. f) GDPR; in particular in the case of enquiries via the contact form, the processing of your data is also justified by the initiation of a contract (Art 6 Paragraph 1 lit. b GDPR).
We use the services of Google Inc. (“Google”) for receiving and sending e-mails, which was commissioned by us within the scope of an order processing pursuant to Article 28 GDPR. The information sent to us by email or contact form is transferred to servers in the USA and processed there. Google has submitted to the PrivacyShield Agreement concluded between the European Union and the USA and has been certified. In doing so, Google undertakes to comply with the standards and regulations of European data protection law. You can find more detailed information in the entry linked below:
The following information is processed when contacting us via email or contact form:
- Your name
- Your email address (sender address)
- Contact time
- Content of correspondence
When you contact us via the contact form (“30-day free trial”), we also save the following information – if you have voluntarily provided it:
- Your position in the company
- Name of your company
- The telephone number you stated
- The website you stated
We only store and use other personal data if you give your consent or if this is legally permissible without special consent.
The recorded personal data will be deleted when they are no longer needed after the purpose of the contact, i.e. when your request has been sufficiently clarified. Excluded from this are cases in which a longer storage is necessary due to legal requirements.
3. Service providers used
3.1 Google Inc.
For various services, including the receipt and sending of emails, for dynamic forms and analysis of website visits (“Google Analytics”), we use services of the company Google Inc. based in California, USA. For this purpose, we have concluded an order processing agreement with the company in accordance with Article 28. In addition, the company guarantees us adequate protection of the data when transferred to third countries. By concluding a contract with the Standard Contractual Clauses (SSC) specified by the EU Commission, we are guaranteed adequate protection of personal data.
Furthermore, Google Inc. has submitted to the PrivacyShield agreement concluded between the European Union and the USA and has certified itself. In this way, Google undertakes to comply with the standards and regulations of European data protection law. You can find more information in the entry linked below:
3.2 Salesforce EMEA
We use the service provider Salesforce to manage contact, address and contract data. We have concluded a contract processing agreement with this provider in accordance with Article 28 DSGVO; furthermore, storage within the EU/EEA is expressly assured by contract. For the fulfillment of the contract, however, the provider uses other companies that are part of its group as subcontractors, including companies based in the USA. However, binding corporate rules (BCR) are imposed and approved for the processing in accordance with Art. 47 DSGVO. Furthermore, an appropriate level of data protection exists for any data transfers through the conclusion of data protection contractual clauses (Standard Contractual Clauses, SCC) specified by the EU Commission.
3.3 Hetzner Online
For the provision of websites, we use services of the provider Hetzner Online GmbH, based in Gunzenhausen, with whom we have concluded an agreement on commissioned processing pursuant to Article 28 DSGVO. A transfer of personal data to third countries outside the EU/EEA does not take place.
Hotjar is an analysis and feedback platform that helps us to better understand the usability of our website and learn more about the user experience of our website visitors. By using Hotjar, we obtain a comprehensive overview on how website visitors use our website. For this purpose, we concluded a Data Processing Agreement with the company in accordance with article 28 (GDPR). The company is based in Malta.
This website uses SalesViewer® technology from SalesViewer® GmbH on the basis of the website operator’s legitimate interests (Section 6 paragraph 1 lit.f GDPR) in order to collect and save data on marketing, market research and optimisation purposes.
The data stored by Salesviewer will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. The data recording and storage can be repealed at any time with immediate effect for the future, by clicking on https://www.salesviewer.com/opt-out in order to prevent SalesViewer® from recording your data. In this case, an opt-out cookie for this website is saved on your device. If you delete the cookies in the browser, you will need to click on this link again.
To analyze visits to our website, we use the services of Hubspot Inc. headquartered in Cambridge, USA. For this purpose, we have entered into a data processing agreement with the company in accordance with Article 28. In addition, Hubspot Inc. assures us of adequate data protection when transferring data to countries outside the European Union. The conclusion of a contract using the Standard Contractual Clauses (SCC) proposed by the EU Commission ensures adequate protection of personal data.
4. Your rights as data subject
Under applicable laws, you have various rights regarding your personal information. If you wish to exercise these rights, please send your request by e-mail to email@example.com or by post, clearly identifying yourself, to the address mentioned in point 1.
Below you will find an overview of your rights.
4.1 Right to confirmation and information
You have the right to obtain confirmation from us at any time as to whether personal data concerning you is being processed. If this is the case, you have the right to request from us free of charge information about the personal data stored about you, together with a copy of this data. In addition, there is a right to the following information:
- the processing purposes;
- the categories of personal data processed;
recipients or categories of recipients to whom the personal data have been or
will be disclosed, in particular in the case of recipients in third countries
or international organisations;
if possible, the planned duration for which the personal data will be kept or, if that is not possible, the criteria for determining that duration
existence of a right of rectification or erasure of personal data relating to
you or of a right to have the processing limited by the controller or to object
to such processing;
the existence of a right of appeal to a supervisory authority
- if the personal data is not collected from you, all available information about the origin of the data;
- the existence of an automated decision-making process, including profiling, in accordance with Article 22 (1) and (4) DPA and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing for you.
If personal data is transferred to a third country or to an international organisation, you have the right to be informed of the appropriate guarantees in accordance with Art. 46 GDPR to be informed in connection with the transfer.
4.2 Right of rectification
You have the right to ask us to correct any incorrect personal data concerning you without delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.
4.3 Right of deletion (“right to be forgotten”)
Art. 17 (1) GDPR entitles you to demand that we delete personal data relating to you without delay, and we are obliged to delete personal data without delay if one of the following reasons applies:
The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
You revoke your consent to the processing according to Art. 6 para. 1 sentence 1 a) GDPR or Art. 9 para. 2 a) GDPR, and there is no other legal basis for the processing.
They shall lay down in accordance with Art. 21 (1) GDPR and there are no legitimate reasons for the processing, or you submit an objection to the processing pursuant to Art. 21 (2) GDPR.
The personal data were processed unlawfully.
The deletion of personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which we are subject.
The personal data has been collected in relation to the information society services offered, in accordance with Art. 8 para. 1 GDPR.
If we have made the personal data public and we have been informed according to Art. 17 paragraph 1 GDPR to delete them, we will take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform data controllers who process personal data that you have requested them to delete all links to these personal data or copies or replications of these personal data.
4.4 Right to restrict processing
You have the right to demand that we restrict processing if one of the following conditions is met:
- the accuracy of the personal data is disputed by you, for a period of time that allows us to verify the accuracy of the personal data
- the processing is unlawful, and you refused to delete the personal data and instead requested the restriction of the use of the personal data
- we no longer need the personal data for the purposes of the processing, but you need the data for the assertion, exercise or defense of legal claims, or you object to the processing in accordance with Art. 21 (1) GDPR as long as it is not yet clear whether the legitimate reasons of our company outweigh yours.
4.5 Right to data transferability
You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format and you have the right to transfer this data to another responsible person without hindrance by us, provided that
- the processing is based on a consent pursuant to Art. 6 para. 1 sentence 1 a) GDPR or Art. 9 para. 2 a) GDPR or on a contract pursuant to Art. 6 para. 1 sentence 1 b) GDPR and
- the processing is carried out using automated procedures.
When exercising your right to data transfer in accordance with paragraph 1, you have the right to obtain that the personal data be transferred directly from us to another responsible party, insofar as this is technically feasible.
4.6 Right of objection
You have the right to object, at any time, for reasons connected with your specific situation, to the processing of personal data concerning you that is carried out pursuant to Art. 6 paragraph 1 sentence 1 e) or f) GDPR; this also applies to profiling based on these provisions. We no longer process personal data unless we can prove compelling reasons for processing worthy of protection that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
Where personal data are processed by us for the purpose of direct marketing, you have the right to object at any time to the processing of personal data relating to you for the purpose of such marketing, including profiling, insofar as it relates to such direct marketing. You have the right to object, for reasons arising from your specific situation, to the processing of personal data concerning you which is carried out for the purposes of scientific or historical research or for statistical purposes in accordance with Art. 89 (1) GDPR, unless the processing is necessary for the performance of a task carried out in the public interest.
4.7 Automated decisions including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effect on you, or which significantly affects you in a similar way. An automated decision-making process based on the personal data collected does not take place.
4.8 Right to revoke a data protection consent
You have the right to withdraw your consent to the processing of personal data at any time.
4.9 Right of appeal to a supervisory authority
You have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you is unlawful.
5. Data security
We make every effort to ensure the security of your data within the framework of the applicable data protection laws and technical possibilities.
Your personal data will be transmitted in an encrypted form. This applies to your orders and also to the customer login. We use the SSL (Secure Socket Layer) coding system, but we would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. A complete protection of data against access by third parties is not possible.
To secure your data, we maintain technical and organizational security measures in accordance with Art. 32 GDPR, which we continually adapt to the state of the art.
Furthermore, we do not guarantee that our offer is available at certain times; disturbances, interruptions or failures cannot be excluded. The servers used by us are regularly and carefully backed up.
6. Transfer of data to third parties, no data transfer to non-EU countries
As a matter of principle, we only use your personal data within our company.
If and to the extent that we involve third parties in the performance of contracts (such as logistics service providers), they will only receive personal data to the extent that the transfer is necessary for the corresponding service.
In the event that we outsource certain parts of the data processing (“contract processing”), we contractually oblige contract processors to use personal data only in accordance with the requirements of the data protection laws and to ensure the protection of the rights of the data subject.
A data transfer to places or persons outside the EU outside the cases mentioned in this declaration in number 2 does not take place and is not planned.
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