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PRIVACY POLICY

Status: September 2018

Hotel Kemmeriboden-Bad AG, Kemmeribodenbad 181, CH-6197 Schangnau is the operator of the website www.kemmeriboden.ch and is therefore responsible for the collection, processing and use of your personal data and for ensuring that data processing complies with applicable data protection legislation.
Your trust is important to us, which is why we take the issue of data protection seriously and ensure appropriate security. It goes without saying that we comply with the legal provisions of the Federal Data Protection Act (FADP), the Ordinance to the Federal Data Protection Act (FADP), the Telecommunications Act (TCA) and other applicable data protection provisions of Swiss or EU law, in particular the General Data Protection Regulation (GDPR).
In order for you to know what personal data we collect from you and for what purposes we use it, please take note of the information below.

A.     Data processing in connection with our

Website
1. calling up our website


When you visit our website, our servers temporarily store each access in a log file. The following technical data are recorded without your intervention, as is generally the case with every connection to a web server, and stored by us until automated deletion after 6 months at the latest:
- the IP address of the requesting computer,
- the name of the owner of the IP address range (usually your Internet access provider),
- the date and time of the access,
- the website from which the access was made (referrer URL), if applicable with the search word used,
- the name and URL of the file accessed,
- the status code (e.g. error message),
- the operating system of your computer
- the browser you are using (type, version and language),
- the transmission protocol used (e.g. HTTP/1.1) and
- if applicable, your user name from a registration/authentication.
The collection and processing of this data is done for the purpose of enabling the use of our website (connection establishment), to ensure system security and stability on a permanent basis and to enable the optimization of our Internet offering as well as for internal statistical purposes. This is our legitimate interest in data processing within the meaning of Art. 6 Para. 1 lit. f DSGVO.
Furthermore, the IP address is evaluated together with the other data in the event of attacks on the network infrastructure or other unauthorized or abusive website use for the purpose of clarification and defense and, if necessary, used in the context of criminal proceedings for identification and civil and criminal action against the users concerned. This is our legitimate interest in data processing within the meaning of Art. 6 (1) lit. f DSGVO.

2. use of our contact form

You have the option of using a contact form to get in touch with us. For this, we require the following mandatory information:
- First and last name
- e-mail address
- message

We use this data as well as a telephone number voluntarily provided by you only to be able to answer your contact request in the best possible and personalized way. The processing of this data is therefore necessary within the meaning of Art. 6 Para. 1 lit. b DSGVO for the implementation of pre-contractual measures or is in our legitimate interest pursuant to Art. 6 Para. 1 lit. f DSGVO.

3. subscribe to our newsletter

On our website you have the possibility to subscribe to our newsletter. For this purpose, registration is required. The following data must be provided as part of the registration process:
- E-mail address

The above data is necessary for data processing. In addition, you can voluntarily provide further data (first and last name). We process this data exclusively in order to personalize the information and offers sent to you and to better align them to your interests.
By registering, you give us your consent to process the data provided for the regular dispatch of the newsletter to the address you have provided and for the statistical evaluation of user behavior and the optimization of the newsletter. This consent constitutes our legal basis for the processing of your e-mail address within the meaning of Art. 6 (1) lit. a DSGVO. We are entitled to commission third parties with the technical processing of advertising measures and are entitled to pass on your data for this purpose (cf. section 13 below).
At the end of each newsletter you will find a link that allows you to unsubscribe from the newsletter at any time. As part of the unsubscribe process, you can voluntarily inform us of the reason for unsubscribing. After unsubscribing, your personal data will be deleted. Further processing only takes place in anonymized form for the optimization of our newsletter.

4. opening of a customer account

To make bookings on our website, you can order as a guest or open a customer account. When registering for a customer account, we compulsorily collect the following data:

- Salutation
- First and last name
- postal address
- Date of birth
- Telephone number
- E-mail address
- Your password

The collection of these and other data voluntarily provided by you (e.g. company name) is for the purpose of providing you with password-protected direct access to your basic data stored with us. You can view your previous and current bookings or manage or change your personal data. The legal basis for processing the data for this purpose lies in the consent given by you in accordance with Art. 6 (1) lit. a DSGVO.

5. booking on the website, by correspondence or by telephone call.

If you make bookings either through our website, by correspondence (email or letter-post) or by telephone call, we require the following data mandatory for the processing of the contract: - Salutation - first and last name - postal address - date of birth - telephone number - Language - Credit card information - e-mail address These data as well as other information voluntarily provided by you (e.g. expected arrival time, motor vehicle registration plate, preferences, remarks) will only be used by us to process the contract, unless otherwise stated in this privacy policy or you have given your separate consent to do so. We will process the data by name in order to record your booking as requested, to provide the services booked, to contact you in the event of ambiguities or problems and to ensure correct payment. The legal basis of data processing for this purpose is the fulfillment of a contract according to Art. 6 para. 1 lit. b DSGVO.

6. Cookies

Cookies help in many aspects to make your visit to our website easier, more pleasant and more meaningful. Cookies are information files that your web browser automatically stores on your computer's hard drive when you visit our website. We use cookies, for example, to temporarily store your selected services and entries when you fill out a form on the website, so that you do not have to repeat the entry when you call up another sub-page. Cookies may also be used to identify you as a registered user after you have registered on the website, without you having to log in again when you call up another sub-page. Most Internet browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears when you receive a new cookie. On the following pages you will find explanations of how to configure the processing of cookies in the most popular browsers: - Microsoft's Windows Internet Explorer - Microsoft's Windows Internet Explorer Mobile - Mozilla Firefox - Google Chrome for Desktop - Google Chrome for Mobile - Apple Safari for Desktop - Apple Safari for Mobile Disabling cookies may prevent you from using all the features of our website.

7. tracking tools
a.    General


For the purpose of demand-oriented design and continuous optimization of our website, we use the web analysis service of Google Analytics. In this context, pseudonymized usage profiles are created and small text files that are stored on your computer ("cookies") are used. The information generated by the cookie about your use of this website is transmitted to the servers of the providers of these services, stored there and processed for us. In addition to the data listed under item 1, we may thereby receive the following information:
- Navigation path taken by a visitor to the site,
- the length of time spent on the website or sub-page,
- the sub-page on which the website is left,
- the country, region or city from which access is made,
- terminal device (type, version, color depth, resolution, width and height of the browser window), and
- Returning or new visitor.
The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to website and internet use for the purposes of market research and demand-oriented design of this website. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf.

b.    Google Analytics

The provider of Google Analytics is Google Inc, a company of the holding company Alphabet Inc, based in the USA. Before the data is transmitted to the provider, the IP address is truncated by activating IP anonymization ("anonymizeIP") on this website within the Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. The anonymized IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. In these cases, we ensure through contractual guarantees that Google Inc. maintains a sufficient level of data protection. According to Google Inc., in no case will the IP address be associated with other data concerning the user.

For more information about the web analytics service used, please visit the Google Analytics website. Instructions on how to prevent the processing of your data by the web analysis service can be found at tools.google.com/dlpage/gaoptout.

B. Data processing in connection with your stay

8. data processing for the fulfillment of legal reporting obligations.

Upon arrival at our hotel, we may require the following information from you and your companions:

- First and last name
- Postal address and canton
- Date of birth
- Place of birth
- Nationality
- Official identification card and number
- Arrival and departure date
- Room number

We collect this information in order to fulfill legal reporting obligations, which arise in particular from hospitality or police law. Insofar as we are obligated to do so under the applicable regulations, we forward this information to the responsible police authority.
Our legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO lies in the fulfillment of the legal requirements.

9. recording of services received

If you obtain additional services during your stay (e.g. make use of the mini-bar or the pay-TV offer), we will record the subject of the service and the time at which it was obtained for billing purposes. The processing of this data is necessary in the sense of Art. 6 para. 1 lit. b DSGVO for the processing of the contract with us.

C.     Storage and exchange of data with third parties

10. Booking platforms

If you make bookings via a third-party platform, we receive various personal information from the respective platform operator. As a rule, this is the data listed in Section 5 of these data protection declarations. In addition, inquiries about your booking may be forwarded to us. We will process this data by name in order to record your booking as requested and to provide the booked services. The legal basis of data processing for this purpose is the fulfillment of a contract according to Art. 6 para. 1 lit. b DSGVO.
Finally, we may be informed by the platform operators about disputes in connection with a booking. In the process, we may also receive data about the booking process, which may include a copy of the booking confirmation as proof of the actual booking completion. We process this data to protect and enforce our claims. This is our legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
Furthermore, please note the information on data protection of the respective provider.

11. central storage and linking of data

We store the data specified in items 2-5 and 8-10 in a central electronic data processing system. The data concerning you will be systematically recorded and linked for the purpose of processing your bookings and handling the contractual services. For this purpose we use software from Oracle, Switzerland. We base the processing of this data within the framework of the software on our legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO in customer-friendly and efficient customer data management.

12. retention period

We store personal data only as long as it is necessary to use the tracking services mentioned above as well as the further processing within the scope of our legitimate interest. Contractual data is stored by us for a longer period of time, as this is required by legal retention obligations. Retention obligations, which oblige us to retain data, result from regulations on registration law, on accounting and from tax law. According to these regulations, business communication, concluded contracts and accounting documents must be stored for up to 10 years. As far as we do not need these data any more for the execution of the services for you, the data are blocked. This means that the data may then only be used for accounting and tax purposes.

13. passing on of data to third parties

We will only pass on your personal data if you have expressly consented to this, if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship. In addition, we disclose your data to third parties to the extent necessary in the context of the use of the website and the execution of contracts (including outside the website), namely the processing of your bookings.
A service provider to whom the personal data collected via the website is transferred or who has or may have access to it is our web host YOUHEY Communication AG. The website is hosted on servers in Switzerland. The data is passed on for the purpose of providing and maintaining the functionalities of our website. This is our legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
Finally, when you pay by credit card on the website, we forward your credit card information to your credit card issuer and to the credit card acquirer. If you decide to pay by credit card, you will be asked to enter all mandatory information. The legal basis for the transfer of data is the fulfillment of a contract according to Art. 6 para. 1 lit. b DSGVO. Regarding the processing of your credit card information by these third parties, we ask you to also read the terms and conditions as well as the privacy policy of your credit card issuer.
Please also note the information in sections 7-8 and 10-11 regarding the transfer of data to third parties.

14. transfer of personal data abroad

We are entitled to transfer your personal data for the purpose of the data processing described in this data protection statement also to third companies (contracted service providers) abroad. These are obligated to data protection to the same extent as we ourselves. If the level of data protection in a country does not correspond to that in Switzerland or the EU, we will ensure by contract that the protection of your personal data corresponds to that in Switzerland or the EU at all times.

D.     Further information

15. right to information, correction, deletion and restriction of processing; right to data portability

You have the right to request information about the personal data that is stored by us about you. In addition, you have the right to have incorrect data corrected and the right to have your personal data deleted, insofar as this does not conflict with a legal obligation to retain the data or with an authorization that allows us to process the data.

You also have the right to demand that we return the data you have provided to us (right to data portability). Upon request, we will also transfer the data to a third party of your choice. You have the right to receive the data in a common file format.

You can contact us for the aforementioned purposes via the e-mail address inverniz-zi@kemmeriboden.ch. For the processing of your requests, we may, at our discretion, require proof of identity.

16. data security

We use appropriate technical and organizational security measures to protect your personal data stored by us against manipulation, partial or complete loss and against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

You should always treat your access data confidentially and close the browser window when you have finished communicating with us, especially if you share a computer with others.

We also take internal company data protection very seriously. Our employees and the service companies commissioned by us have been obligated by us to maintain confidentiality and to comply with the provisions of data protection law.

17. note on data transfers to the USA

For the sake of completeness, we would like to point out for users resident or domiciled in Switzerland that in the USA there are monitoring measures by US authorities which generally allow the storage of all personal data of all persons whose data has been transferred from Switzerland to the USA. This is done without any differentiation, limitation or exception based on the objective pursued and without any objective criterion that would make it possible to limit the access of the U.S. authorities to the data and their subsequent use to very specific, strictly limited purposes that are capable of justifying the intrusion associated both with the access to these data and with their use. Furthermore, we would like to point out that in the U.S. there are no legal remedies available to data subjects from Switzerland that would allow them to gain access to the data concerning them and to obtain its correction or deletion, or that there is no effective judicial legal protection against general access rights of U.S. authorities. We explicitly draw the attention of the data subject to this legal and factual situation so that he or she can make an appropriately informed decision to consent to the use of his or her data.

We would like to point out to users residing in a member state of the EU that, from the perspective of the European Union, the USA does not have a sufficient level of data protection - among other things due to the issues mentioned in this section. Insofar as we have explained in this Privacy Policy that recipients of data (such as Google) are based in the USA, we will ensure either through contractual arrangements with these companies or by ensuring that these companies are certified under the EU or Swiss-US Privacy Shield that your data is protected at an appropriate level with our partners.

18. right to complain to a data protection supervisory authority

You have the right to complain to a data protection supervisory authority at any time.

Status: September 15, 2018