This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profile (hereinafter referred to as collectively referred to as “Online Offering”). With regard to the terms used, such as "processing" or "person responsible", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

RESPONSIBLE ENTITY, CONTACT ADDRESS

Responsible body in terms of data protection law is:

Conrad's Mountain Lodge AG, Via dal Farrer 1, 7513 Silvaplana, Switzerland.

E-mail: mail@cm-lodge.com

If you have any questions about this Statement or to exercise your rights, please contact Cindy Conrad directly.

TYPES OF DATA PROCESSED

• Inventory data (eg, names, addresses). 
• Contact information (e.g., email, phone numbers). 
• Content data (e.g. text input, components of the booking request). 
• Usage data (e.g. websites visited, interest in content, access times). 
• Meta/communication data (e.g. device information, IP addresses).

CATEGORIES OF PERSONS CONCERNED

Visitors and users of the online offer (in the following we refer to the persons concerned collectively as "users").

PURPOSE OF PROCESSING

Every time you interact with us (e.g. when you book a room through our website, by telephone or through a third party, when you post a comment on our blog or subscribe to our newsletter), we may collect the personal data you provide and process and use for the following:

• Provision of the online offer, its functions and content.

• Answering contact requests and communicating with users. 
• Safety measures. 
• Reach measurement/marketing

RELEVANT LEGAL BASES

In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 (1) lit. a and Art Answering inquiries is Article 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(c) GDPR 6 Paragraph 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 lit. d GDPR serves as the legal basis.

SAFETY MEASURES

In accordance with Art. 32 GDPR, we take appropriate technical measures, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons and organizational measures 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 access to the data, as well as access, input, transfer, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 GDPR).

COOPERATION WITH PROCESSOR AND THIRD PARTIES

If, as part of our processing, we disclose data to other people and companies (contract processors or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the data is transmitted to third parties, as to payment service providers, pursuant to Art. 6 Para. 1 lit. b GDPR is required for the fulfillment of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 DSGVO.

TRANSFERS TO THIRD COUNTRIES

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this happens as part of the use of third-party services or disclosure or transmission of data to third parties, this only takes place if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

RIGHTS OF DATA SUBJECTS

You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR. 

You have accordingly. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you. 

In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to demand that the processing of the data be restricted. 

You have the right to request that you receive the data that you have provided to us in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties. You also have the right, in accordance with Article 77 GDPR, to lodge a complaint with the competent supervisory authority.

RIGHT OF WITHDRAWAL

You have the right to revoke your consent in accordance with Article 7 (3) GDPR with effect for the future.

RIGHT TO OBJECT

You can object to the future processing of data relating to you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct advertising purposes.

COOKIES AND THE RIGHT TO OBJECT TO DIRECT ADVERTISING

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. "Permanent" or "persistent" refers to cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, we speak of "first-party cookies"). 

We can use temporary and permanent cookies and explain this in our data protection declaration. 

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer. 

A general objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US site https://www.aboutads.info/choices/ or the EU side https://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the browser settings. Please note that in this case not all functions of this online offer can be used.

DELETION OF DATA

The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage requirements. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.

CONTRACTUAL SERVICES

We process the data of our contractual partners and interested parties as well as other clients, guests or contractual partners (uniformly referred to as "contractual partners") in accordance with Article 6 Paragraph 1 lit. b. GDPR in order to provide you with our contractual or pre-contractual services. The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. 

The processed data includes the master data of our contractual partners (e.g. names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g. services used, contract content, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history). 

In principle, we do not process special categories of personal data, unless these are part of commissioned or contractual processing. 

We process data that is required to justify and fulfill the contractual services and point out the need to provide them if this is not evident to the contractual partner. Disclosure to external persons or companies will only take place if it is required under a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements. 

When using our online services, we can save the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the interests of the user in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties unless it is necessary to pursue our claims in accordance with Article 6 Paragraph 1 lit. f GDPR or there is a legal obligation to do so in accordance with Article 6 Paragraph 1 lit.c. GDPR. 

The data will be deleted if the data is no longer required to fulfill contractual or legal duties of care or to deal with any warranty and comparable obligations, with the necessity of storing the data being checked every three years; Otherwise, the statutory retention requirements apply.

ADMINISTRATION, FINANCIAL ACCOUNTING, OFFICE ORGANIZATION, CONTACT MANAGEMENT

We process data as part of administrative tasks and the organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process within the scope of providing our contractual services. The basis of processing is Art. 6 Para. 1 lit. c. GDPR, Art. 6 Para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information given in these processing activities. 

We disclose or transmit data to the financial administration, consultants such as tax consultants or auditors as well as other fee offices and payment service providers. 

Furthermore, on the basis of our business interests, we store information on suppliers, organizers and other business partners, e.g. for the purpose of later contact. We store this mostly company-related data permanently.

BUSINESS ANALYZES AND MARKET RESEARCH

In order to operate our business economically, to be able to recognize market trends, the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art 6 Paragraph 1 lit. f GDPR, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online offer. The analyzes are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of the registered users with information, e.g. on the services they have used. The analyzes serve us to increase the user-friendliness, the optimization of our offer and the economic efficiency. 

The analyzes serve us alone and are not disclosed externally, unless they are anonymous analyzes with summarized values. 

If these analyzes or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyzes and general trend determinations are created anonymously if possible.

CONTACT

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user is used to process the contact request and to process it in accordance with Article 6 (1) b. (in the context of contractual/pre-contractual relationships), Art. 6 (1) lit. f. (other inquiries) GDPR processed get saved. 

We delete the requests if they are no longer necessary. We review necessity every two years; Furthermore, the statutory archiving obligations apply.

NEWSLETTER

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to receive it and the procedures described. 

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. Our newsletter also contains information about our services and us. 

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else's e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged. 

Registration data: In order to register for the newsletter, it is sufficient if you enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter. 

The sending of the newsletter and the success measurement associated with it are based on the consent of the recipient in accordance with Article 6 Paragraph 1 Letter a, Article 7 GDPR in conjunction with Section 7 Paragraph 2 No. 3 UWG or if consent is not required , on the basis of our legitimate interests in direct marketing in accordance with Article 6 Paragraph 1 of the GDPR in conjunction with Article 7 Paragraph 3 of the UWG. 

The registration process is logged on the basis of our legitimate interests in accordance with Article 6 (1) (f) GDPR. Our interest is focused on the use of a user-friendly and secure newsletter system that serves our business interests as well as meets user expectations and also allows us to prove consent. 

Termination/Revocation – You can terminate the receipt of our newsletter at any time, ie revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We can store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.

NEWSLETTER - MAILCHIMP

The newsletter is sent using the mail service provider Mailchimp. You can view the data protection regulations of the shipping service provider here: https://mailchimp.com/legal/privacy/ The shipping service provider is used on the basis of our legitimate interests in accordance with Article 6 Paragraph 1 lit. f GDPR and an order processing contract in accordance with Article 28 Paragraph 3 Clause 1 GDPR. 

The shipping service provider can use the data of the recipients in pseudonymous form, ie without assignment to a user, to optimize or improve their own services, e.g. for technical optimization of the dispatch and the presentation of the newsletter or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to write to them themselves or to pass the data on to third parties.

NEWSLETTER – SUCCESS MEASUREMENT

The newsletters contain a so-called "web beacon", ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, are initially collected. 

This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider to monitor individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. 

Unfortunately, it is not possible to revoke the success measurement separately. In this case, the entire newsletter subscription must be cancelled.

GOOGLE ANALYTICS

On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO) we use Google Analytics, a web analysis service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and internet usage. Pseudonymous user profiles can be created from the processed data. 

We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. 

The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; In addition, users can prevent the data generated by the cookie and related to their use of the online offer being collected by Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de. 

You can find more information on data use by Google, setting and objection options in Google's data protection declaration https://policies.google.com/technologies/ads as well as in the settings for the display of advertisements by Google https://adssettings.google.com/authenticated 

The personal data of the users will be deleted or made anonymous after 14 months.

ONLINE PRESENCE IN SOCIAL MEDIA

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to be able to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply. 

Unless otherwise stated in our data protection declaration, we process user data if they communicate with us within social networks and platforms, e.g. write posts on our online presence or send us messages.

INCORPORATION OF THIRD PARTY SERVICES AND CONTENT

Within our online offer, based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR), we set content or service offers from third-party providers to integrate their content and services, such as videos or fonts (hereinafter referred to as "content"). 

This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, visiting times and other information on the use of our online offer, as well as being linked to such information from other sources.

If you do not want Facebook to be able to associate your visit to our site with your Facebook user account, please log out of your Facebook user account.

FACEBOOK

Plugins from the social network Facebook, provider Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA, are integrated on our website. You can recognize the Facebook plugins by the Facebook logo or the “Like button” (“I like”) on our site. An overview of the Facebook plugins can be found here: https://developers.facebook.com/docs/plugins/. When you visit our pages, a direct connection is established between your browser and the Facebook server via the plugin. Facebook receives the information that you have visited our site with your IP address. If you click the Facebook "Like" button while you are logged into your Facebook account, you can link the content of our pages to your Facebook profile. This allows Facebook to associate your visit to our site with your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the data transmitted or how it is used by Facebook. You can find more information on this in Facebook's privacy policy at https://de-de.facebook.com/policy.php.

INSTAGRAM

Functions of the Instagram service are integrated on our website. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram account, you can click the Instagram button to link the content of our pages to your Instagram profile. This allows Instagram to associate your visit to our site with your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or how it is used by Instagram. For more information, see Instagram's privacy policy: https://instagram.com/about/legal/privacy/

YOUTUBE

We have included a link to our YouTube channel on our website. The videos are stored on https://www.YouTube.com, operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. Your personal data will only be transmitted to YouTube if you play the videos. We have no influence on this data transmission. More information on the processing of personal data can be found in YouTube's data protection declaration, which is available at: https://www.google.com/intl/en/policies/privacy/

GOOGLE FONTS

External fonts, Google Fonts, are used on this website. Google Fonts is a service provided by Google Inc. ("Google"). These web fonts are integrated by calling a server, usually a Google server in the USA. This transmits to the server which of our Internet pages you have visited. The IP address of the browser of the end device of the visitor to this website is also stored by Google. For more information, see Google's privacy policy, which you can access here: https://www.google.com/fonts https://www.google.com/policies/privacy

SAFETY

For security reasons and to protect the transmission of confidential content, such as the inquiries you send to us as the site operator, this site uses SSL encryption. 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.

All of our employees who may come into contact with personal data are obliged to maintain confidentiality and comply with data protection regulations and have been instructed about the legal requirements.

PRIVACY UPDATE

Conrad's Mountain Lodge AG reserves the right to update this data protection declaration if necessary to adapt it to technical developments or in connection with the offer of new services or products. 

Silvaplana, November 2022