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
We have drafted this Privacy Policy in the German language. If published in another language, the German-language Privacy Policy shall prevail.
For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.
We are subject to Swiss law and, where applicable, foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
The European Commission recognised, by decision of 26 July 2000, that Swiss data protection law ensures an adequate level of data protection. By report of 15 January 2024, the European Commission confirmed this adequacy decision.
Table of Contents
- 1. Contact Details
- 2. Definitions and Legal Bases
- 3. Nature, Scope and Purpose of the Processing of Personal Data
- 4. Disclosure of Personal Data
- 5. Communication
- 6. Applications
- 7. Data Security
- 8. Personal Data Abroad
- 9. Rights of Data Subjects
- 10. Use of the Website
- 11. Notifications and Communications
- 12. Social Media
- 13. Third-Party Services
- 14. Success and Reach Measurement
- 15. Final Notes on the Privacy Policy
1. Contact Details
The controller within the meaning of data protection law is:
Hotel Vorab AG
Via Nova 38
7017 Flims Dorf
Switzerland
In individual cases, third parties may be responsible for the processing of personal data, or joint responsibility with third parties may exist. We are happy to provide data subjects with information about the respective responsibility upon request.
1.1 Data Protection Officer or Data Protection Adviser
We have appointed the following data protection officer or data protection adviser as a point of contact for data subjects and authorities in matters relating to data protection:
Gian-Reto Meiler
Hotel Vorab AG
Via Nova 38
7017 Flims Dorf
Switzerland
1.2 Data Protection Representative in the European Economic Area (EEA)
We have appointed the following data protection representative pursuant to Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The data protection representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the wider European Economic Area (EEA) for enquiries in connection with the GDPR.
2. Definitions and Legal Bases
2.1 Definitions
Data subject: Natural person about whom we process personal data.
Personal data: All information relating to an identified or identifiable natural person.
Sensitive personal data: Data concerning trade union membership, political, religious or philosophical views and activities, data concerning health, the intimate sphere or membership of an ethnic group or race, genetic data, biometric data that uniquely identify a natural person, data concerning criminal and administrative sanctions or prosecutions, and data concerning social welfare measures.
Processing: Any handling of personal data, regardless of the means and procedures applied, such as querying, matching, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, making available, organising, structuring, saving, altering, 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).
Where and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process personal data on the basis of at least one of the following legal bases:
- Art. 6(1)(b) GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6(1)(f) GDPR for the necessary processing of personal data to protect legitimate interests – including the legitimate interests of third parties – unless the fundamental freedoms and fundamental rights and interests of the data subject override such interests. Such interests include in particular the permanent, user-friendly, secure and reliable conduct of our activities and operations, ensuring information security, protection against misuse, enforcement of our own legal claims and compliance with Swiss law.
- Art. 6(1)(c) GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject under applicable law of member states in the European Economic Area (EEA).
- Art. 6(1)(e) GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6(1)(a) GDPR for the processing of personal data with the consent of the data subject.
- Art. 6(1)(d) GDPR for the necessary processing of personal data 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, in particular with 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 sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. Nature, Scope and Purpose of the Processing of Personal Data
We process those personal data that are necessary to conduct our activities and operations in a permanent, 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, contractual data and payment data. The personal data may also constitute sensitive 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, to the extent that such processing is permissible.
We process personal data, where necessary, with the consent of the data subjects. We may process personal data without consent in many cases, for example to fulfil legal obligations or to protect overriding interests. We may also request consent from data subjects where their consent is not required.
We process personal data for the duration required for the respective purpose. We anonymise 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 may include, for example, specialised providers whose services we use. Such third parties may in turn disclose personal data to further third parties.
In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, accounting and fiduciary service providers, debt collection companies, interest groups, IT service providers, cooperation partners, credit and commercial information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.
5. Communication
We process personal data in order to communicate with individuals as well as with authorities, organisations and companies. In doing so, we process in particular data that a data subject transmits to us when making contact, for example by post or e-mail. We may store such data in an address book or using comparable tools.
Third parties who transmit data about other individuals to us are legally obliged to ensure the data protection of those data subjects independently. They must in particular ensure that they are authorised to transmit such data, and must also guarantee the accuracy of the data transmitted.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We may also use such services to manage the data of data subjects beyond direct communication and to process it in other ways, for example in connection with orders, services, projects and resource planning.
6. Applications
We process personal data about applicants to the extent necessary for assessing their suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data arise in particular from the information requested, for example in the context of a job advertisement. We may publish job advertisements with the assistance of suitable third parties, for example in electronic and printed media or on job portals and recruitment platforms.
We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, curricula vitae and other application documents, as well as online profiles.
Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular pursuant to Art. 9(2)(b) GDPR.
We use selected services from suitable third parties to advertise positions by means of e-recruitment and to enable and manage applications.
7. Data Security
We implement appropriate technical and organisational measures to ensure a level of data security appropriate to the respective risk. Our measures ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without however being able to guarantee absolute data security.
Access to our website and our other digital presence is provided by means of transport encryption (SSL / TLS, in particular using the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn before visiting a website without transport encryption.
Our digital communications are subject – as is in principle all 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 cannot directly influence the corresponding processing of personal data by intelligence services, police authorities and other security agencies. We also cannot rule out that a data subject may be specifically monitored.
8. Personal Data Abroad
We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular to process it or have it processed there.
We may export personal data to all countries on Earth and elsewhere in the universe, provided that the law of the respective country ensures an adequate level of data protection pursuant to a decision of the Swiss Federal Council and – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – also pursuant to a decision of the European Commission.
We may transfer personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard contractual clauses or other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We are happy to provide data subjects with information about any applicable safeguards or to supply a copy of any applicable safeguards upon request.
9. Rights of Data Subjects
9.1 Data Protection Claims
We grant data subjects all rights under applicable law. Data subjects have in particular the following rights:
- Access: Data subjects may request information as to whether we process personal data about them, and if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
- Rectification and restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed, and the processing of their data restricted.
- Right to express own view and human review: In the case of decisions based solely on automated processing of personal data that have a legal consequence for data subjects or significantly affect them (automated individual decisions), data subjects may express their own view and request review by a human.
- Erasure and objection: Data subjects may request the erasure of personal data ("right to be forgotten") and object to the processing of their data with effect for the future.
- Data portability and data transfer: Data subjects may request the release of personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of data subjects' rights to the extent permitted by law. We may draw data subjects' attention to any conditions that must be met in order to exercise their data protection claims. We may, for example, refuse access in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other individuals. We may also, for example, refuse the erasure of personal data in whole or in part, in particular with reference to statutory retention obligations.
We may exceptionally charge fees for the exercise of rights. We will inform data subjects in advance of any applicable fees.
We are obliged to identify data subjects who request access or assert other rights by means of appropriate measures. Data subjects are required to cooperate.
9.2 Legal Remedies
Data subjects have the right to enforce their data protection claims through legal proceedings or to file 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 organised as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), the data protection supervisory authorities are structured on a federal basis, in particular in Germany.
10. Use of the Website
10.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies may be stored in the browser temporarily as "session cookies" or for a specific period as so-called persistent cookies. Session cookies are automatically deleted when the browser is closed. Persistent cookies have a specific storage duration. Cookies enable in particular the recognition of a browser on the next visit to our website, thereby allowing, for example, the reach of our website to be measured. Persistent cookies may also be used, for example, for online marketing.
Cookies can be deactivated, restricted or deleted in whole or in part at any time via the browser settings. Browser settings also frequently allow for the automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least where and to the extent required under applicable law – express consent to the use of cookies.
For cookies used for success and reach measurement or for advertising, a general 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).
10.2 Logging
For each access to our website and our other digital presence, we may log at least the following information, provided that it is routinely determined or 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, individual sub-page of our website accessed including the volume of data transferred, last webpage accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. The information is necessary to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also necessary to ensure data security – including by third parties or with the assistance of third parties.
10.3 Tracking Pixels
We may embed tracking pixels in our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are typically small, invisible images or scripts formulated in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can capture at least the same information as logging 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 communication has been opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner, as well as permanently, securely and reliably, based on the needs and reading habits of recipients.
11.2 Consent and Objection
You must in principle consent to the use of your e-mail address and other contact details, unless such use is permitted for other legal reasons. For the possible obtaining of double-confirmed consent, we may use the "double opt-in" procedure. In this case, you will receive a communication with instructions for double confirmation. We may log consents obtained, including IP address and timestamp, for evidentiary and security purposes.
You may in principle object at any time to the receipt of notifications and communications such as newsletters. Such an objection may simultaneously constitute an objection to the statistical recording of usage for success and reach measurement. Reserved are necessary notifications and communications in connection with our activities and operations.
11.3 Service Providers for Notifications and Communications
We send notifications and communications with the assistance of specialised service providers.
We use in particular:
- MAILINGWORK: E-mail marketing platform; provider: Mailingwork GmbH (Germany); information on data protection: Privacy Policy, "Privacy Policy and Newsletter Dispatch – What needs to be considered?".
12. Social Media
We are present on social media platforms and other online platforms in order to communicate with interested individuals and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as the privacy policies and other provisions of the individual operators of such platforms also apply. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.
For our social media presence on Facebook, including the so-called Page Insights, we are – where and to the extent that 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 about how visitors interact with our Facebook presence. We use Page Insights to be able to provide our social media presence on Facebook effectively and in a user-friendly manner.
Further information on the nature, scope and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook as well as Facebook's data protection officer can be found in the Facebook Privacy Policy. We have concluded the so-called "Controller Addendum" with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the "Page Insights Information" page, including "Information about Page Insights Data".
13. Third-Party Services
We use services from specialised third parties in order to be able to conduct our activities and operations in a permanent, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content in our website. When embedding such services, the services used collect, for technically mandatory reasons, at least temporarily the IP addresses of users.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to provide the respective service.
We use in particular:
- Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland), partly for users in the European Economic Area (EEA) and in Switzerland; general information on data protection: "Our approach to privacy", Privacy Policy, "How Google uses personal information", "Google's commitment to complying with applicable data protection laws", "Guide to privacy in Google products", "How we use data from websites or apps that use our services", Cookie Policy, "Ads that include your choices" (personalised advertising settings).
13.1 Digital Infrastructure
We use services from specialised third parties in order to be able to make use of the required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We use in particular:
- exigo: Hosting; provider: exigo ag (Switzerland); information on data protection: Privacy Policy, "Data protection / security".
13.2 Maps
We use services from third parties in order to be able to embed maps in our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; provider: Google; Google Maps-specific information: "How Google uses location information".
13.3 E-Commerce
We operate e-commerce and use services from third parties in order to be able to successfully offer services, content or goods.
13.4 Payments
We use specialised service providers in order to be able to process payments securely and reliably. The processing of payments is additionally governed by the legal terms of the individual service providers, such as general terms and conditions (GTC) or privacy policies.
We use in particular:
- PostFinance: Processing of payments; provider: PostFinance AG (Switzerland); information on data protection: "Legal information and accessibility", "Data protection" (including privacy policies).
- Worldline: Processing of payments, in particular with mobile payment solutions; providers: Worldline SA (France), Worldline Switzerland AG (Switzerland) and other Worldline companies worldwide (including in the USA); information on data protection: Privacy Policy, "Responsible Disclosure Program", Cookie Policy.
13.5 Advertising
We make use of 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 aim in particular to reach individuals who are already interested in or could be interested in our activities and operations (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties who enable such advertising. We may also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may be able to associate the use of our website with your profile on that platform.
We use in particular:
- Google Ads: Search engine advertising; provider: Google; Google Ads-specific information: advertising based inter alia on search queries, whereby various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – are used for Google Ads, Privacy Policy for Advertising, "Manage ads shown to you directly from ads".
- Meta Ads: Social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: targeting, including retargeting, in particular with the Meta Pixel and with Custom Audiences including Lookalike Audiences, Privacy Policy, "Ad preferences" (login as a user required).
14. Success and Reach Measurement
We endeavour to measure the success and reach of our activities and operations. In this context, we may also measure the effect of references from third parties or examine how different parts or versions of our digital presence are used ("A/B testing" method). Based on the results of success and reach measurement, we may in particular fix errors, strengthen popular content or make improvements.
For success and reach measurement, the IP addresses of individual users are collected in most cases. In this context, IP addresses are in principle truncated ("IP masking") in order to follow the principle of data minimisation through the corresponding pseudonymisation.
Cookies may be used for success and reach measurement and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window, and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual services from third parties with which users are registered may be able to associate the use of our online offering with the user account or user profile on the respective service.
We use in particular:
- Google Marketing Platform: Success and reach measurement, in particular with Google Analytics; provider: Google; Google Marketing Platform-specific information: measurement also across different browsers and devices (cross-device tracking) with pseudonymised IP addresses, which are only exceptionally transmitted in full to Google in the USA, Privacy Policy for Google Analytics, "Browser add-on to deactivate Google Analytics".
- Google Tag Manager: Integration and management of services from Google and third parties, in particular for success and reach measurement; provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found for the individual integrated and managed services.
15. Final Notes on the Privacy Policy
The present privacy policy is an unofficial translation from the original German version. We have created this Privacy Policy using the Privacy Policy Generator by Datenschutzpartner The present privacy policy is an unofficial translation from the original German version.
We may update this Privacy Policy at any time. We will inform about updates by publishing the current version of the Privacy Policy on our website.