Responsible for the content:
Privacy policy and consent to the use of data at www.hirlanda.at/
Data protection is a matter of trust and your trust is important to us. To ensure that you feel secure when visiting our website, we strictly observe the statutory provisions when processing your personal data and would like to inform you here about our data collection and data use. The following privacy policy explains what data is collected from you on our website, how we process and use this data and who you can contact with your concerns.

I. Name and address of the person responsible
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other data protection regulations is the:

Hotel Hirlanda
Alberta and Martin Wille
Zürs 80, 6764 Zürs am Arlberg, Austria

T +43(5583)2262
F +43(5583)3269

hotel@hirlanda.at
www.hirlanda.at

II. Name and address of the data protection officer
The data protection officer of the controller is

Hotel Hirlanda
Alberta and Martin Wille
Zürs 80, 6764 Zürs am Arlberg, Austria

T +43(5583)2262
F +43(5583)3269

hotel@hirlanda.at
www.hirlanda.at

III. General information on data processing

a. Scope of the processing of personal data
We only process our users’ personal data to the extent necessary to provide a functional website and our content and services. The processing of our users’ personal data only takes place regularly with the user’s consent. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.

b. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

c.

Data erasure and storage duration
The personal data of the data subject will be erased or blocked as soon as the purpose of storage no longer applies. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

IV. Provision of the website and creation of log files

a. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data is collected:

(1) Information about the browser type and version used

(2) The user’s operating system

(3) The user’s internet service provider

(4) The IP address of the user

(5) Date and time of access

(6) Websites from which the user’s system accesses our website

(7) Websites that are accessed by the user’s system via our website

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

b. Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

c. Purpose of the data processing
The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

The data is stored in log files to ensure the functionality of the website. We also use the data to optimise the website and to ensure the security of our information technology systems. The data is not analysed for marketing purposes in this context.

These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f GDPR.

d. Dauer der Speicherung
Die Daten werden gelöscht, sobald sie für die Erreichung des Zweckes ihrer Erhebung nicht mehr erforderlich sind. Im Falle der Erfassung der Daten zur Bereitstellung der Website ist dies der Fall, wenn die jeweilige Sitzung beendet ist.

d. Duration of storage
The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or anonymised so that it is no longer possible to identify the accessing client.

e. Possibility of objection and removal
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for the user to object.

V. Use of cookies

a. Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

We use cookies to make our website more user-friendly. Some elements of our website require that the accessing browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

(1) Language settings

(2) Log-in information

We also use cookies on our website that enable an analysis of the user’s surfing behaviour.

The following data can be transmitted in this way

(1) Search terms entered

(2) Frequency of page views

(3) Utilisation of website functions

The user data collected in this way is pseudonymised by technical precautions. It is therefore no longer possible to assign the data to the accessing user. The data is not stored together with other personal user data.

When accessing our website, users are informed by an info banner about the use of cookies for analysis purposes and referred to this privacy policy. In this context, there is also a reference to how the storage of cookies can be prevented in the browser settings.

When accessing our website, users are informed about the use of cookies for analysis purposes and their consent to the processing of the personal data used in this context is obtained. In this context, reference is also made to this privacy policy.

b. Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f GDPR.

The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a GDPR if the user has given consent to this.

c. Purpose of the data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

We require cookies for the following applications:

(1) Adoption of language settings

(2) Remembering search terms

The user data collected by technically necessary cookies is not used to create user profiles.

Analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimise our offer.

These purposes also constitute our legitimate interest in the processing of personal data in accordance with Art. 6 para. 1 lit. f GDPR.

d. Duration of storage, objection and removal options
Cookies are stored on the user’s computer and transmitted by it to our website. As a user, you therefore have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

The transmission of Flash cookies cannot be prevented via the browser settings, but by changing the Flash Player settings.

e. TOWA GDPR plugin
This website uses the TOWA GDPR plugin to obtain your consent to the use of services and analysis tools on your end device and to store this consent in compliance with data protection regulations. For this purpose, we record the IP address of the end device used, the time of consent, the page on which you gave your consent and the consents granted by the selection in the cookie notice.

This is necessary in order to be able to provide clear proof of the tools for which consent to tracking has been given as part of the obligation to provide information. The IP address is stored locally in a secure environment and used exclusively to fulfil the duty to provide information. The data stored by the plugin is never passed on to third parties.

The TOWA GDPR plugin sets cookies for all technologies used to save the status of consent. In addition, a randomly generated value is stored in the GdprAccepted cookie to enable the consent to be assigned. These cookies have a duration of 90 days.

VI. Newsletter

a. Description and scope of data processing
You can subscribe to a free newsletter on our website. When you register for the newsletter, the data from the input screen is transmitted to us.

The following data is also collected during registration

(1) IP address of the accessing computer

(2) Date and time of registration

Your consent is obtained for the processing of the data as part of the registration process and reference is made to this privacy policy.

No data is passed on to third parties in connection with the data processing for sending newsletters. The data is used exclusively for sending the newsletter.

The newsletter service MailChimp https://mailchimp.com/legal/privacy/ is used to send the newsletter. With this tool, we only receive the email address that you enter in the dialogue box, but do not collect any other personal data. If you wish to unsubscribe from the newsletter, you can do so via the “Unsubscribe” link in the newsletter. The data will be used exclusively for sending the newsletter.

b. Legal basis for data processing
The legal basis for the processing of data after registration for the newsletter by the user is Art. 6 para. 1 lit. a GDPR if the user has given consent.

The legal basis for sending the newsletter as a result of the sale of goods or services is Section 7 (3) UWG.

c. Purpose of data processing
The purpose of collecting the user’s email address is to send the newsletter.

The collection of other personal data as part of the registration process serves to prevent misuse of the services or the e-mail address used.

d. Duration of storage
The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. The user’s email address is therefore stored for as long as the subscription to the newsletter is active.

The other personal data collected during the registration process is generally deleted after a period of seven days.

e. Right of objection and cancellation

The subscription to the newsletter can be cancelled by the user concerned at any time. For this purpose, there is a corresponding link in every newsletter.

This also makes it possible to withdraw consent to the storage of personal data collected during the registration process.

VII. Contact form and e-mail contact
a. Description and scope of data processing
There is a contact form on our website that can be used to contact us electronically. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored. These data are

(1) Your first name

(2) Your surname

(3) Your e-mail address

(4) Age of the children, if applicable

The following data is also stored at the time the message is sent:

(1) The IP address of the user

(2) Date and time of registration

Your consent is obtained for the processing of the data as part of the sending process and reference is made to this privacy policy.

Alternatively, you can contact us via the email address provided. In this case, the user’s personal data transmitted with the e-mail will be stored.

No data will be passed on to third parties in this context. The data is used exclusively for processing the conversation.

b. Legal basis for data processing
The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

c. Purpose of the data processing
The processing of the personal data from the input mask serves us solely to process the contact. If you contact us by email, this also constitutes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

d. Duration of storage
The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. For the personal data from the input screen of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

e. Right of objection and cancellation
The user has the option to revoke their consent to the processing of personal data at any time. If the user contacts us by e-mail, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

The following is a description of how to withdraw consent and object to storage.

All personal data stored in the course of making contact will be deleted in this case.

VIII. Web analysis
a. Scope of the processing of personal data
We use Google Analytics, a web analytics service provided by Google Inc (“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 will use this information on our behalf to analyse the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymised user profiles can be created from the processed data.

We only use Google Analytics with activated IP anonymisation. This means that the IP address of users is truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The IP address transmitted by the user’s browser will not be merged with other Google data.

Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

You can find further information on the use of data for advertising purposes by Google, setting and objection options on the Google websites: https://www.google.com/intl/de/policies/privacy/partners/

(“Data use by Google when you use our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.de/settings/ads (“Manage information that Google uses to show you adverts”) and http://www.google.com/ads/preferences/ (“Determine which adverts Google shows you”)

The software places a cookie on the user’s computer (for cookies, see above). If individual pages of our website are accessed, the following data is stored:

(1) Two bytes of the IP address of the user’s accessing system

(2) The website accessed

(3) The website from which the user accessed the website (referrer)

(4) The subpages that are accessed from the accessed website

(5) The time spent on the website

(6) The frequency with which the website is accessed

The software runs exclusively on the servers of our website. Users’ personal data is only stored there. The data is not passed on to third parties.

The software is set so that the IP addresses are not stored in full, but 2 bytes of the IP address are masked (e.g.: 192.168.xxx.xxx). In this way, it is no longer possible to assign the shortened IP address to the calling computer.

b. Legal basis for the processing of personal data
The legal basis for the processing of users’ personal data is Art. 6 para. 1 lit. f GDPR.

c. Purpose of data processing
The processing of users’ personal data enables us to analyse the surfing behaviour of our users. By analysing the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to constantly improve our website and its user-friendliness. These purposes also constitute our legitimate interest in processing the data in accordance with Art. 6 para. 1 lit. f GDPR. By anonymising the IP address, the interest of users in the protection of their personal data is adequately taken into account.

d. Duration of storage
The data is deleted as soon as it is no longer required for our recording purposes. In our case, this is the case after 26 months.

e. Possibility of objection and removal

Cookies are stored on the user’s computer and transmitted by it to our website. As a user, you therefore have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

We offer our users the option of opting out of the analysis process on our website. To do this, you must follow the corresponding link. In this way, another cookie is set on your system, which signals to our system not to save the user’s data. If the user deletes the corresponding cookie from their own system in the meantime, they must set the opt-out cookie again.

You can find more information on privacy settings at the following link:

https://myaccount.google.com/privacy.

IX. Retargeting and data collection by third parties
As part of retargeting and banner advertising, we use third-party services that set cookies on our website. These are the following providers:

– Doubleclick by Google, Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; https://www.google.de/intl/de/policies/technologies/ads/

– Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA; https://www.facebook.com/about/privacy

– Linkedin Inc, 222 Scond Street San Francisco, CA 94105, USA; https://www.linkedin.com/legal/privacy-policy

– Salesforce Inc, Suite 300 San Francisco, CA 94105; https://www.salesforce.com/company/privacy/

– Pinterest Inc, 808 Brannan St San Francisco, CA 94103-4904; https://policy.pinterest.com/de/privacy-policy

X. Rights of the data subject
The following list includes all rights of data subjects under the GDPR. Rights that are not relevant to your own website do not have to be mentioned. In this respect, the list can be shortened.

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

a. Right to information
You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing is taking place, you can request the following information from the controller:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data being processed

(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4) the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period

(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing

(6) the existence of a right to lodge a complaint with a supervisory authority

(7) all available information about the origin of the data if the personal data is not collected from the data subject

(8) the existence of automated decision-making, including profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

b. Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you is incorrect or incomplete. The controller must make the rectification without undue delay.

c. Right to restriction of processing
You may request the restriction of the processing of your personal data under the following conditions

(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead

(3) the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or

(4) if you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override your grounds.

If the processing of personal data concerning you has been restricted, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

d. Right to erasure
1. obligation to erase
You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You withdraw your consent on which the processing was based according to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and where there is no other legal ground for the processing.

(3) You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.

(4) The personal data concerning you has been processed unlawfully.

(5) The deletion of personal data concerning you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.

(6) The personal data concerning you have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

2. information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 (1) GDPR, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3. exceptions
The right to erasure does not exist if the processing is necessary

(1) for exercising the right of freedom of expression and information;

(2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

(3) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 (1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or

(5) for the establishment, exercise or defence of legal claims.

e. Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right vis-à-vis the controller to be informed about these recipients.

f. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

(1) the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and

(2) the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

g. Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

Notwithstanding Directive 2002/58/EC, you have the option of exercising your right to object in connection with the use of information society services by means of automated procedures that use technical specifications.

h. Right to revoke the declaration of consent under data protection law
You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

i. Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1) is necessary for the conclusion or fulfilment of a contract between you and the controller

(2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or

(3) with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

j. Right to lodge a complaint with the data protection authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.