Privacy Statement and Cookie Policy
Version 1.0
Hintertuxerhof GesmbH & Co KG having registered office in Hintertux 780, A-6294 Hintertux (hereafter Hotel Hintertuxerhof) is committed to protecting the online privacy of users. Pursuant to art. 13 of EU Regulation 2016/679 (hereafter: „Regulation“), this statement was written to inform you on our privacy policy and how your personal data is handled when you visit our website (hereafter “Website”), as well as to enable you to give your specific and informed consent to the processing of your Personal Data, where applicable. Please be informed that parental consent is required for children under 16 years of age. The information and data provided by you, or otherwise acquired through use of our online services (hereafter „Services“) on your part, will be processed in compliance with the Regulation and the Data Controller’s obligation to confidentiality.
Pursuant to the Regulation, Hotel Hintertuxerhof shall process Personal Data based on the principles of lawfulness, fairness, transparency, limitation of purpose and retention, data minimisation, accuracy, integrity and confidentiality.
TABLE OF CONTENTS
1. Data Controller
2. Personal Data subject to processing
a. Browsing data
b. Special categories of Personal Data
c. Data volunteered by Data Subjects
3. Purposes of data processing
4. Lawful basis and mandatory or optional nature of data processing
5. Disclosure of Personal Data
6. Transfer of Personal Data
7. Retention of Personal Data
8. Your rights
9. Details Website
10. Changes
11. Contact
1. Data Controller
In relation to the data processing carried out through our website, the Data Controller as defined above is Max Kofler GesmbH & Co KG. For any information regarding the processing of Personal Data by the Data Controller, including the list of Data Processors, please write to the following address: info@hintertuxerhof.at
2. Personal Data subject to processing
Please be informed that as a result of website browsing, the Data Controller will collect and process Personal Data that may consist of information like name and surname, identification number, online identifier, mail address, e-mail address, landline and/or mobile telephone number or information on one or more physical, physiological, psychological, financial, cultural or social features relating to an identified or identifiable person (hereafter “Personal Data”).
The following Personal Data is processed through our Website:
a. Browsing data
During normal operation, the computer systems and software used to operate our Website acquire some Personal Data the transmission of which is implicit in the Internet communication protocols. The collection of this information is intended to be associated with identified parties; however, the data collected might by its nature allow users to be identified through processing and association with data held by third parties. This category of data includes IP addresses or domain names of computers used by users who connect to the Website, URI (Uniform Resource Identifier) of requested resources, the time of request and method used to submit it to the server, the size of the file obtained in reply, the numerical code indicating the server response status (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to ensure its correct functioning by identifying any anomalies and/or abuses, and are therefore deleted immediately after processing. The data could be used to ascertain responsibility in the event of possible computer crimes against the Website or third parties; except for this possibility, the data collected from the Website is removed within a short period of time.
b. Special categories of Personal Data
If you send us your application via e-mail or through our website, you might provide us with Personal Data that falls within special categories as set forth in art. 9 of the Regulation, namely: “[…] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and […] genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. Please do not disclose this type of data unless it is strictly necessary. Please be informed that if you do choose to provide this type of data without giving your specific consent to the processing (e.g. by sending a CV), the processing on our part will relate to data made manifestly public by the Data Subject, as provided for by art. 9(1)(e) of the Regulation. Therefore, the Data Controller will be released from any liability or dispute whatsoever in connection with the processing of such data. As previously mentioned, explicit consent to the processing of special categories of Personal Data is fundamental if you do choose to disclose such information.
Please be also informed that the Data Controller may view any social media profiles made openly available on professional networking sites or platforms (e.g. LinkedIn).
c. Data volunteered by Data Subjects
We may process Personal Data of third parties that you send to the Data Controller when using certain services on our Website (e.g. the request/contact/booking forms). In these cases, you act as independent Data Controller, thereby assuming all the obligations and liabilities set by law. In this sense, you release the Data Controller from any and all responsibilities and obligations with respect to any dispute, claim, compensation for damages etc. that may be received from third parties whose Personal Data has been processed through the Website functions in violation of applicable data protection laws. In any case, if you provide or process Personal Data of third parties while using our Website, you warrant – assuming full liability – that processing has a lawful basis in compliance with art. 6 of the Regulation.
3. Purposes of data processing
If necessary and with your specific consent, we will process your Personal Data for the following purposes:
a. Provide the services you require;
b. Respond to requests for assistance, information or bookings;
c. View CVs and contact applicants;
d. Comply with legal and tax obligations;
e. Marketing purposes: the data provided may be used, subject to explicit and specific consent, for the sending of promotional and marketing communications, including newsletters and market surveys, using automated tools (SMS, MMS, e-mails, push notifications) and non-automated tools (paper mail, telephone calls by operators). The lawful basis for the processing of your data for these purposes is art. 6, paragraph 1, letter a) of the Regulation. The processing of data for direct marketing is optional and based exclusively on your free choice, and denying your consent for this purpose will not affect the use of services on your part.
4. Lawful basis and mandatory or optional nature of data processing
The lawful basis for the processing of Personal Data for the purposes referred to in section 3 (a-b-c) is art. 6(1)(b) of the Regulation (performance of a contract) as the data is necessary to provide the services required and/or to respond to requests from the interested party. Giving your Personal Data for these purposes is optional, but indispensable to activate the services provided by the Website, to answer requests or evaluate CVs. With specific reference to the purpose 3.c and the viewing of profiles on professional networking platforms made freely available on the Internet, as mentioned in section 2.b, the lawful basis is art. 6(1)(f) of the Regulation, i.e. the legitimate interest of the holder in verifying the candidate’s suitability for the open position and any potential risks.
For the purposes illustrated in section 3.d, the lawful basis is art. 6(1)(c) of the Regulation (compliance with legal obligations). Once provided, Personal Data must be processed for the Data Controller to comply with legal obligations.
Art. 6(1)(a) of the Regulation (your consent) is the lawful basis for the processing of data for the purposes referred to in section 3.e. In this respect, activities that involve the direct sending of advertising material, direct sales or market surveys and commercial communications in relation to products or services similar to those you purchased, the Data Controller may use your e-mail and mail addresses without your consent, in accordance with and within the limits allowed by art. 130, paragraph 4 of the Italian Data Protection Code and the by the Decision of the Italian Data Protection Authority of 19 June 2008. The lawful basis for the processing of your data for this purpose is Art. 6(1)(f) of the Regulation (legitimate interest).
5. Disclosure of Personal Data
For the purposes listed in section 3, your Personal Data may be shared with:
a. Parties who typically act as Data Processors, namely: i) persons and/or organisations providing us assistance and counselling services on marketing and communication; ii) persons and/or organisations who assist us in providing certain services (e.g. hosting providers) iii) persons and/or organisations who perform technical maintenance activities (including maintenance of network equipment and electronic communication networks); (collectively, “Recipients”);
b. Persons, entities or authorities to whom Personal Data must be disclosed by virtue of legal provisions or orders given by a competent authority;
c. Parties authorised by the Data Controller to perform activities that are strictly related to the provision of services or for the purposes listed in section 3, who have committed themselves to confidentiality or have legal obligation to confidentiality (e.g. employees).
6. Transfer of Personal Data
Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area. The Data Controller ensures that these Recipients process your Personal Data in compliance with the Regulation. Transfer of Personal Data may be based on an adequacy decision, on Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis. For further information please contact the Data Controller by sending an e-mail to: info@hintertuxerhof.at
7. Retention of Personal Data
Personal Data processed for the purposes referred to in section 3(a-b) will be kept only for as long as strictly necessary to achieve those purposes. In any case, since data is used in order to provide services, the Data Controller will process the Personal Data up to the time allowed by Italian law (art. 2946 of the Italian Civil Code and subsequent amendments). With regard to any CVs submitted through the Website or by e-mail (see section 3.c), the Personal Data will be kept for as long as necessary for the purpose. The Data Controller may contact the candidate again shortly before the indicated deadline to ask for an extension of the retention period.
Personal Data processed for the purposes referred to in section 3(d) will be stored for as long as provided for by applicable laws and regulations.
Personal Data processed for the purposes referred to in section 3(e) will be kept until we have consent; if you do not withdraw your consent, your data will be stored for a time deemed appropriate.
For more information on our data retention policy and criteria, please contact: info@hintertuxerhof.at
8. Your rights
Pursuant to Art. 15 and following of the Regulation, you have the right to obtain access to your Personal Data at any time. You have the right to request from the Data Controller rectification or erasure of your data, as well as to object to and restrict processing of your data in the cases provided for by Art. 18 of the Regulation. You have the right to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format in compliance with Art. 20 of the Regulation.mm m
Requests must be submitted in written form and sent at: info@hintertuxerhof.at
In any case, you also have the right to lodge a complaint with the competent Supervisory Authority (Italian Data Protection Authority) if you consider that the processing of your Personal Data infringes the applicable law, pursuant to Art. 77 of the Regulation.
9. Details Website
Cookies
Our website uses so-called cookies. These are small text files that are stored on your device using the browser. They do no harm. We use cookies to make our offer user-friendly. Some cookies remain stored on your device until you delete them. They allow us to recognize your browser on your next visit. If you do not want this, you can set up your browser so that it informs you about the setting of cookies and you allow this only in individual cases. Disabling cookies may limit the functionality of our website.
Web Analytics – Using Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. („Google“). Google Analytics uses so-called „cookies“, text files that are stored on your computer and that allow an analysis of the use of the website by you. These are cookies from Google itself (Google Analytics cookies) and so-called third-party cookies (DoubleClick cookies). The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, your IP address will be shortened by Google beforehand within member states of the European Union or other parties to 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. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and other services related to website activity and internet usage, including but not limited to display advertising features such as Google Analytics reports to provide demographic and interest services to the website operator. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. The Google Analytics demographics and interest reports use third-party data and third-party visitor data (such as age, gender, and interests) obtained through Google’s interest-based advertising. Google will never associate your IP address with other Google data. You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading the browser plug-in available under the following link and install [http://tools.google.com/dlpage/gaoptout?hl=en].
Use of Facebook plugins
This website uses plugins from the social network facebook.com operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA („Facebook“). If you visit our internet presence with such a plugin, a connection will be made to the Facebook servers and the plugin will be displayed on the website by a message to your browser. This will be transmitted to the Facebook server, which of our websites you have visited. If you are logged in as a member of Facebook, Facebook assigns this information to your personal Facebook user account. When using the plug-in functions (eg clicking on the „Like“ button, submitting a comment), this information will also be assigned to your Facebook account, which you can only prevent by logging out before using the plug-in the data through Facebook, about your rights in this regard and ways to protect your privacy can be found in the privacy policy of Facebook.
Use of Facebook Remarketing
The provider uses the „Custom Audiences“ remarketing feature of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA („Facebook“) on the website. By means of this function, the provider can address the visitors of the website purposefully with advertising, by providing visitors of the website with personalized, interest-based Facebook ads when they visit the social network Facebook. To perform the function, the remarketing tag from Facebook is implemented on the provider’s website. This tag is used to make a direct connection to the Facebook servers when visiting the website. This will be transmitted to the Facebook server, which of our websites you have visited. Facebook assigns this information to your personal Facebook user account. For more information on the collection and use of data by Facebook, about your rights in this regard and ways to protect your privacy, please refer to the privacy policy of Facebook at https://www.facebook.com/about/privacy/. If you do not want Facebook to associate the collected information directly with your Facebook user account, you can disable the „Custom Audiences“ remarketing feature here. To do this, you must be logged in to Facebook.
Use the Google „+1“ button
These websites use the „+1“ button of Google Inc.’s Google Plus, 1600 Amphitheater Parkway, Mountain View, California, 94043 USA („Google“) social network. If you call up an Internet page with the „+1“ button, you will be connected to the Google servers in the USA and the button will be displayed on the website by a message to your browser. In this case, both your IP address and the information about which of our website you have visited are transmitted to the Google server. This applies regardless of whether you are registered or logged in to Google Plus. Even with non-registered or not logged in users will be transmitted. The „+1“ button is not used to track your visits to the Internet. Google does not permanently log your browsing history when displaying a „+1“ button and does not otherwise evaluate your visit to a page with a „+1“ button. Google stores about two weeks of data about your visit for system maintenance and troubleshooting purposes. However, this data is not structured according to individual profiles, usernames or URLs and will not be forwarded to us. In addition, if you are a member of Google Plus and logged in to Google Plus at the time you use the plug-in, the information you collect about your visit to the Site will be linked to your Google Plus account and shared with other users. Also in the case of interactions that are possible with the various Google plugins, the information about you will be collected and transmitted to Google and stored. An overview of the different types of Google Plugins can be viewed here:
https://developers.google.com/+/plugins If you have made your profile public in Google Plus’s settings, Google’s „+1“ may be used as a reference along with your profile name and photo in Google services, such as in search results or in your Google profile, or elsewhere on websites and ads on the Internet. If you do not want Google to map the collected information directly to your Google Plus profile, you’ll need to log out of Google Plus before visiting our page. For more information about how Google collects and uses your data, your rights and how to protect your privacy, see the Google Privacy Policy: http://www.google.com/intl/en/policies/privacy/
You also have the option to prevent the loading of the Google plugins by installing the corresponding add – ons in your browser.
Using the Remarketing or „Like Audiences“ feature of Google Inc.
The provider uses the remarketing or „Like Audiences“ feature of Google Inc. („Google“) on the website. This feature enables the advertiser to target advertisers to the website by displaying personalized, interest-based advertising ads to visitors to the provider’s website when they visit other websites on the Google Display Network. In order to carry out the analysis of the website usage, which forms the basis for the creation of interest-related advertisements, Google uses so-called cookies. For this Google stores a small file with a sequence of numbers in the browsers of the visitors of the website. This number records website visits and anonymous data on website use. There is no storage of personal data of visitors to the website. If you visit another website on the Google Display Network, you’ll see ads that are likely to include previously viewed product and information areas. You may permanently disable the use of cookies by Google by following the link below and downloading and installing the plug-in provided there: https://www.google.com/settings/ads/plugin. Alternatively, you may disable the use of third-party cookies by visiting the Network Advertising Initiative deactivation page at http://www.networkadvertising.org/choices/ and implementing the opt-out information listed there. For more information about Google Remarketing and Google’s privacy policy, please visit: http://www.google.com/privacy/ads/.
Using Google Adwords Conversion Tracking
We use the Google AdWords online advertising program and conversion tracking as part of Google AdWords. Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; „Google“). When you click on an ad served by Google, a conversion tracking cookie will be placed on your machine. These cookies lose their validity after 30 days, contain no personal data and are thus not used for personal identification. If you visit certain web pages on our website and the cookie has not expired, Google and we may recognize that you clicked on the ad and were redirected to this page. Each Google AdWords customer receives a different cookie. Thus, there is no way that cookies can be tracked through the websites of advertisers. The information gathered using the conversion cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. It tells customers the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users. If you do not want to participate in the tracking, you can object to this use by preventing the installation of cookies by a corresponding setting of your browser software (deactivation option). You will not be included in the conversion tracking statistics. For more information and Google’s privacy policy, please visit: http://www.google.com/policies/technologies/ads/, http://www.google.com/policies/privacy/
Instagram
Functions of the service Instagram are integrated on our sides. These features are provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, United States. If you are logged in to your Instagram account, you can link the contents of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate the visit to our pages with your user account. We point out that we as the provider of the pages do not receive knowledge of the content of the transmitted data and their use by Instagram.
For more information, see the Instagram Privacy Policy: http://instagram.com/about/legal/privacy/.
Google Maps
This website uses the Google Maps product of Google Inc. By using this site, you consent to the collection, processing and use of the automated data collected by Google Inc, its agents and third parties.
You can find the Terms of Use for Google Maps at https://www.google.com/intl/en_en/help/terms_maps.html
YouTube
Our website uses plugins from the Google-powered YouTube page. Site operator is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit one of our YouTube plug-in-enabled sites, you will be connected to the servers of YouTube. It tells the YouTube server which of our pages you’ve visited. If you’re logged into your YouTube account, YouTube will allow you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. The use of YouTube is in the interest of an attractive presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO. For more information on how to handle user data, please refer to the YouTube Privacy Policy at: https://www.google.com/intl/en/policies/privacy.
Newsletter
You have the opportunity to subscribe to our newsletter via our website or on request directly from us. For this we need your e-mail address and your declaration that you agree with the subscription to the newsletter. In order to provide you with targeted information, we also collect and process information voluntarily provided on areas of interest, birthday and postal code. You can cancel the subscription to the newsletter at any time. Please send your cancellation to the following e-mail address: marketing@hintertuxerhof.at We will immediately delete your data in connection with the newsletter dispatch.
10. Changes
This Privacy Policy takes effect on 25.05.2018. The Data Controller reserves the right to amend or update the content of this policy, in part or in full, especially in the case of changes in the applicable law. Since the content of our Website and Privacy Policy may be subject to change, we recommend you visit this section regularly for updates on how we collect and use Personal Data.
11. Contact
You can reach us under the following contact details:
Kinder- & Gletscherhotel Hintertuxerhof
Max Kofler GesmbH & Co KG
Family Kofler
Hintertux 780
A-6294 Hintertux
Tel: +43 5287 8530
Fax: +43 5287 85305
Email: info@hintertuxerhof.at