Booking

Privacy Policy

With this Privacy Policy, we inform you about the personal data we process in connection with our activities and tasks, including our hotelvorab.ch website. We inform you in particular about the purposes, methods, and locations of the personal data we process. We also inform you about the rights of individuals whose data we process.

For individual or additional activities and tasks, additional privacy policies as well as other legal documents such as General Terms and Conditions (GTC), Terms of Use or Participation Conditions may apply.

We are subject to Swiss data protection law as well as any applicable foreign data protection law, such as that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. Contact Addresses

Responsibility for the processing of personal data:

Hotel Vorab AG
Via Nova 38
7017 Flims Dorf
Switzerland

info@hotelvorab.ch

We will inform you if there are other responsible parties for the processing of personal data in individual cases.

1.1 Data Protection Officer

We have the following data protection officer as a point of contact for affected individuals and as a contact person for supervisory authorities for data protection-related inquiries:

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 the following data protection representation according to Art. 27 GDPR. The data protection representation serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the General Data Protection Regulation (GDPR):

VGS Datenschutzpartner UG
Am Kaiserkai 69
20457 Hamburg
Germany

info@datenschutzpartner.eu

2.1 Terms

Personal data means any information relating to an identified or identifiable natural person. A data subject is a person about whom personal data is processed.

Processing means any operation or set of operations which is performed on 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 of personal data.

The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

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

We process personal data in accordance with at least one of the following legal bases, to the extent and insofar as the General Data Protection Regulation (GDPR) is applicable:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data to fulfill a contract with the data subject and to carry out pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to safeguard our legitimate interests or those of third parties, provided that the fundamental freedoms and rights and interests of the data subject do not prevail. Legitimate interests are in particular our interest in exercising our activities and operations permanently, user-friendly, secure and reliable, as well as being able to communicate about them, ensuring information security, protection against misuse, enforcement of our own legal claims, and compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of the Member States of the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the data subject’s consent.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

3. Type, Scope and Purpose

We process those personal data that are necessary to exercise our activities and operations permanently, user-friendly, secure and reliable. Such personal data may include categories of inventory and contact data, browser and device data, content data, meta and edge data, usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration necessary for the respective purpose or purposes or as required by law. Personal data that is no longer required will be anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. These third parties are in particular specialised providers whose services we use. We also ensure data protection with such third parties.

We only process personal data with the consent of the data subject, unless the processing is permissible for other legal reasons. Processing without consent may, for example, be permissible to fulfill a contract with the data subject and for corresponding pre-contractual measures, to safeguard our overriding legitimate interests, because the processing is apparent from the circumstances or after prior information.

In this context, we process in particular information that a data subject voluntarily transmits to us when contacting us – for example, by postal mail, email, instant messaging, contact form, social media, or telephone – or when registering for a user account. We may store such information, for example, in an address book, a customer relationship management system (CRM system), or with comparable tools. When we receive data about other persons, the transmitting persons are obliged to ensure data protection for these persons and to ensure the accuracy of this personal data.

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

4. Personal data abroad

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

We may export personal data to all states and territories on Earth as well as elsewhere in the Universe, provided that the applicable law in that location ensures adequate data protection according to the assessment of the Swiss Federal Data Protection and Information Commissioner (FDPIC) or based on a decision of the Swiss Federal Council or, if and to the extent that the General Data Protection Regulation (GDPR) applies, according to a decision of the European Commission.

We may transfer personal data to states where the applicable law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to states without adequate or appropriate data protection if the special data protection requirements are met, such as the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we will be happy to provide data subjects with information about any safeguards or provide a copy of such safeguards.

5. Rights of data subjects

Data subjects whose personal data we process have the rights under Swiss data protection law. These include the right to information and the right to correction, deletion or blocking of the processed personal data.

Data subjects whose personal data we process may – if and to the extent that the General Data Protection Regulation (GDPR) applies – request confirmation free of charge as to whether we are processing personal data relating to them. In this case, data subjects may request information on the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted (the “right to be forgotten”), blocked or completed.

Data subjects whose personal data we process may – if and to the extent that the GDPR applies – revoke their consent granted at any time with effect for the future and object to the processing of their personal data at any time.

Individuals whose personal data we process have the right to lodge a complaint with a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

6. Data security

We take appropriate technical and organizational measures to ensure an appropriate level of data security that corresponds to the respective risk. However, we cannot guarantee absolute data security.

Access to our website is secured with transport encryption (SSL/TLS, particularly with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication is subject to mass surveillance without cause or suspicion, as well as other surveillance by law enforcement authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries, as is the case with all digital communication in principle. We cannot exert direct influence on the corresponding processing of personal data by intelligence services, police authorities, and other law enforcement authorities.

7. Use of the website

7.1 Cookies

We may use cookies. Cookies – both first-party cookies and third-party cookies that we use (third-party cookies) – are data stored in the browser. Such stored data need not be limited to traditional text-based cookies.

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

Cookies can be deactivated or deleted completely or partially at any time in the browser settings. Without cookies, our website may not be fully available. We therefore request – at least where necessary – express consent to the use of cookies.

For cookies used for success and reach measurement or advertising, a general objection (“opt-out”) is possible for numerous services via 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).

7.2 Server log files

We may collect the following information for each access to our website, provided it is transmitted by your browser to our server infrastructure or can be determined by our web server: date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including transmitted data volume, last website accessed in the same browser window (referrer).

We store such information, which may also represent personal data, in server log files. The information is necessary to provide our website permanently, user-friendly, and reliably, and to ensure data security and in particular the protection of personal data – also by third parties or with the help of third parties.

7.3 Counting pixels

We may use counting pixels on our website. Counting pixels are also known as web beacons. Counting pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when visiting our website. Counting pixels can collect the same information as in server log files.

8. Notifications and messages

We send notifications and messages by email and other communication channels such as instant messaging or SMS.

8.1 Success and reach measurement

Notifications and messages may contain web links or tracking pixels that record whether an individual notification was opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and messages in a personalized manner. We require this statistical recording of usage for success and reach measurement in order to effectively, user-friendly, permanently, securely, and reliably send notifications and messages based on the needs and reading habits of recipients.

You must generally explicitly consent to the use of your email address and other contact information, unless the use is legally permissible for other reasons. We use the “double opt-in” procedure wherever possible for any such consent. This means you receive an email with a web link that you must click to confirm, in order to prevent abuse by unauthorized third parties. We may log such consents, including Internet Protocol (IP) address, date and time, for evidentiary and security reasons.

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

8.3 Service providers for notifications and messages

We send notifications and messages using specialized service providers.

In particular, we use:

9. Social Media

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

The general terms and conditions (GTC) and terms of use, as well as the data protection declarations and other provisions of the individual operators of such platforms, also apply. These provisions provide information, in particular, about the rights of affected persons directly with respect to the respective platform, which includes, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are – to the extent and as far 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). The Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook effectively and user-friendly.

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

10. Third-Party Services

We use services from specialized third parties to permanently carry out our activities and tasks in a user-friendly, secure, and reliable manner. With such services, we can embed functions and content into our website. In such an embedding, the services used capture the internet protocol (IP) addresses of users for technical reasons at least temporarily.

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

In particular, we use:

10.1 Digital Infrastructure

We use services from specialized third parties to be able to access the necessary digital infrastructure in connection with our activities and tasks. This includes hosting and storage services from selected providers.

In particular, we use:

10.2 Contact Options

We use services from selected providers to better communicate with third parties such as potential and existing customers.

10.3 Audio and Video Conferences

We use specialized services for audio and video conferences to communicate online. For example, we can hold virtual meetings or conduct online classes and webinars. In addition to our own privacy policies, the legal texts of each service, such as privacy policies and terms of use, also apply to participation in audio and video conferences.

Depending on your life situation, we recommend that you mute the microphone by default when participating in audio or video conferences, and blur the background or display a virtual background.

We use in particular:

10.4 Map Material

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

In particular, we use:

10.5 Digital audio and video content

We use services from specialized third parties to enable direct playback of digital audio and video content such as music or podcasts.

In particular, we use:

10.6 Fonts

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

In particular, we use:

10.7 E-Commerce

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

10.8 Advertising

We use the option to display targeted advertising for our activities and operations on third-party platforms such as social media platforms and search engines.

We want to reach people with such advertising who are already interested in or could be interested in our activities and operations (remarketing and targeting). For this purpose, we may provide corresponding – possibly personal – information to third parties that enable such advertising. We may also determine whether our advertising is successful, i.e., whether it leads to visits to our website (conversion tracking).

Third parties on which we advertise and where you are registered as a user may potentially associate the use of our online offerings with your local profile.

In particular, we use:

11. Success and Reach Measurement

We use services and programs to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and actions as well as the impact of third-party links on our website. We can also, for example, test and compare how different versions of our online offering or parts of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can, in particular, fix errors, strengthen popular content, or make improvements to our online offering.

When using services and programs for success and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened (“IP masking”) to follow the principle of data minimization through the corresponding pseudonymization and to improve data protection for users.

When using services and programs for success and reach measurement, cookies may be used and user profiles created. User profiles include, for example, the pages visited or content viewed on our website, information about the size of the screen or browser window, and the – at least approximate – location. Basically, user profiles are created exclusively in pseudonymized form. We do not use user profiles to identify individual users. Individual third-party services where users are logged in may be able to assign the use of our online offering to the user account or profile at the respective service.

We use in particular:

12. Final Provisions

We created this privacy policy with the privacy policy generator from Datenschutzpartner.

We reserve the right to modify and supplement this privacy policy at any time. We will inform about such modifications and supplements in an appropriate manner, in particular by publishing the current privacy policy on our website.