Privacy policy Miraval, Val di Non

Thank you for your interest in our company. Data protection is of particular importance to the management of Miraval Hotel. In principle, the Miraval Hotel website can be used without providing any personal data. However, if a data subject wishes to use special services offered by our company through our website, the processing of personal data may be necessary. Where personal data must be processed and there is no legal basis for such processing, we generally obtain the data subject's consent.

The processing of personal data, such as a data subject's name, address, email address or telephone number, is always carried out in accordance with the General Data Protection Regulation and the country-specific data protection provisions applicable to Miraval Hotel. Through this privacy policy, our company wishes to inform the public about the nature, scope and purpose of the personal data we collect, use and process. This privacy policy also informs data subjects of their rights.

As the controller, Miraval Hotel has implemented numerous technical and organisational measures to ensure the most comprehensive possible protection of personal data processed through this website. Nevertheless, internet-based data transmissions may inherently have security vulnerabilities, so absolute protection cannot be guaranteed. Data subjects are therefore free to provide personal data to us by alternative means, for example by telephone.

1. Definitions

The privacy policy of Miraval Hotel is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the public as well as our customers and business partners. To ensure this, we first explain the terminology used.

In this privacy policy, we use the following terms, among others:

• a)    Personal data

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

• b)    Data subject

  A data subject is any identified or identifiable natural person whose personal data is processed by the controller. 
   

• c)    Processing

  Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, 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 means the marking of stored personal data with the aim of limiting its processing in the future. 
   

• e)    Profiling

  Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. 
   

• f)    Pseudonymisation

  Pseudonymisation means processing 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 separately and is subject to technical and organisational measures ensuring that the personal data is not attributed to an identified or identifiable natural person. 
   

• g)    Controller or data controller

  A controller or data 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 processing 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 nomination may be provided for by Union or Member State law. 
   

• h)    Processor

  A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. 
   

• i)    Recipient

  A recipient is a natural or legal person, public authority, agency or other body to which personal data is disclosed, whether or not it is a third party. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. 
   

• j)    Third party

  A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data. 
   

• k)    Consent

  Consent means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which they, by a statement or clear affirmative action, signify agreement to the processing of personal data relating to them. 
   

2. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions relating to data protection is:

Miraval Hotel

Via G. Marconi 12

38012 38012 Predaia frazione Coredo TN

Italy

Tel.: 00390463536141

Email: info@miravalhotel.it

Website: www.miravalhotel.it

3. Cookies

The Miraval Hotel website uses cookies. Cookies are text files that are placed and stored on a computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier consisting of a string of characters that enables websites and servers to identify the particular internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of a data subject from other browsers that contain different cookies. A specific internet browser can be recognised and identified by its unique cookie ID.

By using cookies, Miraval Hotel can provide users of this website with more user-friendly services that would not be possible without cookies.

Cookies allow us to optimise the information and offers on our website for the user. As mentioned above, cookies enable us to recognise website users. The purpose of this recognition is to make using our website easier. For example, a user of a website that uses cookies does not need to enter their login details on every visit because the website and the cookie stored on the user's computer system take care of this. Another example is a shopping-cart cookie in an online shop. The online shop remembers the items a customer has placed in their virtual shopping cart by means of a cookie.

A data subject may prevent the setting of cookies by our website at any time by adjusting the settings of their internet browser, thereby permanently objecting to the use of cookies. Cookies that have already been set can also be deleted at any time through an internet browser or other software. This is possible in all commonly used internet browsers. If a data subject disables cookies in their browser, some functions of our website may not be fully available.

4. Collection of general data and information

Whenever a data subject or automated system accesses the Miraval Hotel website, a range of general data and information is collected and stored in the server log files. This may include (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which the accessing system reaches our website (the referrer), (4) the subpages accessed on our website, (5) the date and time of access, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used to prevent threats in the event of attacks on our information technology systems.

Miraval Hotel does not draw conclusions about the data subject from this general data and information. Instead, this information is needed to (1) deliver our website content correctly, (2) optimise our website content and its advertising, (3) ensure the long-term functionality of our information technology systems and website technology, and (4) provide law enforcement authorities with the information needed for prosecution in the event of a cyberattack. Miraval Hotel therefore analyses this anonymously collected data and information for statistical purposes and to improve data protection and data security within the company, ultimately ensuring the highest possible level of protection for the personal data we process. Anonymous server log data is stored separately from any personal data provided by a data subject.

5. Subscription to our newsletter

Users of the Miraval Hotel website have the opportunity to subscribe to our company's newsletter. The personal data transmitted to the controller when subscribing is determined by the input form used for this purpose.

Miraval Hotel regularly informs customers and business partners about company offers by newsletter. A data subject may generally receive our newsletter only if (1) they have a valid email address and (2) they have registered to receive the newsletter. For legal reasons, a confirmation email is sent to the email address entered for the first time using the double opt-in procedure. This confirmation email verifies that the owner of the email address has authorised receipt of the newsletter.

When a data subject registers for the newsletter, we also store the IP address assigned by the internet service provider (ISP) to the computer system used at registration, together with the date and time of registration. Collecting this information is necessary to trace possible misuse of the data subject's email address at a later date and therefore serves to protect the controller legally.

The personal data collected when registering for our newsletter is used exclusively for sending the newsletter. Newsletter subscribers may also be informed by email where this is necessary for operating the newsletter service or their registration, for example in the event of changes to the newsletter offering or technical circumstances. Personal data collected as part of the newsletter service is not passed on to third parties. Data subjects may cancel their subscription at any time and withdraw their consent to the storage of personal data provided for newsletter distribution at any time. Each newsletter contains a link for withdrawing consent. Users may also unsubscribe directly from the controller's website at any time or inform the controller by other means.

6. Newsletter tracking

The newsletters sent by Miraval Hotel contain tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log-file recording and analysis. This allows statistical evaluation of the success or failure of online marketing campaigns. Using the embedded tracking pixel, Miraval Hotel can identify whether and when a data subject opened an email and which links in that email were accessed.

Personal data collected through tracking pixels in newsletters is stored and evaluated by the controller to optimise newsletter distribution and better tailor future newsletter content to the interests of data subjects. This personal data is not shared with third parties. Data subjects may withdraw their separate consent given through the double opt-in process at any time. Following withdrawal, the controller deletes this personal data. Miraval Hotel automatically treats unsubscribing from the newsletter as withdrawal of consent.

7. Contact via the website

In accordance with statutory provisions, the Miraval Hotel website contains information that enables quick electronic contact and direct communication with our company, including a general email address. If a data subject contacts the controller by email or via a contact form, the personal data supplied by that person is automatically stored. Such personal data voluntarily provided to the controller is stored for the purpose of processing the enquiry or contacting the data subject. This personal data is not shared with third parties.

8. Routine deletion and blocking of personal data

The controller processes and stores personal data only for the period necessary to achieve the purpose of storage, or for as long as required by European or other applicable legislators in laws or regulations to which the controller is subject.

When the purpose of storage no longer applies, or a retention period prescribed by the European or another competent legislator expires, personal data is routinely blocked or deleted in accordance with legal requirements.

9. Rights of the data subject

• a)    Right to confirmation

  Every data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning them is being processed. A data subject wishing to exercise this right may contact an employee of the controller at any time. 
   

• b)    Right of access

  Every data subject has the right granted by the European legislator to obtain information from the controller, free of charge and at any time, about the personal data stored concerning them and to receive a copy of this information. The European legislator has also granted the data subject access to the following information:

  • the purposes of processing
  • the categories of personal data being processed
  • the recipients or categories of recipients to whom the personal data has been or will be disclosed, particularly recipients in third countries or international organisations
  • where possible, the envisaged period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
  • the existence of the right to request rectification or erasure of personal data, or restriction of processing by the controller, or to object to such processing
  • the right to lodge a complaint with a supervisory authority
  • where personal data is not collected from the data subject, any available information as to its source
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject

  The data subject also has the right to be informed whether personal data has been transferred to a third country or an international organisation. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

  A data subject wishing to exercise this right of access may contact an employee of the controller at any time. 
   

• c)    Right to rectification

  Every data subject has the right granted by the European legislator to obtain the rectification of inaccurate personal data concerning them without undue delay. Taking into account the purposes of processing, the data subject also has the right to have incomplete personal data completed, including by means of a supplementary statement.

  A data subject wishing to exercise this right to rectification may contact an employee of the controller at any time. 
   

• d)    Right to erasure (right to be forgotten)

  Every data subject has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies and processing is not necessary:

  • The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
  • The data subject withdraws consent on which processing is based under Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal basis for processing.
  • The data subject objects to processing under Article 21(1) GDPR and there are no overriding legitimate grounds for processing, or the data subject objects under Article 21(2) GDPR.
  • The personal data has been unlawfully processed.
  • The personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject.
  • The personal data was collected in relation to information society services offered pursuant to Article 8(1) GDPR.

  Where one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by Miraval Hotel, they may contact an employee of the controller at any time. The Miraval Hotel employee will arrange for the erasure request to be complied with without undue delay.

  Where Miraval Hotel has made personal data public and is obliged to erase it under Article 17(1) GDPR, Miraval Hotel, taking account of available technology and the cost of implementation, shall take reasonable measures, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure of any links to, or copies or replications of, that personal data, insofar as processing is not necessary. An employee of Miraval Hotel will take the necessary action in individual cases. 
   

• e)    Right to restriction of processing

  Every data subject has the right granted by the European legislator to obtain restriction of processing from the controller where one of the following conditions applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify its accuracy.
  • The processing is unlawful and the data subject opposes erasure of the personal data and requests restriction of its use instead.
  • The controller no longer needs the personal data for processing purposes, but the data subject requires it for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing under Article 21(1) GDPR pending verification of whether the controller’s legitimate grounds override those of the data subject.

  Where one of the above conditions applies and a data subject wishes to request the restriction of processing of personal data stored by Miraval Hotel, they may contact an employee of the controller at any time. The Miraval Hotel employee will arrange for processing to be restricted. 
   

• f)    Right to data portability

  Every data subject has the right granted by the European legislator to receive personal data concerning them which they have provided to a controller in a structured, commonly used and machine-readable format. They also have the right to transmit that data to another controller without hindrance from the controller to which the data was provided, where processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR, and is carried out by automated means, provided processing is not necessary for a task carried out in the public interest or in the exercise of official authority vested in the controller.

  When exercising the right to data portability under Article 20(1) GDPR, the data subject also has the right to have personal data transmitted directly from one controller to another where technically feasible and provided that the rights and freedoms of others are not adversely affected.

  A data subject may contact any employee of Miraval Hotel at any time to exercise the right to data portability. 
   

• g)    Right to object

  Every data subject has the right granted by the European legislator to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions.

  In the event of an objection, Miraval Hotel will no longer process the personal data unless we demonstrate compelling legitimate grounds for processing which override the interests, rights and freedoms of the data subject, or processing is necessary for the establishment, exercise or defence of legal claims.

  Where Miraval Hotel processes personal data for direct marketing, the data subject has the right to object at any time to processing for such marketing. This also applies to profiling to the extent that it is related to direct marketing. If the data subject objects to Miraval Hotel processing personal data for direct marketing, Miraval Hotel will no longer process that data for these purposes.

  In addition, the data subject has the right to object, on grounds relating to their particular situation, to processing by Miraval Hotel for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, unless processing is necessary for the performance of a task carried out for reasons of public interest.

  To exercise the right to object, the data subject may contact any employee of Miraval Hotel directly. In connection with the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may also exercise this right by automated means using technical specifications. 
   

• h)    Automated individual decision-making, including profiling

  Every data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into or performing a contract between the data subject and controller, (2) is authorised by Union or Member State law to which the controller is subject and which lays down suitable measures to safeguard the data subject's rights, freedoms and legitimate interests, or (3) is based on the data subject's explicit consent.

  Where the decision (1) is necessary for entering into or performing a contract between the data subject and controller, or (2) is based on the data subject's explicit consent, Miraval Hotel shall implement suitable measures to safeguard the data subject's rights, freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

  A data subject wishing to exercise rights relating to automated decision-making may contact an employee of the controller at any time. 
   

• i)    Right to withdraw consent under data protection law

  Every data subject has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

  A data subject wishing to exercise the right to withdraw consent may contact an employee of the controller at any time. 
   

10. Data protection provisions concerning the use of Facebook

The controller has integrated components of Facebook into this website. Facebook is a social network.

A social network is an online meeting place, an online community that generally enables users to communicate and interact with each other in a virtual environment. A social network can serve as a platform for exchanging views and experiences or allow the online community to provide personal or business-related information. Among other features, Facebook enables users to create personal profiles, upload photos and connect through friend requests.

Facebook is operated by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. Where a data subject lives outside the USA or Canada, the controller responsible for processing personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Whenever a page of this website operated by the controller and containing a Facebook component (Facebook plug-in) is accessed, the Facebook component automatically causes the internet browser on the data subject's information technology system to download a display of the corresponding component from Facebook. An overview of Facebook plug-ins is available at developers.facebook.com/docs/plugins/. During this technical process, Facebook learns which specific subpage of our website the data subject has visited.

If the data subject is logged into Facebook at the same time, Facebook recognises which specific subpage of our website the data subject visits whenever they access our website and throughout their visit. This information is collected by the Facebook component and assigned by Facebook to the data subject's Facebook account. If the data subject clicks a Facebook button integrated into our website, such as the “Like” button, or posts a comment, Facebook assigns this information to their personal Facebook account and stores the personal data.

Facebook receives information through the Facebook component that the data subject has visited our website whenever they are logged into Facebook at the time of visiting our website, irrespective of whether they click the Facebook component. If the data subject does not wish this information to be transmitted to Facebook, they can prevent this by logging out of their Facebook account before visiting our website.

Facebook's data policy, available at de-de.facebook.com/about/privacy/, provides information on how Facebook collects, processes and uses personal data. It also explains the settings available to protect the data subject's privacy. Various applications are also available that can prevent data from being transmitted to Facebook. Data subjects may use such applications to prevent transmission of data to Facebook.

11. Data protection provisions concerning the use of Google Analytics (with anonymisation function)

The controller has integrated Google Analytics (with anonymisation function) into this website. Google Analytics is a web analytics service. Web analytics involves collecting and evaluating data about the behaviour of website visitors. Among other things, a web analytics service records the website from which a data subject arrived (referrer), which subpages were accessed, and how frequently and for how long a subpage was viewed. Web analytics is primarily used to optimise websites and analyse the cost effectiveness of online advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The controller uses the addition “_gat._anonymizeIp” for web analytics via Google Analytics. By means of this addition, Google shortens and anonymises the IP address of the data subject's internet connection when our website is accessed from an EU Member State or another state party to the Agreement on the European Economic Area.

The purpose of Google Analytics is to analyse visitor traffic on our website. Google uses the data and information collected, among other things, to evaluate use of our website, compile online reports about website activity for us and provide other services relating to website use.

Google Analytics places a cookie on the data subject's information technology system. Cookies have already been explained above. The cookie enables Google to analyse how our website is used. Whenever a page of this website operated by the controller and containing a Google Analytics component is accessed, that component automatically causes the browser on the data subject's system to transmit data to Google for online analysis. During this technical process, Google obtains personal data such as the data subject's IP address, which Google uses, among other purposes, to trace the origin of visitors and clicks and subsequently enable commission settlements.

The cookie stores personal information such as the time of access, the location from which access originated and the frequency of visits by the data subject. Whenever our website is visited, this personal data, including the IP address of the data subject's internet connection, is transmitted to Google in the United States of America and stored there. Google may pass personal data collected by this technical process on to third parties.

As explained above, the data subject can prevent cookies from being set by our website at any time through the appropriate browser settings and thus permanently object to cookies. Such browser settings would also prevent Google from placing a cookie on the data subject's system. In addition, any cookie already set by Google Analytics can be deleted through the internet browser or other software at any time.

The data subject can also object to and prevent the collection of data generated by Google Analytics about use of this website and its processing by Google. To do so, the data subject must download and install the browser add-on at tools.google.com/dlpage/gaoptout. This add-on tells Google Analytics via JavaScript that no data or information about website visits may be transmitted to Google Analytics. Google regards the installation of the add-on as an objection. If the data subject's information technology system is later deleted, formatted or reinstalled, the add-on must be installed again to deactivate Google Analytics. If the data subject or another person under their control uninstalls or deactivates the add-on, it can be reinstalled or reactivated.

Further information and Google's applicable privacy provisions are available at www.google.de/intl/de/policies/privacy/ and www.google.com/analytics/terms/de.html. Google Analytics is described in more detail at www.google.com/intl/de_de/analytics/.

12. Data protection provisions concerning the use of Google Remarketing

The controller has integrated Google Remarketing services into this website. Google Remarketing is a Google AdWords feature that enables a company to display advertising to internet users who have previously visited the company's website. Integrating Google Remarketing therefore enables a company to create user-related advertising and show internet users advertisements relevant to their interests.

The operator of Google Remarketing is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Remarketing is to display interest-based advertising. Google Remarketing enables us to show advertisements through the Google advertising network or on other websites, tailored to the individual needs and interests of internet users.

Google Remarketing places a cookie on the data subject's information technology system. Cookies have already been explained above. The cookie enables Google to recognise visitors to our website when they subsequently visit other websites that are also members of the Google advertising network. Whenever a website incorporating Google Remarketing is accessed, the data subject's browser automatically identifies itself to Google. During this technical process, Google obtains personal data such as the user's IP address or browsing behaviour, which Google uses, among other things, to display interest-based advertising.

The cookie stores personal information, for example the websites visited by the data subject. Consequently, whenever our website is visited, personal data including the IP address of the data subject's internet connection is transmitted to Google in the United States of America and stored there. Google may pass on personal data collected through this technical process to third parties.

As explained above, the data subject can prevent the setting of cookies by our website at any time using the appropriate internet browser settings and permanently object to cookies. This would also prevent Google from setting a cookie on the data subject's system. Furthermore, a cookie already set by Google Analytics can be deleted at any time via an internet browser or other software.

The data subject may also object to interest-based advertising by Google. To do so, they must open www.google.de/settings/ads in each internet browser they use and select the desired settings.

Further information and Google's applicable privacy provisions are available at www.google.de/intl/de/policies/privacy/.

13. Data protection provisions concerning the use of Google AdWords

The controller has integrated Google AdWords into this website. Google AdWords is an online advertising service that enables advertisers to place ads both in Google search results and in the Google advertising network. It allows advertisers to define keywords in advance so that an ad appears in Google search results only when a user searches for a relevant keyword. In the Google advertising network, ads are distributed to relevant websites by an automated algorithm based on the predefined keywords.

Google AdWords is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google AdWords is to promote our website by showing interest-based advertising on third-party websites and in Google search results, and to display third-party advertising on our own website.

If a data subject reaches our website through a Google advertisement, Google places a so-called conversion cookie on the data subject's information technology system. Cookies have been explained above. A conversion cookie expires after thirty days and does not serve to identify the data subject. Provided the cookie has not expired, it can be used to determine whether certain subpages, such as the shopping cart of an online shop, have been visited on our website. The conversion cookie allows us and Google to determine whether a data subject arriving via an AdWords ad generated a sale, meaning whether they completed or abandoned a purchase.

Google uses the data and information collected through the conversion cookie to compile visit statistics for our website. We use these statistics to determine the total number of users referred to us through AdWords advertisements, evaluate the success or failure of individual ads and optimise future AdWords advertising. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, for example which websites the data subject has visited. Whenever our website is visited, personal data including the IP address of the data subject's internet connection is therefore transmitted to Google in the United States of America and stored there. Google may disclose the personal data collected through this technical process to third parties.

As explained above, the data subject may prevent our website from setting cookies at any time using the appropriate internet browser settings and thus permanently object to cookies. Such settings also prevent Google from setting a conversion cookie on the data subject's system. In addition, cookies already set by Google AdWords can be deleted at any time using the browser or other software.

The data subject may also object to interest-based advertising by Google. To do so, they must visit www.google.de/settings/ads from each internet browser they use and select the desired settings.

Further information and Google's applicable privacy provisions are available at www.google.de/intl/de/policies/privacy/.

14. Data protection provisions concerning the use of Instagram

The controller has integrated components of Instagram into this website. Instagram is an audiovisual platform that allows users to share photos and videos and redistribute that content on other social networks.

The operator of Instagram is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Whenever a page of this website operated by the controller and incorporating an Instagram component (Instagram button) is accessed, the component automatically causes the data subject's browser to download a display of the corresponding component from Instagram. During this process, Instagram learns which specific subpage of our website the data subject visits.

If the data subject is logged into Instagram at the same time, Instagram recognises which specific subpage of our website the data subject visits whenever they access our website and throughout their visit. This information is collected by the Instagram component and assigned to the data subject's Instagram account. If the data subject clicks an Instagram button integrated into our website, the transmitted data and information is assigned to their personal Instagram account and stored and processed by Instagram.

Instagram receives information through the Instagram component that the data subject has visited our website whenever they are logged into Instagram at the time of their visit, regardless of whether they click the Instagram component. If the data subject does not wish such information to be transmitted, they can prevent this by logging out of their Instagram account before visiting our website.

Further information and Instagram's applicable privacy provisions are available at help.instagram.com/155833707900388 and www.instagram.com/about/legal/privacy/.

15. Data protection provisions concerning the use of Pinterest

The controller has integrated components of Pinterest Inc. into this website. Pinterest is a social network. A social network is an online meeting place, an internet community that generally allows users to communicate and interact with each other virtually. It can serve as a platform for exchanging views and experiences or for sharing personal or business information. Pinterest allows users to publish collections of images, individual pictures and descriptions on virtual pinboards (known as pinning), which other users can then share (repin) or comment on.

Pinterest is operated by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

Whenever a page of this website operated by the controller and incorporating a Pinterest component (Pinterest plug-in) is accessed, the component automatically causes the data subject's browser to download a display of the corresponding component from Pinterest. Further information on Pinterest is available at pinterest.com. During this process, Pinterest learns which specific subpage of our website the data subject has visited.

If the data subject is logged into Pinterest at the same time, Pinterest recognises which specific subpage of our website the data subject visits whenever they access our website and throughout their visit. This information is collected by the Pinterest component and assigned to their Pinterest account. If the data subject clicks a Pinterest button integrated into our website, Pinterest assigns this information to their personal Pinterest account and stores the personal data.

Pinterest receives information through the Pinterest component that the data subject has visited our website whenever they are logged into Pinterest at the time of visiting the website, whether or not they click the component. If the data subject does not wish such information to be transmitted, they can prevent this by logging out of their Pinterest account before visiting our website.

Pinterest's privacy policy, available at about.pinterest.com/privacy-policy, provides information about its collection, processing and use of personal data.

16. Data protection provisions concerning the use of Matomo

The controller has integrated Matomo into this website. Matomo is an open-source web analytics tool. Web analytics involves collecting and evaluating data on visitor behaviour. Among other things, a web analytics tool records which website a data subject came from (referrer), which subpages were visited, and how often and for how long a subpage was viewed. Web analytics is primarily used to optimise websites and assess the cost effectiveness of internet advertising.

The software runs on the controller's server. The log files containing data sensitive under data protection law are stored exclusively on this server.

The purpose of Matomo is to analyse visitor traffic on our website. The controller uses the collected data and information, among other purposes, to evaluate website use and compile online reports showing activity on our website.

Matomo places a cookie on the data subject's information technology system. Cookies have been explained above. The cookie enables us to analyse website use. Whenever a page of our website is accessed, the Matomo component automatically causes the data subject's internet browser to transmit data to our server for online analysis. During this technical process, we obtain personal data such as the data subject's IP address, which helps us trace the origin of visitors and clicks.

The cookie stores personal information, for example the access time, the location from which access originated and the frequency of visits to our website. Each visit to our website results in this personal data, including the IP address of the data subject's internet connection, being transmitted to our server. We store this personal data and do not pass it on to third parties.

As explained above, the data subject can prevent the setting of cookies by our website at any time using the appropriate browser settings and thus permanently object to cookies. Such settings would also prevent Matomo from setting a cookie on the data subject's system. In addition, any cookie already set by Matomo can be deleted via an internet browser or other software at any time.

The data subject may also object to and prevent the collection of data generated by Matomo about their use of this website. To do so, the data subject must enable “Do Not Track” in their browser.

However, setting an opt-out cookie may mean that the controller's website can no longer be used in full.

Further information and Matomo's applicable privacy provisions are available at matomo.org/privacy/.

17. Data protection provisions concerning the use of Twitter

The controller has integrated Twitter components into this website. Twitter is a publicly accessible multilingual microblogging service on which users can publish and distribute short messages known as tweets, limited to 280 characters. These messages can be viewed by anyone, including people not registered with Twitter. Tweets are also displayed to the user's followers. Followers are other Twitter users who follow someone's tweets. Hashtags, links and retweets also allow users to reach a broad audience.

The operating company is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

Whenever a page of this website operated by the controller and incorporating a Twitter component (Twitter button) is accessed, the component automatically causes the data subject's browser to download the corresponding component from Twitter. Further information about Twitter buttons is available at about.twitter.com/de/resources/buttons. During this process, Twitter learns which subpage of our website the data subject visits. The purpose of integrating Twitter is to enable users to share our website content, increase its visibility online and attract more visitors.

If the data subject is logged into Twitter at the same time, Twitter recognises which specific subpage of our website the data subject visits whenever they access our website and throughout their visit. The Twitter component collects this information and assigns it to their Twitter account. If the data subject clicks a Twitter button integrated into our website, the transmitted information is assigned to their personal Twitter account and stored and processed by Twitter.

Twitter receives information through its component that the data subject has visited our website whenever they are logged into Twitter at the time of access, whether or not they click the Twitter component. If the data subject does not wish this information to be transmitted, they can prevent it by logging out of Twitter before visiting our website.

Twitter's applicable privacy policy is available at twitter.com/privacy.

18. Data protection provisions concerning the use of YouTube

The controller has integrated components of YouTube into this website. YouTube is an online video portal that allows video publishers to upload clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube enables all types of videos to be published, including full-length films and television programmes, music videos, trailers and user-generated videos.

YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

Whenever a page of this website operated by the controller and incorporating a YouTube component (YouTube video) is accessed, the component automatically causes the data subject's browser to download the corresponding YouTube component. Further information on YouTube is available at www.youtube.com/yt/about/de/. During this technical process, YouTube and Google learn which specific subpage of our website the data subject visits.

If the data subject is logged into YouTube at the same time, YouTube recognises which specific subpage of our website the data subject visits when they open a page containing a YouTube video. YouTube and Google collect this information and assign it to the data subject's YouTube account.

YouTube and Google receive information through the YouTube component that the data subject has visited our website whenever they are logged into YouTube at the time, whether or not they click a YouTube video. If the data subject does not wish this information to be transmitted, they can prevent it by logging out of YouTube before visiting our website.

YouTube's published privacy provisions, available at www.google.de/intl/de/policies/privacy/, provide information about how YouTube and Google collect, process and use personal data.

19. Legal basis for processing

Article 6(1)(a) GDPR provides the legal basis for processing operations for which our company obtains consent for a specific purpose. Where processing personal data is necessary to perform a contract to which the data subject is party, such as processing required for the delivery of goods or the provision of a service or consideration, processing is based on Article 6(1)(b) GDPR. The same applies to processing necessary to take steps before entering into a contract, for example in response to enquiries about our products or services. Where our company is subject to a legal obligation requiring personal data processing, such as fulfilling tax obligations, processing is based on Article 6(1)(c) GDPR. In rare cases, processing may be necessary to protect the vital interests of the data subject or another natural person. This could occur if a visitor were injured at our premises and their name, age, health insurance details or other vital information needed to be shared with a doctor, hospital or other third party. Processing would then be based on Article 6(1)(d) GDPR. Finally, processing may be based on Article 6(1)(f) GDPR. This basis applies to processing not covered by the preceding legal grounds where it is necessary for the legitimate interests of our company or a third party, provided the data subject's interests, fundamental rights and freedoms do not override those interests. The European legislator specifically mentioned this type of processing and considered that a legitimate interest might exist where the data subject is a customer of the controller (Recital 47, sentence 2, GDPR).

20. Legitimate interests pursued by the controller or a third party

Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business activities for the benefit of the well-being of all our employees and shareholders.

21. Period for which personal data is stored

The criterion for determining the storage period of personal data is the applicable statutory retention period. After this period expires, the corresponding data is routinely deleted, provided it is no longer needed to perform or initiate a contract.

22. Statutory or contractual requirements to provide personal data; necessity for entering into a contract; obligation to provide personal data; possible consequences of failure to provide it

We inform you that providing personal data may be required by law (for example, tax regulations) or may arise from contractual provisions (for example, information about a contractual partner). In some cases, it may be necessary for a data subject to provide personal data in order to enter into a contract with us, and we must subsequently process that data. For example, a data subject is obliged to provide personal data when our company enters into a contract with them. Failure to provide personal data would mean that the contract could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will explain in the individual case whether providing the personal data is required by law or contract, or necessary for entering into a contract, whether the data subject is obliged to provide it, and what the consequences of not providing it would be.

23. Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

Developed by the Legal Tech specialists at Willing & Able, who also developed the system for providing antitrust training. The texts of the privacy policy generator were written and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.