With this DATA PROTECTION DECLARATION we inform you which personal data we process in connection with our WEB SITE WWW.top3starhotels.ch.
Our offer is subject to Swiss data protection law as well as any applicable foreign data protection law, such as in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
- CONTACT ADDRESSES
Responsibility for the processing of personal data:
Top 3 Star Hotels of Switzerland
c/o Alma Hotel Zurich Seefeld
+41 (0) 76 323 02 74
We point out if there are other persons responsible for the processing of personal data in individual cases.
- PROCESSING OF PERSONAL DATA
PERSONAL DATA is any information relating to an identified or identifiable person. A DATA SUBJECT is a person about whom personal data are processed. PROCESSING includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, storage, modification, destruction and use of personal data.
The EUROPEAN ECONOMIC AREA (EEA) comprises the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
2.2 LEGAL BASIS
We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Data Protection Act (FADP) and the Ordinance to the Federal Data Protection Act (FDPA).
We process personal data - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b DSGVOforthe necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to provide our offer permanently, in a user-friendly, secure and reliable manner and to be able to advertise for it as required, information security as well as protection against misuse and unauthorized use, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
- Art. 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task that is in the public interest.
- Art. 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person
2.3 NATURE, SCOPE AND PURPOSE
We process those personal data that are REQUIRED to provide our offer permanently, user-friendly, secure and reliable. Such personal data can fall in particular into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales, contract and payment data.
We process personal data for the DURATION that is required for the respective purpose(s) or by law. Personal data whose processing is no longer required will be anonymized or deleted. Persons whose data we process have, in principle, a right to deletion.
As a matter of principle, we process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a data subject voluntarily and personally provides to us when contacting us - for example, by letter, e-mail, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book or with comparable tools. If you transmit personal data to us via third parties, you are obliged to ensure data protection vis-à-vis such third parties and to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of providing our services, if and to the extent that such processing is permitted for legal reasons.
2.4 PROCESSING OF PERSONAL DATA BY THIRD PARTIES, ALSO ABROAD
We may have personal data processed by commissioned third parties or process it jointly with third parties or with the help of third parties or transmit it to third parties. Such third parties are in particular providers whose services we use. We also ensure appropriate data protection for such third parties.
Such third parties are generally located in Switzerland as well as in the European Economic Area (EEA). Such third parties may also be located in other states and territories on earth as well as elsewhere in the universe, provided that their data protection law ensures adequate data protection in the opinion of the Swiss Federal Data Protection and Information Commissioner (FDPIC) and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - in the opinion of the European Commission, or if adequate data protection is ensured for other reasons, such as by a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or by a corresponding certification. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the requirements under data protection law, such as the express consent of the data subject, are met for this purpose
- RIGHTS OF DATA SUBJECTS
Data subjects whose personal data we process have the rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the personal data processed. Data subjects whose personal data we process may - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - request confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed. Data subjects whose personal data we process may - if and insofar as the GDPR applies - revoke any consent they have given at any time with future effect and object to the processing of their personal data at any time. Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
- DATA SECURITY
We take appropriate and suitable technical and organizational measures to ensure data protection and, in particular, data security. However, despite such measures, the processing of personal data on the Internet can always have security gaps. We can therefore not guarantee absolute data security. Access to our online offer takes place via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar. Access to our online offering is subject - as is basically any Internet use - to mass surveillance without cause and without suspicion, as well as other surveillance by security authorities in Switzerland, the European Union (EU), the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies and other security authorities.
- USE OF THE WEBSITE
Cookies can be stored temporarily in your browser as "session cookies" when you visit our website or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, they allow us to recognize your browser the next time you visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
For cookies used for performance and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via AdChoices (Digital Advertising Alliance Of Canada), Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
5.2 SERVER LOG FILES
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including data volume transferred, website last accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our online offer permanently, user-friendly and reliably and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.
5.3 NUMBER PIXEL
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels - also from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to collect the same information as server log files.
- NOTIFICATIONS AND MESSAGES
We send notifications and communications such as newsletters by email and through other communication channels such as instant messaging.
6.1 PERFORMANCE AND REACH MEASUREMENT
Notifications and messages may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to offer notifications and communications effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
6.2 CONSENT AND OBJECTION
As a matter of principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent to receive e-mails, we use the "double opt-in" procedure where possible, i.e. you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
In principle, you can unsubscribe from notifications and communications such as newsletters at any time. By unsubscribing, you can in particular object to the statistical recording of usage for performance and reach measurement. Notifications and communications that are absolutely necessary for our offer remain reserved.
6.3 SERVICE PROVIDERS FOR NOTIFICATIONS AND MESSAGES
We send notifications and messages via third-party services or with the help of service providers. Cookies may also be used in the process. In particular, we use:
- SOCIAL MEDIA
We are present on social media platforms and other online platforms in order to communicate with interested persons and to inform them about our offer. In doing so, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
For our SOCIAL MEDIA PRESENCE ON FACEBOOK including the so-called Page Insights, we are, if and to the extent that the GDPR applies, jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly manner.
- THIRD PARTY SERVICES
We use third-party services in order to be able to provide our offer permanently, user-friendly, secure and reliable. Such services may also be used to embed content on our website. Such services - for example, hosting and storage services, video services and payment services - require your Internet Protocol (IP) address, as such services cannot otherwise transmit the corresponding content.
For their own security, statistical and technical purposes, third parties whose services we use may also process data related to our offer as well as from 8 other sources - including with cookies, log files and counting pixels - aggregated, anonymized or pseudonymized.
We use in particular:
DigitalShop: e-guma. https://www.e-guma.ch/datenschutz/
8.1 We use services from third parties in order to be able to make use of the digital infrastructure required for our offer. This includes, for example, hosting and storage services from specialized providers. In particular, we use:
8.2 SOCIAL MEDIA FUNCTIONS AND SOCIAL MEDIA CONTENT
We use third party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and in other ways. In particular, we use:
8.3 MAP MATERIALS
We use third party services to embed maps on our website. In particular, we use:
- GOOGLE MAPS: including Google Maps Platform: mapping service; Google Maps-specific privacy disclosures: "How Google uses location information".
We use third party services to embed selected fonts as well as icons, logos and symbols on our website. In particular, we use:
- GOOGLE FONTS: Fonts; Google Fonts-specific privacy statements: "What does using the Google Fonts API mean for the privacy of my users?" ("What does using the Google Fonts API mean for the privacy of my users?").
We use the option to display targeted ADVERTISING FOR OUR OFFER on third parties such as social media platforms and search engines.
With such advertising, we would like to reach in particular persons who are interested in our offer or already use our offer(REMARKETING AND TARGETING). For this purpose, we may transmit corresponding - if necessary also personal - data to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website(CONVERSION TRACKING).
Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our offer to your profile there.
We use in particular:
- FACEBOOK ADVERTISING (FACEBOOK ADS): social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies(among others in the USA); data protection information: remarketing and targeting in particular with the FACEBOOK PIXEL as well as CUSTOM AUDIENCES including LOOKALIKE AUDIENCES, data protection declaration, "advertising preferences" (user registration required).
- GOOGLE ADS: Search engine advertising; Google Ads-specific privacy disclosures: advertising based on search queries, among other things, using various domain names - notably doubleclick.net, googleadservices.com, and googlesyndication.com - for Google Ads, "Advertising" (Google), "Why am I seeing a particular ad?".
- INSTAGRAM ADS: social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies(including in the USA); data protection information: remarketing and targeting in particular with FACEBOOK PIXEL as well as CUSTOM AUDIENCES including LOOKALIKE AUDIENCES, data protection declaration (Instagram), data protection declaration (Facebook), "advertising preferences" (Instagram) (user registration required), "advertising preferences" (Facebook) (user registration required).
- ENHANCEMENTS FOR THE WEBSITE
We use extensions for our website in order to be able to use additional functions.
We use in particular:
- GOOGLE RECAPTCHA: spam protection (distinguishing between wanted comments coming from humans and unwanted comments coming from bots and spam); Google reCAPTCHA specific privacy information: "What is reCAPTCHA?" ("What is reCAPTCHA?").
- PERFORMANCE AND REACH MEASUREMENT
We use services and programs to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our online offering and the effect of third-party links to our website. However, we can also, for example, test and compare how different versions of our online offering or parts of our online offering are used ("A/B test" method). Based on the results of the performance and reach measurement, we can in particular correct errors, strengthen particularly popular content or make improvements to our online offering.
When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened in order to follow the principle of data economy through the corresponding pseudonymization and to improve the data protection of visitors to our website ("IP masking").
When using services and programs for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. As a matter of principle, user profiles are created exclusively on a pseudonymous basis. We do not use user profiles to identify individual visitors to our website. Individual services with which you are registered as a user may be able to assign the use of our online services to your profile with the respective service, whereby you usually had to give your consent to this assignment in advance.
We use in particular:
- GOOGLE ANALYTICS: Success and reach measurement; Google Analytics-specific information on data protection: measurement also across different browsers and devices 12 (CROSS-DEVICE TRACKING) as well as with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA in exceptional cases, "Data protection", "Browser add-on to deactivate Google Analytics".
- GOOGLE TAG MANAGER: Integration and management of services for performance and reach measurement as well as other services from Google as well as from third parties; further information on data protection can be found at the individual integrated and managed services.
- FINAL PROVISIONS