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Data protection

Contents overview

Preamble

With the following data protection declaration we would like to explain to you which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). The terms used are not gender specific. Status: January 14, 2021

Responsible person

European Hotel & Consulting Group, S.L. Norbert Remer Carrer del Mar 2, 1C 07400 Puerto de Alcudia Balearen / Spanien Authorized representatives: Val Rangaraju E-Mail-Address: info@ehc-g.com Imprint: https://ehc-g.com/en/imprint/

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. Names, Addresses).
  • Content data (E.g. entries in online forms).
  • Kontaktdaten (e.g. e-mail, telephone numbers).
  • Meta / communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).

Categories of data subjects

  • Communication partner.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Contact requests and communication.

Relevant legal bases

In the following we share the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements in your or our country of residence and domicile may apply. If more specific legal bases are relevant in individual cases, we will inform you of this in the data protection declaration.
  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has given their consent to the processing of their personal data for a specific purpose or for several specific purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – The processing is necessary for the fulfillment of a contract to which the data subject is a party, or for the implementation of pre-contractual measures that take place at the request of the data subject.
  • Legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR) – The processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, outweigh this.

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk. The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, ensuring availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Transmission and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or they are disclosed to them. The recipients of this data can include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

Insofar as we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing in the context of the use of third-party services or the disclosure or transfer of data to other persons, offices or companies takes place, this is only done in accordance with the legal requirements. Subject to express consent or contractually or legally required transmission, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en ).

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored on the user’s computer by a browser. A cookie is primarily used to store information about a user during or after their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also known as “user IDs”) A distinction is made between the following types of cookies and functions:
  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent Cookies: Permanent cookies are saved even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users who are used to measure reach or for marketing purposes can also be stored in such a cookie.
  • First-Party-Cookies: First-party cookies are set by ourselves.
  • Third-Party-Cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) Cookies: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
  • Statistics, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when the interests of a user or his behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used to show users, for example, content that corresponds to their potential interests. This process is also known as “tracking”, i.e. tracking the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations. Storage period: If we do not provide you with any explicit information on the storage duration of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage duration can be up to two years. General information on revocation and objection (Opt-Out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies (collectively referred to as “opt-out”). You can first explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which can also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used. Processing of cookie data on the basis of consent: We use a procedure for cookie consent management, in the context of which the consent of the user to the use of cookies or the processing and provider mentioned in the context of the cookie consent management procedure is obtained and managed and revoked by the users can be. The declaration of consent is saved so that you do not have to repeat the query again and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and / or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or his device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of the consent (e.g. which categories of cookies and / or service providers) as well as the browser, system and end device used.
  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Par. 1 S. 1 lit.f. GDPR).

Provision of the online offer and web hosting

In order to be able to provide our online offer safely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we can use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services. The data processed as part of the provision of the hosting offer can include all information relating to the users of our online offer that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites. Email sending and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data can also be processed for the purpose of detecting SPAM. Please note that emails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted on the transport route, but (if no so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and receipt on our server. Collection of access data and log files: We ourselves (or our web hosting provider) collect data every time the server is accessed (so-called server log files). The server log files can include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong. The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the load on the server and its stability.
  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR).

Contact

When you contact us (e.g. via the contact form, email, phone or via social media), the details of the inquiring person are processed, insofar as this is necessary to answer the contact inquiries and any requested measures. The answering of contact inquiries in the context of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre) contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.
  • Types of data processed: Inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Affected people: Communication partner.
  • Purposes of processing: Contact requests and communication.
  • Legal bases: Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent permitted for processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data is no longer applicable or is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. Further information on the deletion of personal data can also be found in the individual data protection information of this data protection declaration.

Change and update of the data protection declaration

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification. If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses may change over time and ask you to check the information before contacting us.

Definitions of terms

This section gives you an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and primarily defined in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.
  • Personal data: “Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”); A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
  • Responsible person: “Responsible” means the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is any process carried out with or without the aid of automated processes or any such series of processes in connection with personal data. The term goes far and includes practically every handling of data, be it the collection, the evaluation, the storage, the transmission or the deletion.
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