Privacy policy
This privacy policy explains the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the associated websites, functions, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”). With regard to the terms used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible person
Hotel Schloß Gehrden GmbH
Schlossstraße 6, 33034 Brakel-Gehrden
Phone: +4905648/96320-0
Fax: +4905648/96320-256
info@schloss-gehrden.de
Managin director: Nassime Tullius-Pour
HRB 17235
Amtsgericht Paderborn
USt-IdNr.:DE369189054
Bank details:
Vereinigte Volksbank
IBAN: DE12 4726 4367 6009 5742 00
BIC: GENODEM1STM
Types of data processed:
– Inventory data (e.g., names, addresses).
– Contact data (e.g., email, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter we refer to the data subjects collectively as “users”).
Purpose of processing
– Provision of the online service, its functions, and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing
Terms used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually all data handling.
‘Pseudonymisation’ means the processing of personal data in such a manner 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 to ensure that the personal data are not attributed to an identified or identifiable natural person.
“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 natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis for our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR, the legal basis for processing to fulfill our services and implement contractual measures as well as to answer inquiries is Art. 6 (1) (b) GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 (1) (c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 (1) (f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.
Security measures
In accordance with Art. 32 GDPR, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and response to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes, in accordance with the principle of data protection by design and through data protection-friendly default settings (Article 25 GDPR).
Cooperation with processors and third parties
If, as part of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if transmission of the data to third parties, such as payment service providers, is necessary to fulfil the contract in accordance with Art. 6 (1) (b) GDPR), 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 agreement”, this is done on the basis of Art. 28 GDPR.
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 if this occurs as part of the use of third-party services or the disclosure or transmission of data to third parties, this will only occur if it is necessary to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or have data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level equivalent 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.
According to Art. 16 GDPR, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
In accordance with Art. 17 GDPR, you have the right to request that the data in question be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with Art. 18 GDPR.
You have the right to request that we receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties.
Furthermore, pursuant to Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.
Rights of withdrawal
You have the right to revoke consent given in accordance with Art. 7 (3) GDPR with effect for the future
Rights of objection
You may object to the future processing of your data at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for direct marketing purposes.
Cookies and right to object to direct advertising
“Cookies” are small files that are stored on users’ computers. Different types of information can be stored within cookies. A cookie is primarily used to save information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online service and closes their browser. Such a cookie can store, for example, the contents of a shopping cart in an online shop or a login status. “Permanent” or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if the user visits the website several days later. Likewise, the interests of the user can be saved in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and explain this in our privacy policy.
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser’s system settings. Stored cookies can be deleted in the browser’s system settings. Excluding cookies may result in functional limitations of this online service.
A general objection to the use of cookies used for online marketing purposes can be declared for a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/
Deletion of data
The data we process will be deleted or restricted in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention periods that prevent deletion. If the data is not deleted because it is required for other 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 law reasons.
According to legal requirements in Germany, storage takes place in particular for 10 years in accordance with Sections 147 Para. 1 AO, 257 Para. 1 Nos. 1 and 4, Para. 4 HGB (books, records, management reports, accounting documents, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with Section 257 Para. 1 Nos. 2 and 3, Para. 4 HGB (commercial letters).
According to legal requirements in Austria, storage takes place in particular for 7 years in accordance with Section 132 Paragraph 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statements of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services that are provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop (MOSS) is used.
Business-related processing
In addition, we process
– contract data (e.g., subject matter of the contract, term, customer category)
– payment data (e.g., bank details, payment history)
from our customers, prospective customers, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.
External payment service providers
We use external payment service providers through whose platforms users and we can carry out payment transactions (e.g., each with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)
To fulfill contracts, we use payment service providers on the basis of Art. 6 (1) (b) GDPR. Furthermore, we use external payment service providers based on our legitimate interests pursuant to Art. 6 (1) (f) GDPR to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, amount and recipient-related information. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, only information confirming or rejecting the payment. Under certain circumstances, the payment service providers will transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and data protection information of the payment service providers.
Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.
Administration, financial accounting, office organization, contact management
We process data as part of administrative tasks and to organize our operations, financial accounting, and to comply with legal obligations, such as archiving. In doing so, we process the same data that we process as part of providing our contractual services. The processing is based on Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Customers, interested parties, business partners, and website visitors are affected by the processing. The purpose of and our interest in the processing lies in administration, financial accounting, office organization, and data archiving—i.e., tasks that serve to maintain our business activities, perform our duties, and provide our services. The deletion of data for contractual services and contractual communication corresponds to the information provided for these processing activities.
We disclose or transmit data to the tax authorities, consultants such as tax consultants or auditors as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, event organizers, and other business partners, e.g., for the purpose of later contact. We generally store this mostly company-related data permanently.
Business analysis and market research
In order to operate our business economically and to identify market trends and the wishes of our contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data and metadata on the basis of Art. 6 (1) (f) GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offering.
The analyses are conducted for the purposes of business evaluations, marketing, and market research. We may consider the profiles of registered users with information, for example, about the services they have used. The analyses help us increase user-friendliness, optimize our offerings, and improve business efficiency. The analyses serve our sole purpose and will not be disclosed externally unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they will be deleted or anonymized upon user termination, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general trend determinations are created anonymously wherever possible.
Booking.com affiliate program
Based on our legitimate interests (i.e., interest in the economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we participate in the Booking.com affiliate program, which was designed to provide a medium for websites through which advertising costs can be earned by placing advertisements and links to Booking.com (a so-called affiliate system). Booking.com uses cookies to track the origin of bookings. Among other things, Booking.com can recognize that you clicked the affiliate link on this website and subsequently made a booking with Booking.com.
Further information on data usage by Booking.com and options for objection can be found in the company’s privacy policy: https://www.booking.com/content/privacy.de.html .
Registration function
Users can create a user account. During registration, the required mandatory information is communicated to users and processed on the basis of Art. 6 (1) (b) GDPR for the purpose of providing the user account. The data processed includes, in particular, login information (name, password, and an email address). The data entered during registration is used for the purposes of using the user account and its purpose.
Users can be informed via email about information relevant to their user account, such as technical changes. If users terminate their user account, their data related to the user account will be deleted, subject to any statutory retention requirements. It is the user’s responsibility to back up their data before the end of the contract upon termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
When you use our registration and login functions, as well as your user account, we store your IP address and the time of each user action. This storage is based on our legitimate interests, as well as the user’s interest in protecting against misuse and other unauthorized use. This data will generally not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 (1) (c) GDPR. IP addresses are anonymized or deleted after 7 days at the latest.
Contact us
When you contact us (e.g. via contact form, email, telephone or via social media), the user’s information will be processed to process the contact request and its handling in accordance with Art. 6 (1) (b) (within the framework of contractual/pre-contractual relationships) and Art. 6 (1) (f) (other inquiries) GDPR. User information may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete requests if they are no longer required. We review their necessity every two years; furthermore, statutory archiving obligations apply.
Newsletter
The following information provides you with information about the content of our newsletter, the registration, dispatch, and statistical evaluation procedures, as well as your right to object. By subscribing to our newsletter, you agree to receive it and to the described procedures.
Newsletter content: We only send newsletters, emails, and other electronic notifications containing promotional information (hereinafter “newsletters”) with the recipient’s consent or legal permission. If the newsletter content is specifically described when registering for the newsletter, this information is decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter is done using a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else’s email address. Newsletter registrations are logged to provide evidence of the registration process in accordance with legal requirements. This includes saving 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: To subscribe to the newsletter, simply provide your email address. Optionally, we ask you to provide a name so we can address you personally in the newsletter.
The newsletter is sent and the associated performance measurement is based on the recipient’s consent in accordance with Art. 6 (1) (a), Art. 7 GDPR in conjunction with Section 7 (2) No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 (1) (f) GDPR in conjunction with Section 7 (3) UWG.
The registration process is logged based on our legitimate interests pursuant to Art. 6 (1) (f) GDPR. Our interest is in using a user-friendly and secure newsletter system that serves our business interests and meets user expectations, while also allowing us to verify consent.
Cancellation/Revocation – You can cancel your subscription to our newsletter at any time, i.e., revoke your consent. A link to unsubscribe from the newsletter can be found at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove that consent was previously given. 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.
Hosting and email sending
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services and technical maintenance services, which we use for the purpose of operating this online offering.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of a contract for data processing).
Collection of access data and log files
Based on our legitimate interests pursuant to Art. 6 (1) (f) GDPR, we, or rather our hosting provider, collect data about every access to the server on which this service is located (so-called server log files). This access data includes the name of the accessed website, the file, the date and time of access, the amount of data transferred, the notification of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), the IP address, and the requesting provider.
Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.
WordPress analysis Plugin WP Statistics
This website uses the WordPress analytics plugin WP Statistics. This plugin is provided by wp-statistics.com. Simple statistics are compiled from the data in an anonymized form. No user profiles are created for this purpose, and no cookies are set. All data collected by WP Statistics is stored completely anonymously on this web server. Personal identification of a visitor, even retrospectively, is therefore not possible.
Online presence in social media
We maintain online presences within social networks and platforms to communicate with customers, interested parties, and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process users’ data if they communicate with us within the social networks and platforms, e.g. by writing posts on our online presence or sending us messages.
Integration of third-party services and content
Within our online offering, we use content or service offerings from third parties on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR) in order to integrate their content and services, such as videos or fonts (hereinafter collectively 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 would not be able to send the content to their browser. The IP address is therefore necessary 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 may 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 may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as be linked to such information from other sources.
Google ReCaptcha
We integrate the function for detecting bots, e.g., when entering data into online forms (“ReCaptcha”) from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-out: https://adssettings.google.com/authenticated .
Google Maps
We integrate maps from the “Google Maps” service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The data processed may include, in particular, users’ IP addresses and location data, which, however, will not be collected without their consent (usually obtained through their mobile device settings). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/ , Opt-Out: https://adssettings.google.com/authenticated .
Functions and content of the Twitter service, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, may be integrated into our online offering. This may include content such as images, videos or texts and buttons with which users can share content from this online offering within Twitter.
If users are members of the Twitter platform, Twitter can assign the access to the above-mentioned content and functions to the users’ profiles there. Twitter 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=a2zt0000000TORzAAO&status=Active ). Data protection declaration: https://twitter.com/de/privacy , Opt-out: https://twitter.com/personalization .
Google+
Our online offering may incorporate features and content from the Google+ platform, offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). This may include content such as images, videos, or text, as well as buttons that allow users to share content from this online offering within Google. If users are members of the Google+ platform, Google can associate the access to the aforementioned content and features with the user’s profiles there.
Google is certified under the Privacy Shield Framework, thus guaranteeing compliance with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ). Further information on Google’s data usage, settings, and opt-out options can be found in Google’s privacy policy ( https://policies.google.com/technologies/ads ) and in the settings for the display of Google ads (https://adssettings.google.com/authenticated ).
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