Privacy Policy

Last modified: January 2021

The operators of these pages (hereinafter only „responsible parties“ or „operators“) take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this data protection declaration.

The use of our website is generally possible without providing personal data. Insofar as personal data (for example name, address or e-mail addresses) is collected on our pages, this is always done, as far as possible, on a voluntary basis. This data will not be passed on to third parties without your express consent.

The processing of your personal data, for example the name, address, e-mail address or telephone number, is always in accordance with national and European law, in particular the Data Protection Regulation (hereinafter referred to as „DSGVO“). By means of this data protection declaration, our company would like to inform you about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, by means of this data protection declaration, you will be informed about the rights to which you are entitled.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

1. Definitions

The data protection declaration of these pages is based on the terms of Article 4 of the DSGVO, which were defined by the European Union when it adopted the General Data Protection Regulation (DSGVO). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms, among others, in this data protection declaration:

• personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter „data subject“ or „user“). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

• b) Data subject

Data subject means any identified or identifiable natural person whose personal data, are processed by the controller.

• c) Processing

Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

• e) Profiling

Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

• f) Pseudonymization

Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separate and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

• g) Controller or person responsible for processing.

The controller or controller is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.

• h) Processor

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

• Recipient

Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, authorities that may receive Personal Data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

• j) Third Party

Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

• k) Consent

Consent shall mean any freely given indication of the data subject’s wishes for the specific case in an informed and unambiguous manner, in the form of a statement or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

2. Rights of the user

We are also concerned to make you aware of the rights to which you are entitled on the basis of the GDPR with regard to the processing of your data:

• Right to confirmation (Art. 15(1) GDPR).

Every data subject has the right to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact the address indicated in the imprint or this privacy statement, or another employee of the controller.

• b) Right to information (Art. 15 (1) and (3) DSGVO).

Any person affected by the processing of personal data (user) has the right to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of this information. Furthermore, the controller shall provide the data subject with information on the following:

• the purposes of processing
• the categories of personal data processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations
• if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
• the existence of a right to obtain the rectification or erasure of personal data concerning him or her, or to obtain the restriction of processing by the controller, or a right to object to such processing
• the existence of a right of appeal to a supervisory authority
• if the personal data are not collected from the data subject: Any available information about the origin of the data
• The existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

Furthermore, the data subject shall have the right to obtain information as to whether personal data have been transferred to a third country or to an international organization. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.

• c) Right to rectification (Art 16 GDPR).

Any person affected by the processing of personal data has the right to request that inaccurate personal data concerning him or her be rectified without undue delay. Furthermore, the data subject has the right, taking into account the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary declaration.

1. d) Right to erasure (right to be forgotten) (Art. 17 GDPR)

Any person concerned by the processing of personal data has the right to obtain from the controller the erasure without delay of personal data concerning him or her, where one of the following grounds applies and insofar as the processing is no longer necessary:

The personal data were collected or otherwise processed for such purposes for which they are no longer necessary.

• The data subject revokes his or her consent on which the processing was based pursuant to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO and there is no other legal basis for the processing.
• The data subject objects to the processing pursuant to Article 21(1) DS-GVO and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) DS-GVO.

• The personal data have been processed unlawfully.
• The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data has been collected in relation to information society services offered pursuant to Article 8(1) DS-GVO.

If the personal data have been made public by the controller and our company as controller is obliged to erase the personal data pursuant to Article 17 (1) of the DS-GVO, the controller shall implement reasonable measures, including technical measures, taking into account the available technology and the cost of implementation, to inform other data controllers which are processing the published personal data, that the data subject has requested from those other data controllers the erasure of all links to the personal data or copies or replications of the personal data, unless the processing is necessary.

• e) Right to restriction of processing (Art 18 GDPR).

Any person concerned by the processing of personal data has the right to obtain from the controller the restriction of processing where one of the following conditions is met:

• The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
• The controller no longer needs the personal data for the purposes of the processing, but the data subject needs it for the assertion, exercise or defense of legal claims.
• The data subject has objected to the processing pursuant to Article 21 (1) DS-GVO and it is not yet clear whether the legitimate grounds of the controller outweigh those of the data subject.
• f) Right to data portability (Art. 20 DSGVO)
• Any person concerned by the processing of personal data has the right to receive the personal data concerning him or her which have been provided by the data subject to a controller in a structured, commonly used and machine-readable format. He or she also has the right to transmit this data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out with the aid of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising the right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to obtain that the personal data be transferred directly from one controller to another controller, where technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.

• g) Right to object (Art 21 DSGVO).

Any person affected by the processing of personal data has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out on the basis of Art. 6(1)(e) or (f) DS-GVO. This also applies to profiling based on these provisions

The controller shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defense of legal claims.

If the controller processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data for such marketing. This also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to the controller to the processing for direct marketing purposes, the controller will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her which is carried out by the controller for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the Data Protection Regulation, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

The user is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise their right to object by means of automated procedures using technical specifications.

• h) Automated decisions in individual cases, including profiling (Art 22 GDPR).

Any person concerned by the processing of personal data has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is permitted by Union or Member State law to which the data controller is subject, and that law contains suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is made with the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) it is made with the data subject’s explicit consent, the controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain the data subject’s involvement, to express his or her point of view and to contest the decision.

• I) Right to withdraw consent under data protection law.

Any person affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time.

3. Cookies

The Internet pages partly use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called „session cookies“. They are automatically deleted after the end of your visit. Other cookies remain stored on your terminal device until you delete them. These cookies allow us to recognize your browser on your next visit.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, as well as activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

4. Data processing when using PMS systems (widgets)

Widgets from the company zadego GmbH (easybooking) may be implemented on these pages.

zadego GmbH

Tschamlerstrasse 4

6020 Innsbruck

Austria

The provider is a PMS system, which is the provider of the hotel software of the responsible person. The widgets may be – depending on the tourism business – the following:

– Inquiry form

– Booking form

– Small Search (inquiry, booking)

– Category view

– Room view

– Packages Widget

– Price overview

– Price comparison

– Availability calendar

– Online Check-In

• 1 General

In order to process your inquiry or booking, it is necessary to process the data you have provided to the person responsible.

The aforementioned responsible party and zadego GmbH, (both also jointly referred to as „provider“) are in a contractually regulated business relationship. The responsible party obtains its hotel management and booking software from zadego GmbH.

There is a transfer of the personal data disclosed by you to the management system and to companies having business relations with the management system. This transfer takes place in particular to the above-mentioned landlords, possibly also to tourism associations, registration providers, payment providers and other companies that are connected to the management system and/or landlords and must be called upon to fulfill post-contractual obligations.

The use of personal data by the providers is governed by the applicable legal provisions and the consent given by you to the use of your data.

• Collection of data

In the context of an inquiry or booking with the tourism company, you provide relevant data for the implementation of the same. This is usually the following:

– First and last name

– e-mail address

– Your address

– telephone number

– Payment data (bank account, credit card data)

– Birth data (for identification of children)

This data is only collected to the extent permitted by law and only with your consent and through your active participation. Insofar as consent is declared electronically as part of the services, the legal obligations to provide information will be taken into account and this consent will be logged by means of suitable technical systems.

• Purpose of this data processing

The controller will process your personal data in this context for the following purposes:

– Offer submission

– Online check-in

– Fulfillment of notification obligations

– Payment processing

– Invoicing

If personal data is entered in one of these widgets (contact data, e-mail, data of the desired stay in our house), this is always done on a voluntary basis and only for the purpose of being able to submit a corresponding offer to your desired stay.

If no contractual relationship is established between the parties (i.e. there is no stay in the company of the person responsible), the data of the person concerned is immediately deleted from the systems automatically. In individual cases, legal retention and deletion periods must be observed.

• Reporting obligation

According to the applicable registration law, the person responsible is obliged to register all guests residing with the person responsible with the data specified in the registration law. This concerns, among other things, the following data:

– Name

– Name of accompanying persons

– Date of birth

– sex

– nationality

– Country of origin

– Address of traveler

– Travel document (type, number, date of issue, issuing authority, country)

– Date of travel

•  Guest directory

In accordance with a legal obligation, the responsible party must keep a record of all guest data transmitted to him for a booking in a so-called guest directory. This guest directory is subject to the automatic deletion and anonymization periods stored in the system. The Provider shall provide suitable technical and organizational measures to store personal data in the system in accordance with the law. In individual cases, legally prescribed storage and retention periods must be observed and complied with. The set storage periods apply insofar as the data concerned are not processed for longer for other purposes stated in this data protection declaration.

The guest directory is maintained electronically by the person responsible, whereby the data is forwarded to zadego GmbH for this purpose. In this case, zadego GmbH acts as a processor, as it stores the data on its servers. A transfer to a third country does not take place without prior information to the data subjects.

6. SSL encryption

This site uses SSL encryption for security reasons and to protect the transmission of confidential content, such as requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from „http://“ to „https://“ and by the lock symbol in your browser line.

If SSL encryption is activated, the data you transmit to us cannot be read by third parties.

• Privacy policy Google Maps

This website uses the product Google Maps from Google Inc. By using this website, you agree to the collection, processing and use of the automatically collected data by Google Inc., its representatives and third parties.

The terms of use of Google Maps can be found under „Terms of use of Google Maps“.

• Privacy policy on the use and application of Google Analytics (with anonymization function)

The responsible party has integrated the component Google Analytics (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, compilation and evaluation of data about the behavior of visitors to websites. A web analysis service collects, among other things, data on which website a data subject came to a website from (so-called referrers), which subpages of the website were accessed or how often and for how long a subpage was viewed.

The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The responsible party uses the addition „_gat._anonymizeIp“ for web analysis via Google Analytics. By means of this additive, the IP address of the Internet connection of the data subject is shortened and anonymized by Google if access to our Internet pages is from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Among other things, Google uses the data and information obtained to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide other services related to the use of our website.

Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. By each call of one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently enable commission calculations.

By means of the cookie, personal information, for example the access time, the place from which an access originated and the frequency of visits to our website by the data subject, is stored. Each time the data subject visits our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose this personal data collected via the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics and related to the use of this website as well as to the processing of this data by Google and to prevent such processing. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to Internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the information technology system of the data subject is deleted, formatted or reinstalled at a later point in time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. Provided that the browser add-on is uninstalled or deactivated by the data subject or another person attributable to his or her sphere of control, there is the option of reinstalling or reactivating the browser add-on.

9. Privacy policy on the use and application of YouTube

The controller has integrated components of YouTube on this website. YouTube is an Internet video portal that allows video publishers to post video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube allows the publication of all types of videos, which is why complete film and TV shows, but also music videos, trailers or videos made by users themselves can be accessed via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

By each call of one of the individual pages of this website, which is operated by the controller and on which a YouTube component (YouTube video) has been integrated, the Internet browser on the information technology system of the data subject is automatically caused by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information on YouTube can be found at https://www.youtube.com/yt/about/de/. Within the scope of this technical procedure, YouTube and Google receive knowledge of which specific sub-page of our website is visited by the data subject.

If the data subject is logged into YouTube at the same time, YouTube recognizes which specific sub-page of our website the data subject is visiting by calling up a sub-page that contains a YouTube video. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject. YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is simultaneously logged into YouTube at the time of calling up our website; this takes place regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not want this information to be transmitted to YouTube and Google, he or she can prevent the transmission by logging out of his or her YouTube account before accessing our website.

The privacy policy published by YouTube, which is available at https://www.google.de/intl/de/policies/privacy/, provides information about the collection, processing and use of personal data by YouTube and Google.

10 Tripadvisor

Our website uses plugins from the Tripadvisor site operated by Tripadvisor Inc. The operator of the pages is the company Tripadvisor Inc, 141 Needham Street, Newton, MA 02464, USA. You can recognize the plugin by the corresponding logos on our site. When you visit one of our pages equipped with a Tripadvisor plugin, a connection to Tripadvisor’s servers is established. This service thereby receives the information that you have visited our site with your IP address.
For the purpose and scope of the data collection and the further processing and use of the data by TripAdvisor, as well as your rights in this regard and setting options for protecting your privacy, please refer to TripAdvisor’s privacy policy: http://www.tripadvisor.de/pages/privacy.html

11 HolidayCheck Widget

This site embeds a widget from HolidayCheck for displaying reviews. Provider is:
HolidayCheck AG
Bahnweg 8
8598 Bottighofen
Switzerland
(http://www.holidaycheck.de/impressum)
To use the functions of the HolidayCheck widget, it is necessary to store your IP address. This information is usually transmitted to a HolidayCheck server in Switzerland and stored there. The provider of this site has no influence on this data transmission.
When you click on the “Rate now” button, a new window opens. If you enter and submit a rating there, this data is usually transmitted to a HolidayCheck server in Switzerland and stored there. The provider of this site has no influence on this data transfer.
The use of the HolidayCheck widget is in the interest of presenting the reviews of our hotel submitted on HolidayCheck, and to be able to offer the possibility of writing a review on HolidayCheck. This constitutes a legitimate interest within the meaning of Art. 6 (1) lit. f DSGVO.
The data protection guidelines, which information HolidayCheck collects and processes, can be found in the HolidayCheck data protection declaration: https://www.holidaycheck.de/datenschutz.

12. server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
– browser type and browser version
– Operating system used
– referrer URL
– Host name of the accessing computer
– Time of the server request
This data cannot be assigned to specific persons. This data is not merged with other data sources. We reserve the right to check this data retrospectively if we become aware of specific indications of unlawful use.

13. non-existence of an automated decision-making process
As a responsible company, we do not use automated decision-making or profiling.

14. note on online dispute resolution

Online dispute resolution in accordance with Article 14 (1) ODR Regulation: The European Commission provides a platform for online dispute resolution (OS), which you can find at http://ec.europa.eu/consumers/odr/.

15. objection to advertising e-mails

The use of contact data published within the framework of the imprint obligation for the purpose of sending unsolicited advertising and information materials is hereby prohibited. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

16. changes to this privacy policy

We may update our privacy policy from time to time. Therefore, it is recommended that you check this page regularly for changes. We will notify you of changes by posting the new privacy policy on this page. These changes will be effective immediately upon posting on this page.

17. how to contact us
If you have any questions, suggestions or concerns about this policy or how we use your information, please contact us at the address provided in the Legal Notice or this Privacy Policy.

Sonnenalm Mountain Lodge
Michaelerberg 60
A 8965 Michaelerberg-Pruggern
office@sonnenalm.at
www.sonnenalm.at
+43 664 576 1908
+49 176 345 61059
015678584935