Booking

Privacy Policy

With this Privacy Policy, we inform you about the processing of personal data in connection with our activities and operations, including our website under the domain name hotelvorab.ch. In particular, we explain for what purposes, how, and where we process which personal data. We also inform about the rights of individuals whose data we process.

For individual or additional activities and operations, we may publish further privacy policies or other information regarding data protection.

We are subject to Swiss law and, where applicable, foreign law, especially that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

On 26 July 2000, the European Commission recognized that Swiss data protection law ensures an adequate level of data protection. On 15 January 2024, the European Commission confirmed this adequacy decision.

Table of Contents

1. Contact Addresses

Responsible under data protection law:

Hotel Vorab AG
Via Nova 38
7017 Flims Dorf
Switzerland

info@hotelvorab.ch

In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. Upon request, we are happy to provide information about the specific responsibilities.

1.1 Data Protection Officer or Advisor

We have appointed the following Data Protection Officer or Advisor as the point of contact for data subjects and authorities for inquiries regarding data protection:

Gian-Reto Meiler
Hotel Vorab AG
Via Nova 38
7017 Flims Dorf
Switzerland

info@hotelvorab.ch

1.2 Data Protection Representation in the European Economic Area (EEA)

We have appointed the following Data Protection Representation pursuant to Art. 27 GDPR:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

info@hotelvorab.ch

The data protection representation serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the GDPR.

2. Terms and Legal Bases

2.1 Terms

Data Subject: Natural person whose personal data we process.

Personal Data: Any information relating to an identified or identifiable natural person.

Special Categories of Personal Data: Data concerning trade union, political, religious, or ideological views and activities, health data, data relating to intimate life or racial or ethnic origin, genetic data, biometric data uniquely identifying a natural person, data concerning criminal convictions and offenses or administrative sanctions, and data regarding measures of social assistance.

Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, retaining, reading, disclosing, procuring, collecting, recording, deleting, revealing, arranging, organizing, storing, modifying, disseminating, linking, destroying, and using personal data.

European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

2.2 Legal Bases

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, FADP) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

We also process personal data in accordance with the European General Data Protection Regulation (GDPR) — if and insofar as it is applicable — based on at least one of the following legal bases:

  • Art. 6(1)(b) GDPR for processing necessary for the performance of a contract with the data subject or in order to take steps prior to entering into a contract.
  • Art. 6(1)(f) GDPR for processing necessary for the purposes of legitimate interests pursued by us or a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject. Such legitimate interests include the continuous, user-friendly, secure, and reliable operation of our activities and services, ensuring information security, protection against misuse, enforcement of our own legal claims, and compliance with Swiss law.
  • Art. 6(1)(c) GDPR for processing necessary for compliance with a legal obligation to which we are subject under applicable laws of member states within the European Economic Area (EEA).
  • Art. 6(1)(e) GDPR for processing necessary for the performance of a task carried out in the public interest.
  • Art. 6(1)(a) GDPR for processing based on the data subject’s consent.
  • Art. 6(1)(d) GDPR for processing necessary to protect the vital interests of the data subject or another natural person.
  • Art. 9(2) et seq. GDPR for the processing of special categories of personal data, particularly based on the consent of the data subjects.

The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data, and the processing of special categories of personal data as the processing of special categories of personal data (Art. 9 GDPR).

3. Type, Scope, and Purpose of Processing Personal Data

We process personal data that is necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The personal data processed may fall in particular into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also include special categories of personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of performing our activities and operations, as long as such processing is permitted.

We process personal data where necessary with the consent of the data subjects. In many cases, we may process personal data without consent — for example, to comply with legal obligations or to safeguard overriding interests. We may also request consent from data subjects even if it is not required.

We process personal data for the duration required for the respective purpose. We anonymize or delete personal data, in particular depending on statutory retention and limitation periods.

4. Disclosure of Personal Data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties are in particular specialized service providers whose services we use.

For example, we may disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, advocacy groups, IT service providers, cooperation partners, credit agencies and business information services, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, insurance providers, and payment service providers.

5. Communication

We process personal data in order to communicate with individuals as well as with authorities, organizations, and companies. In doing so, we process in particular data that a data subject provides to us when making contact, for example by postal mail or email. We may store such data in an address book or using similar tools.

Third parties who provide us with data about other individuals are obliged to independently ensure the data protection of the affected persons. In particular, they must ensure that such data is accurate and may be transmitted.

We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. With such services, we may also manage and otherwise process the data of the data subjects beyond direct communication.

6. Applications

We process personal data of applicants to the extent necessary to assess their suitability for employment or to execute an employment contract at a later stage. The required personal data are derived in particular from the requested information, for example as part of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and print media or on job portals and job platforms.

We also process personal data that applicants voluntarily provide or publish, especially as part of cover letters, CVs, other application documents, or online profiles.

We process — if and insofar as the General Data Protection Regulation (GDPR) applies — personal data of applicants in particular pursuant to Art. 9(2)(b) GDPR.

7. Data Security

We take appropriate technical and organizational measures to ensure data security that is appropriate to the respective risk. Our measures particularly ensure the confidentiality, availability, traceability, and integrity of the processed personal data — although absolute data security cannot be guaranteed.

Access to our website and other digital presence is protected by transport encryption (SSL / TLS, in particular via Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption.

Our digital communication is subject — as generally with any digital communication — to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence over the respective processing of personal data by intelligence agencies, police authorities, and other security services. We also cannot rule out that a data subject may be specifically monitored.

8. Personal Data Abroad

We generally process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, particularly to process them there or have them processed.

We may export personal data to any country on Earth and elsewhere in the universe, provided that the local law — according to the decision of the Swiss Federal Council and — if and insofar as the General Data Protection Regulation (GDPR) applies — also according to the decision of the European Commission — ensures adequate data protection.

We may transfer personal data to countries whose law does not ensure adequate data protection if data protection is guaranteed for other reasons — in particular based on standard data protection clauses or with other suitable safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the specific legal requirements for data protection are met, for example the explicit consent of the data subject or a direct connection with the conclusion or performance of a contract. Upon request, we are happy to inform data subjects about any guarantees or provide a copy of such guarantees.

9. Rights of Data Subjects

9.1 Data Protection Rights

We grant all rights to data subjects in accordance with applicable law. Data subjects particularly have the following rights:

  • Access: Data subjects may request information on whether we process personal data about them, and if so, what personal data is involved. They also receive the information necessary to assert their data protection rights and ensure transparency. This includes the personal data itself and, among other things, information on the purpose of processing, the retention period, any disclosure or transfer of data to other countries, and the source of the personal data.
  • Rectification and Restriction: Data subjects may have incorrect personal data rectified, incomplete data completed, and processing restricted.
  • Right to Express Own View and Human Review: In the case of decisions based solely on automated processing of personal data that have legal effects or significantly affect them (automated individual decisions), data subjects may express their point of view and request a human review.
  • Erasure and Objection: Data subjects may request the erasure of their personal data (“right to be forgotten”) and object to future processing.
  • Data Portability: Data subjects may request the provision of their personal data or transfer to another controller.

We may defer, restrict, or deny the exercise of data subject rights within the legally permissible framework. We may inform data subjects about any conditions that must be met for the exercise of their data protection rights. For example, we may refuse to provide information in whole or in part by referring to confidentiality obligations, overriding interests, or the protection of other persons. Similarly, we may refuse to delete personal data, particularly by referring to statutory retention obligations.

We may exceptionally impose costs for the exercise of rights. We inform affected individuals in advance about any such costs.

We are obligated to identify individuals who request information or assert other rights by appropriate measures. Affected individuals are required to cooperate.

9.2 Legal Remedies

Data subjects have the right to enforce their data protection rights through legal proceedings or to lodge a complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), data protection supervisory authorities are organized federally, particularly in Germany.

10. Use of the Website

10.1 Cookies

We may use cookies. Cookies — whether our own (first-party cookies) or from third parties whose services we use (third-party cookies) — are data stored in the browser. Such stored data does not necessarily have to be limited to traditional text-form cookies.

Cookies can be stored in the browser temporarily as “session cookies” or for a certain period as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies in particular make it possible to recognize a browser on a subsequent visit to our website, for example to measure the reach of our website. However, permanent cookies can also be used for online marketing.

Cookies can be completely or partially deactivated, restricted, or deleted at any time in the browser settings. Browser settings often also allow for the automated deletion and management of cookies. Without cookies, our website may no longer be available in full. We actively request explicit consent for the use of cookies — at least insofar as required by applicable law.

For cookies used for success and reach measurement or advertising, many services offer a general opt-out through AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

10.2 Logging

We may log at least the following information for each access to our website and other digital presence, insofar as this information is transmitted to our digital infrastructure during such access: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, the individual subpage of our website accessed including the amount of data transferred, and the previously visited page in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. This information is necessary to ensure the sustainable, user-friendly, and reliable provision of our digital presence. It is also necessary to ensure data security — including by third parties or with the help of third parties.

10.3 Tracking Pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels — including those from third parties whose services we use — are usually small, invisible images or scripts formulated in JavaScript that are automatically loaded when accessing our digital presence. Tracking pixels can capture at least the same information as recorded in log files.

11. Notifications and Communications

11.1 Success and Reach Measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels can also capture the use of notifications and communications in a personally identifiable manner. We need this statistical recording to measure success and reach, enabling us to send notifications and communications effectively, user-friendly, and reliably based on the needs and reading habits of recipients.

11.2 Consent and Objection

You must generally consent to the use of your email address and other contact information, unless use is permitted for other legal reasons. To obtain consent, we may use a “double opt-in” procedure. In this case, you will receive a message with instructions for confirming your consent. We may log obtained consents, including the IP address and timestamp for proof and security reasons.

You may generally object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of use for success and reach measurement. Required notifications and communications related to our activities and operations remain reserved.

11.3 Service Providers for Notifications and Communications

We send notifications and communications with the help of specialized service providers.

In particular, we use:

12. Social Media

We are present on social media platforms and other online platforms to communicate with interested individuals and inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The terms and conditions, terms of use, privacy policies, and other provisions of the respective platform operators also apply. These provisions particularly inform about the rights of data subjects directly against the respective platform, including, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are — if and insofar as the General Data Protection Regulation (GDPR) is applicable — jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including in the USA). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to make our Facebook social media presence effective and user-friendly.

Further information about the type, scope, and purpose of data processing, as well as information on the rights of data subjects and the contact details of Facebook and Facebook’s data protection officer, can be found in the Facebook Privacy Policy. We have concluded the so-called “Controller Addendum” with Facebook and have agreed, in particular, that Facebook is responsible for ensuring the rights of data subjects. The relevant information regarding Page Insights can be found on the page “Information about Page Insights” including “Information about Page Insights Data”.

13. Third-Party Services

We use services provided by specialized third parties to perform our activities and operations sustainably, user-friendly, securely, and reliably. With such services, we can embed functions and content into our website. For technical reasons, the services used must at least temporarily capture users’ IP addresses.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data necessary to provide the respective service.

We particularly use:

13.1 Digital Infrastructure

We use services from specialized third parties to access necessary digital infrastructure for our activities and operations. This includes, for example, hosting and storage services from selected providers.

We particularly use:

13.2 Maps

We use services from third parties to embed maps into our website.

We particularly use:

13.3 Fonts

We use services from third parties to embed selected fonts as well as icons, logos, and symbols into our website.

We particularly use:

13.4 E-Commerce

We operate e-commerce and use services from third parties to successfully offer services, content, or goods.

13.5 Payments

We use specialized service providers to process payments securely and reliably. In addition, the legal texts of the individual service providers, such as general terms and conditions (GTC) or privacy policies, apply to the processing of payments.

We particularly use:

13.6 Advertising

We use the opportunity to display targeted advertising with third parties such as social media platforms and search engines for our activities and operations.

With such advertising, we particularly aim to reach individuals who are already interested or might be interested in our activities and operations (remarketing and targeting). For this purpose, we may transmit corresponding — possibly personal — data to third parties who enable such advertising. We may also determine whether our advertising is successful, meaning in particular whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and where you are registered as a user may be able to associate the use of our website with your respective profile there.

We particularly use:

14. Success and Reach Measurement

We aim to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party references or test how different parts or versions of our digital presence are used (the “A/B testing” method). Based on the results of success and reach measurement, we can particularly fix errors, strengthen popular content, or make improvements.

For success and reach measurement, IP addresses of individual users are mostly collected. IP addresses are generally shortened (“IP masking”) to follow the principle of data minimization through pseudonymization.

Cookies may be used, and user profiles may be created during success and reach measurement. Possible user profiles may include, for example, the pages visited or content viewed on our digital presence, information about the screen or browser window size, and the — at least approximate — location. Generally, any user profiles created are pseudonymized and not used to identify individual users. However, individual services from third parties where users are registered may associate the use of our online offering with their user account or profile at the respective service.

We particularly use:

15. Final Notes on the Privacy Policy

The present privacy policy is an unofficial translation from the original German version.

We created this Privacy Policy with the help of the Privacy Policy Generator from Datenschutzpartner .

We may update this Privacy Policy at any time. We will inform about updates in an appropriate manner, in particular by publishing the current version of the Privacy Policy on our website.