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1. contact addresses

Responsibility for the processing of personal data:

Responsible Hotels of Switzerland
c/o Schmid Pelli & Partner AG
Bodmerstrasse 6
8002 Zürich
+41 43 810 06 06
info@responsiblehotels.ch

We point out if there are other persons responsible for the processing of personal data in individual cases.

2 Processing of personal data

2.1 Definitions

Personal data is any information that relates 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, acquisition, 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, in particular the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection (FADP).

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 DSGVO for the 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, as well as to be able to advertise for it as required, information security as well as protection against misuse and unauthorised 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 which 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 GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

2.3 Type, scope and purpose

We process the personal data that is necessary to provide our services in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular fall 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 period of time required for the relevant purpose(s) or as required by law. Personal data whose processing is no longer required is anonymised or deleted. Persons whose data we process generally have the right to have their data deleted.

In principle, we only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons, for example to fulfil 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 provides to us voluntarily and of his or her own accord when contacting us - for example, by letter, email, 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 guarantee 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 accessible 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, including 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 and 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 guarantees adequate data protection according to the assessment 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 - according to the assessment of the European Commission, or if adequate data protection is guaranteed for other reasons, such as through a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or through 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 explicit consent of the data subject, are met for this purpose.

3. rights of data subjects

Data subjects whose personal data we process have rights under Swiss data protection law. These include the right to information and 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 consent they have given at any time with effect for the future 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).

4 Data security

We take appropriate and suitable technical and organisational 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 cannot therefore 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 offer is subject - as is basically any use of the Internet - 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.

5 Use of the website

5.1 Cookies

We may use cookies for our website. Cookies - both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) - are data that are stored in your browser. Such stored data need not be limited to traditional cookies in text form. Cookies cannot run programs or transmit malware such as Trojans and viruses.

Cookies can be stored in your browser temporarily 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 enable us to recognise your browser the next time you visit our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

You can deactivate or delete cookies in full or in part at any time in your browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent for the use of cookies - if and to the extent necessary.

In the case of cookies used for performance and reach measurement or for advertising, a general objection ("opt-out") is possible for many 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 record 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. This information is necessary in order to provide our online service in a permanent, user-friendly and reliable manner 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 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.

6. notifications and messages

We send notifications and communications such as newsletters via email and other communication channels such as instant messaging.

6.1 Performance and reach measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked. Such web links and tracking pixels may also record the use of notifications and messages 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

In 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 which you must click to confirm, so that no misuse by unauthorised 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 communications

We send notifications and communications via third-party services or with the help of service providers. Cookies may also be used in the process. In particular, we use:

- Mailchimp: communication platform; provider: The Rocket Science Group LLC d/b/a Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); data protection information: privacy policy (Intuit) including "Country and Region-Specific Terms", cookie policy, "Privacy Rights Requests", "Mailchimp and European Data Transfers", "Security".

7 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. Personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such online platforms also apply in each case. These provisions inform in particular about the rights of data subjects, which include in particular the right to information.

For our social media presence on Facebook, including the so-called page insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland), if and insofar as the GDPR is applicable. 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.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Responsible Party Addendum" with Facebook and thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Page Insights Information" including "Page Insights Data Information".

8. third party services

We use third-party services in order to be able to provide our offer in a permanent, user-friendly, secure and reliable manner. 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 relevant content.

For their own security, statistical and technical purposes, third parties whose services we use may also process aggregated, anonymised or pseudonymised data in connection with our service and from 8 other sources - including cookies, log files and counting pixels.

We use in particular:

- Services from Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and security principles", data protection declaration, "Google is committed to compliance with applicable data protection laws", "Guide to data protection in Google products", "How we use data from websites or apps on or in which our services are used" (information from Google), "How Google uses cookies", "Personalised advertising" (activation / deactivation / settings).

8.1 Digital infrastructure

We use third-party services to provide the digital infrastructure required for our services. This includes, for example, hosting and storage services from specialised providers. In particular, we use:

- Cyon: Hosting; Provider: Cyon GmbH (Switzerland); Information on data protection: "Data protection", Privacy policy.

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 other ways. In particular, we use:

- Facebook (social plugins): embedding Facebook functions and Facebook content, for example "Like" or "Share"; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: data protection declaration.

- Instagram platform: Embedding of Instagram content; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: data protection declaration (Instagram), data protection declaration (Facebook).

- LinkedIn Consumer Solutions Platform: Embedding of functions and content from LinkedIn, for example with plugins such as the "Share Plugin"; Provider: LinkedIn Ireland Unlimited Company (Ireland) for users in the European Economic Area (EEA) as well as in Switzerland / LinkedIn Corporation USA) for users in the rest of the world; data protection details: "Datenschutz" ("Privacy"), data protection declaration, cookie policy, cookie management / objection to e-mail and SMS communication from LinkedIn, objection to interest-based advertising.

8.3 Maps

We use third party services to embed maps on our website. In particular, we use:

- Google Maps: including Google Maps Platform: map service; Google Maps-specific privacy information: "How Google uses location information".

8.4 Fonts

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 my users' privacy?" ("What does using the Google Fonts API mean for the privacy of my users?").

8.5 Advertising

We use the option of displaying targeted advertising for our services on third parties such as social media platforms and search engines.

We want to use such advertising to reach people who are interested in our offer or who already use our offer (remarketing and targeting). For this purpose, we may transmit corresponding - possibly also personal - information 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 (including 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 different domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - for Google Ads, "Advertising" (Google), "Why do I see a certain 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).

- LinkedIn Ads: Social media advertising; provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); data protection information: remarketing and targeting in particular with the LinkedIn Insight Tag, "Data protection", privacy policy, cookie policy, objection to personalised advertising.

9. extensions for the website

We use extensions for our website in order to be able to use additional functions.

In particular, we use:

- Google reCAPTCHA: spam protection (distinguishing between wanted comments that come from humans and unwanted comments from bots, as well as spam); Google reCAPTCHA-specific privacy disclosures: "What is reCAPTCHA?" ("What is reCAPTCHA?").

10. performance and reach measurement

We use services and programmes to determine how our online offer is used. In this context, we can, for example, measure the success and reach of our online offer as well as the effect of third-party links to our website. We can also, for example, test and compare how different versions of our online offer or parts of our online offer are used ("A/B test" method). Based on the results of the performance and reach measurement, we can, in particular, correct errors, strengthen content that is particularly in demand or make improvements to our online offer.

When using services and programmes for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are always shortened in order to comply with the principle of data economy through the corresponding pseudonymisation and to improve the data protection of visitors to our website ("IP masking").

When using services and programmes 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 only created pseudonymously. We do not use user profiles to identify individual visitors to our website. Individual services with which you are registered as a user may, if necessary, allocate the use of our online offer to your profile with the respective service, whereby you usually had to give your consent to this allocation in advance.

We use in particular:

- Google Analytics: performance 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 pseudonymised 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 and third parties; further information on data protection can be found in the individual integrated and managed services.

11. final provisions

We have created this data protection declaration with the data protection generator of Datenschutzpartner.

We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.