Data Protection

table of contents

1. Subject of Data Protection and Legal Grounds
2. Server Log Data
3. Contact Form / Email
4. Live Chat
5. Member Area
6. Payment Transactions via Credit Card
7. Communication via Email
8. Newsletter and Promotional Mail
9. Cookies
10. Cloudflare (Content Delivery Network)
11. Web Analysis / Google Analytics
12. Retargeting / Remarketing
13. Embedding Videos
14. Other Services and Content from Third Parties
15. Links to our Social Media Presences; Sharing of Content
16. Recipients of Personal Data
17. Data Processing in Third Countries
18. Retention Period and Deletion
19. Your Rights
20. Security
21. Changes

(hereinafter also referred to as “we” or “Groups”)

Regarding the data protection-related aspects of using the website www.groups.swiss or www.groupstravel.com (hereinafter also referred to as “Website”) and your rights as a data subject, we, the

as the responsible party, would like to inform you as follows.

The processing of your personal data occurs exclusively within the framework of applicable legal provisions of data protection law, particularly the Swiss Federal Act on Data Protection (“DSG”), the EU General Data Protection Regulation (“GDPR”), as well as other legal provisions related to data protection (collectively hereinafter referred to as “Data Protection Laws”).

This privacy statement applies only to the website that you can access under the domain groups.swiss or groupstravel.com. For other internet presences or offerings from Groups, the applicable privacy notices may be provided there. It may also happen that we provide you with additional privacy notices in other situations of contact or data processing that you should also take note of.

Furthermore, the following notes do not apply to external websites of other providers linked from the website. Since we are based in Switzerland and operate our website from there, the processing of your personal data, unless otherwise stated in this privacy statement, generally takes place in Switzerland. As far as the processing of data is carried out by us in Switzerland, an adequate level of data protection is ensured with respect to you as a customer in the European Union (EU) or the European Economic Area (EEA), in accordance with the EU’s adequacy decision for Switzerland.

1. Subject of Data Protection and Legal Basis

The subject of data protection is the protection of personal data. Personal data refers to all information that relates to an identified or identifiable natural person (the so-called data subject).

Please note that this is not a complete or exhaustive enumeration of possible legal bases, but merely examples intended to make the legal grounds for data protection clearer. Further details on the legal grounds for the individual data processing activities on our website can be found in the following sections.

2. Server Log Data

We process this data based on our legitimate interests in providing the website, ensuring technical operations, and securing our IT systems. We have an interest in enabling and maintaining the use of our website and its technical functionality. This data is automatically processed when you access our website. Without this provision, you cannot use our website. We do not use this data to draw conclusions about your identity.

The automatically collected data is usually deleted after the purpose has been fulfilled, unless there is an exceptional circumstance in which a different legal basis applies. If that is the case, we will delete the data immediately after the alternative legal basis ceases to exist.

We cannot comply with an objection to the collection and storage of your server log data, as this data is essential for the smooth operation of the website.

3. Contact Form / Email

If you would like to contact us via email, we may process your voluntarily provided data (for example, contact details such as your name and email address). The data you provide through our contact form or via email will be transmitted to us over a secured connection (for details, see Section 21). The collection, processing, and use of your contact data will occur solely for the purpose of recording and, if applicable, responding to your inquiry. The processing of data transmitted in the course of communication through the contact form or email occurs either for the initiation or execution of a contractual relationship with you or based on our legitimate interests. In the latter case, we have a legitimate interest in processing voluntarily submitted contact inquiries directed to us.

We will delete the data you provide as soon as the purpose of collection is completely fulfilled, subject to the fulfillment of ongoing legal retention obligations. If your data is processed based on legitimate interests, you can object to the storage of your personal data at any time. In this case, we will no longer process your data unless we can demonstrate a legitimate interest in doing so or are otherwise legally obligated to retain the data. To exercise your right to object regarding the storage, please contact us in writing or via email.

Please note, however, that when communicating through the contact form and especially via email, we cannot guarantee complete data security. Particularly in the case of confidential information, we therefore recommend sending such information through a secure transmission method, such as postal mail.

4. Live Chat

If you do not wish to use the Live Chat, you can access all information through other communication channels (e.g., our website) and contact us via the contact form, among other means.

5. Member Area 

The storage of voluntary information is based on our legitimate interests. We have a legitimate interest in processing the data you voluntarily provide to offer and continuously improve the functionalities in the member area. You can object to the processing of voluntary information at any time by deleting the respective data from your user profile. The data you provide will be transmitted from your browser to our server and processed there to verify your request. 

You can delete your member account at any time by sending a message via the contact form. Alternatively, you can also delete your member account directly in your user profile under “Profile.” Your profile will be deleted or locked immediately upon deletion of your member account, unless there are statutory retention obligations or we can demonstrate an overriding legitimate interest (for further details, see Section 19). 

6. Booking 

The “Booking Request” and “Direct Booking” functions on our website can be used regardless of whether you register as a Guest (Group Leader) or use our website without registration. If you are registered as a Guest (Group Leader) and are logged in at the time of your booking request or direct booking, the respective forms will be pre-filled with your data (see Section 5 (b) bb of this privacy statement). You can change the information at any time in this case.

a) Booking Request 

This function allows you to communicate with the landlord via email to clarify all essential details of a rental agreement with the landlord and to send your booking request directly to them. The landlord will then contact you. The contract is always concluded directly between you and the landlord. We will not be involved in the processing of the booking request. For more information on the conclusion of the contract, please refer to our General Terms and Conditions (GTC). 

In the course of a booking request, you must provide the following data in the corresponding form on our website (as well as in the exceptional case of a phone booking): 

The entered data will be forwarded to the landlord of the desired accommodation for processing your booking request and conducting the rental. We also store a copy of your entered data for any inquiries you may have regarding your booking request (e.g., if you do not hear back from the landlord). Please note that for further processing of your data by the landlord, the landlord is solely responsible. Therefore, please also refer to the privacy notices of the respective landlord. 

You can also send the aforementioned booking request to multiple landlords simultaneously (“Group Request”). A Group Request can also be sent to all your previously marked favorites. 

The processing of your data in the context of the booking request function is carried out for the execution of the contractual relationship in accordance with our General Terms and Conditions (GTC) with you and based on our legitimate interests. We have a legitimate interest in optimally processing your booking requests and being able to continuously improve this function.

b) Direct Booking 

This function allows you to make a reservation online, where your desired date is already reserved for you and blocked for other inquiries. The landlord then has three days to confirm the reservation. As with direct bookings, the contract is always concluded directly between you and the landlord. However, in this case, we act as an intermediary and take care of concluding the rental agreement and organizing the payment processing. More information on the conclusion of the contract can be found in our General Terms and Conditions (GTC) as well as our General Terms of Business for Direct Bookings. 

In the course of a direct booking, you must provide the following data on our website: 

• Details of your desired booking (e.g., check-in and check-out dates) 

The data you enter will be forwarded to the landlord of the desired accommodation for processing and conducting the rental agreement. We also store a copy of your entered data for any inquiries you may have regarding your “Direct Booking” (e.g., if you do not hear back from the landlord). Please note that for further processing of your data by the landlord, the landlord is solely responsible. Therefore, please also refer to the privacy notices of the respective landlord. 

The processing of your data in the context of the direct booking function occurs for the execution of the contractual relationship in accordance with our General Terms and Conditions (GTC) with you and based on our legitimate interests. We have a legitimate interest in optimally processing your “Direct Booking” and being able to continuously improve this function. 

The payment processing between you and the landlord for payments within the framework of the rental agreement can be made by bank transfer (on the landlord’s invoice) or by credit card through the involvement of a payment service provider (see Section 7 of this privacy statement). Regardless of whether you transfer the invoice amounts to the landlord or make a payment by credit card, we generally do not store your payment data. Please also refer to the privacy notices of the respective landlords in this context. 

c) Cancellation Insurance 

After you receive a binding booking confirmation from the landlord, you have the option to obtain “Cancellation Cost Insurance for Groups.” This insurance is offered by the following provider, with whom the insurance contract is concluded: AWP P&C S.A., Saint-Ouen (Paris), Branch Office Wallisellen (Switzerland), Richtiplatz 1, 8304 Wallisellen. For more information, please refer to the “General Insurance Conditions” on our website regarding “Cancellation Cost Insurance for Groups” as well as our General Terms and Conditions (GTC). Please also refer to the privacy notices of the insurance provider.

7. Payment Transactions via Credit Card 

For payment transactions related to the functions mentioned in this privacy statement, if the option for credit card payment is available, we work with the following payment service provider: Stripe Payments Europe, Ltd., The One Building, 1 Grand Canal Street Lower, Dublin 2, Ireland (“Stripe”). 

We provide only an interface to Stripe, so the processing of your payment data (name of your financial institution, IBAN, BIC) for the purpose of payment processing is generally carried out exclusively by Stripe. The legal basis for data processing for payment processing is the fulfillment of the contract in accordance with our General Terms and Conditions (GTC) with you.  Please refer to Stripe’s privacy policy for more details: [www.stripe.com/privacy](http://www.stripe.com/privacy).

8. Communication via Email 

If you make a booking on our website or register as a landlord, we will send you an email in certain situations (e.g., guests may receive a booking confirmation, travel information shortly before arrival, or inquiries about your stay after your return; landlords may receive reminders to update availability or pricing). 

In the course of email communication, your title, name, email address, and any data provided by the landlord in their profile for contact purposes will be processed. 

The processing is carried out for the purpose of providing our contractual services, executing our contractual relationship with you in accordance with our General Terms and Conditions (GTC), fulfilling legal obligations, and based on our legitimate interests. We have a legitimate interest in optimally processing your booking, providing you with as much information as possible for your stay, and continuously improving our offerings based on your feedback. 

The emails are sent using Mailgun, an email delivery service provided by the US-based company Mailgun Technologies Inc, 548 Market Street, Suite 43099, San Francisco, CA 94101, USA. The data processing is carried out on our behalf based on a Data Processing Agreement (DPA) that we have signed with Mailgun. In this agreement, Mailgun commits to protecting our users’ data, processing it only on our behalf, and, in particular, not disclosing it to third parties. 

The email addresses and other data described in this notice are stored on Mailgun’s servers in the USA. Mailgun uses this information to send emails on our behalf. However, Mailgun does not use this data to contact you directly or to share it with third parties.  Data transfers to the USA are subject to the EU Standard Contractual Clauses concluded with Mailgun Technologies Inc. For more information on data processing by Mailgun, you can view the following link: [www.mailgun.com/gdpr](http://www.mailgun.com/gdpr).

9. Newsletter and Promotional Mail 

We offer you the opportunity to subscribe to our customer newsletter, landlord newsletter, or promotional mail in various places on our website as well as during the creation of a member account. 

We send our newsletters and promotional mail only upon appropriate registration, meaning with your consent. We explicitly reserve the right to rely on other legal grounds. If specific content is described as part of the registration for one of our newsletters or for receiving promotional mail, this will determine the scope of your consent. Otherwise, our newsletters and promotional mail include information about our products, offers, promotions, and our company. 

Should you no longer wish to receive newsletters and/or promotional mail from us, you can withdraw your consent at any time. A notification in written form (e.g., email, letter) to the contact details provided above or via the contact form is sufficient. You will also find an unsubscribe link in each newsletter. 

The newsletters are sent using CleverReach, a newsletter delivery platform provided by CleverReach GmbH & Co. KG, CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany (“CleverReach”). The data processing is carried out on our behalf based on a data processing agreement that we have concluded with CleverReach. In this agreement, CleverReach commits to protecting our users’ data, processing it only on our behalf, and, in particular, not disclosing it to third parties. 

CleverReach processes the email addresses of our newsletter recipients and their additional data described in this notice, using this information to send and evaluate the newsletters on our behalf. CleverReach does not use the data of our newsletter recipients to contact them directly or to share it with third parties. 

Additionally, please note that after the newsletters are sent, we evaluate your user behavior regarding our newsletter. For this evaluation, the sent emails include so-called web beacons, also known as tracking/counting pixels. These are one-pixel image files that link to our website and allow us to evaluate your user behavior concerning our newsletter and conduct statistical analyses (e.g., evaluating open rates). This is done by collecting technical information such as your browser, system, IP address, and the time of retrieval, as well as web beacons that are assigned to your email address and linked to a unique ID. 

Tracking via web beacons is not possible if you have disabled image display by default in your email program. In this case, the newsletter will not be displayed fully, and you may not be able to use all functions. If you manually enable images, the aforementioned tracking will occur. 

You can view information about data protection at CleverReach here: [Data Protection Compliance CleverReach](https://www.cleverreach.com/en/privacy/). Regardless of newsletters, we may send you emails regarding relevant actions related to your member account. The legal basis for this is the fulfillment of our contractual obligations according to our General Terms and Conditions (GTC).

10. Cookies 

The website uses cookies and similar tracking technologies (hereinafter collectively referred to as “Cookies”) to optimize the website’s design. This enables easier navigation and a high degree of user-friendliness.

Cookies are generally small identification markers that our web server sends to your browser, which your device stores by default. They can be used to determine whether there has already been communication from your device to us. Therefore, they serve the purpose of making the use of our website more comfortable for you and optimizing our services by analyzing how you use our site. Cookies can be set by us or by third parties, such as our partners for analytics, marketing, and social media. The data processing occurs based either on our legitimate interests or on your consent, provided that you have explicitly consented to the storage and use of cookies. Personal data can be stored in cookies only if technically necessary, if you do not object, or if you have given your consent. The right to rely on other legal grounds remains expressly reserved.

When you use our website, we inform you of the use of functional cookies, and you can object to the use and storage of functional cookies at any time with effect for the future in the cookie settings of this website. 

If you also grant us your consent for the use and storage of analytics and marketing cookies, you can revoke this at any time with effect for the future in the cookie settings of this website.

Furthermore, you can technically prevent the storage of necessary cookies at any time by selecting “do not accept cookies” in your browser settings. The procedures for technically managing and deleting cookies in your browser settings can be found in your browser’s help function. 

Additionally, you can technically prevent the storage and use of all cookies by using free browser add-ons, such as “Adblock Plus” (adblockplus.org/de) in combination with the “EasyPrivacy” list (easylist.to). 

However, if you prevent the storage of all cookies, this may lead to limitations in the functionality of the website.

a) Necessary Cookies 

We use necessary cookies on our website, which we have a legitimate interest in storing, as we could not otherwise provide certain basic functionalities. Necessary cookies can only be technically disabled through your browser settings or browser add-ons. For more details, please refer to the above section. This may lead to limitations in the functionality of the website.

b) Functional Cookies 

Additional cookies that are not strictly necessary for using the website still serve important purposes. They enable comfortable browsing on our website. Functional cookies allow a website to remember information that affects how the website behaves or looks, such as pre-filled forms or your location. The storage and use of functional cookies take place, unless you object, in order to safeguard our legitimate interests. Our legitimate interest arises from the usage purposes presented. For more details, please refer to the above sections. You can object to the use of functional cookies at any time with effect for the future in the cookie settings of this website.

c) Analytics Cookies 

Analytics cookies help us better understand how visitors interact with our website and our content by evaluating usage information. In this context, we also use third-party cookies, which may allow them to obtain information about your usage behavior and use it for their own purposes (see Section 11). Please visit the websites of third parties for more information on their cookie usage. The storage and use of analytics cookies are based on your consent, provided that you have granted this to us. For more details, please refer to the above sections and Section 12 below. You can revoke this consent at any time with effect for the future in the cookie settings of this website.

d) Marketing Cookies 

For the use of marketing services (see Section 13) and to connect with social media offerings (see Section 16), we also use third-party cookies, which may allow them to obtain information about your usage behavior and use it for their own purposes. Please visit the websites of third parties for more information on their cookie usage. The storage and use of marketing cookies occurs based on your consent, provided that you have granted this to us. For more details regarding data processing and the purposes pursued, please refer to the above sections and the descriptions of the individual services and functions in Sections 13ff that are based on the use of such cookies. You can revoke your consent at any time with effect for the future in the cookie settings of this website.

11. Cloudflare (Content Delivery Network) 

On our website, we use the “Content Delivery Network” (CDN) service provided by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA (hereinafter referred to as “Cloudflare”). A CDN is a service that helps deliver content from our website to you more quickly and protects us, for example, from Distributed Denial of Service (DDoS) attacks. In the process, your browser may transmit personal data, such as your IP address, to Cloudflare. In the case of the transmission of personal data, this data may be temporarily stored on servers in the USA.

The processing of your personal data takes place for the purposes of maintaining the functionality and stability of the CDN, as well as ensuring the functionality and information security of our website. The processing of your personal data is carried out based on Article 6(1)(f) of the GDPR, as we have a legitimate interest in the security of our information technology systems and ensuring the operability or technical operation and optimization of our website.

To the extent that personal data are processed, this processing is done on our behalf. Any data transfers to the USA are subject to the EU Standard Contractual Clauses concluded with Cloudflare, Inc.

For more information on how Cloudflare handles your personal data, you can refer to their privacy policy: (https://www.cloudflare.com/privacypolicy/).

12. Web Analytics / Google Analytics 

If you have consented to it, we use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). 

Google Analytics utilizes cookies. The information generated by the cookie about your use of our website is typically transmitted to a Google server in the USA and stored there. The legal basis for the data processing is your consent. We explicitly reserve the right to rely on other legal grounds. Any data transfers to the USA are subject to the EU Standard Contractual Clauses concluded with Google’s parent company, Google LLC, which can be accessed here: (https://support.google.com/adspolicy/answer/9012903?hl=en). 

On our behalf, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services related to website usage and internet usage. From the processed data, pseudonymous usage profiles can be created. 

We implement Google Analytics with IP anonymization enabled. This means that Google will truncate the user IP address within member states of the European Union (EU) or in other contracting states of the agreement on the European Economic Area (EEA). Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The data will be deleted as soon as they are no longer required for our recording purposes. In our case, this is typically after 36 months. 

You can revoke any consent you may have given for the use of Google Analytics at any time through the cookie settings of this website. Furthermore, you can technically prevent the storage and use of cookies by adjusting the settings in your browser or using browser add-ons (see Section 10 above). Additionally, you can prevent the collection of data generated by the cookie related to your use of the website (including your IP address) by Google and the processing of these data by Google by downloading and installing the browser plugin available at the following link: (https://tools.google.com/dlpage/gaoptout?hl=en). 

For more information on Google’s data usage, settings, and options for objection, please visit the following Google websites: 

• https://www.google.com/intl/de/policies/privacy/partners (Data usage by Google when you use websites or apps of our partners)
• https://www.google.com/policies/technologies/ads (Data usage for advertising purposes)
• https://www.google.de/settings/ads (Manage information that Google uses to show you ads)

13. Retargeting/Remarketing 

We use retargeting/remarketing services on our website to optimize our offerings, including those from third parties. The data processing takes place based on your consent, provided you have granted us this. We expressly reserve the right to rely on other legal grounds.

a) How Retargeting/Remarketing Works 

On our website, data is collected based on cookie/tracking technology to optimize our advertising and the entire online offering (so-called retargeting/remarketing). We do not use this data to personally identify you; rather, it serves solely to evaluate the use of our website and to target users who have already shown interest in our content and offerings with interest-based advertising on our website and on other websites and social media channels of our partners. We believe that displaying interest-based advertising is generally more appealing to you than ads that lack this personal relevance. The display of ads on our website or on the websites of our partners is based on an analysis of previous usage behavior. The creation of usage profiles is typically done in an anonymized or pseudonymized manner, according to the providers of the retargeting/remarketing services we use. We also never merge this data with other personal data stored with us. In the following section of this privacy statement, you will find information about the third parties we collaborate with, how your data is processed in this context, and how you can deactivate retargeting/remarketing technologies.

b) Facebook Pixel 

We use services from Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter referred to as “Facebook”), such as the Facebook Pixel, for retargeting/remarketing purposes on this website. 

If you visit our website and you have granted us your consent, a direct connection between your browser and the Facebook server is established through the Facebook Pixel. This allows Facebook to receive information that you have visited our website, enabling us to make our Facebook activities more effective, such as displaying posts or ads specifically to visitors of our website. Additionally, the Facebook Pixel allows us to analyze how this website is used and to display ads for content and offers that may interest you. The data collected is transmitted to Facebook in an encrypted format and is anonymized for us, meaning that personal data about individual users is not visible to us. We also use the “advanced matching” feature of the Facebook Pixel, meaning that personal data such as your email address or booking information can be transmitted to Facebook to approach you with even more targeted advertising tailored to your interests.

For more information on the Facebook Pixel, including the type, scope, purposes, legal bases, and options to object to the data processing by Facebook, as well as your options for protecting your privacy, you can refer to Facebook’s privacy policy at (https://www.facebook.com/about/privacy/) and (https://www.facebook.com/business/learn/facebook-ads-pixel).

You can revoke your consent for us to store and use cookies (including the Facebook Pixel) for retargeting/remarketing purposes at any time with future effect through the cookie settings of this website. Additionally, you can technically prevent the storage and use of marketing cookies (including the Facebook Pixel) by adjusting your browser settings or using browser add-ons (see Section 10 above).

14. Integration of Videos 

Our website uses video integrations from YouTube. This service is provided by the following company (hereinafter also referred to as “third party”):

• YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4,  Ireland (“Google” or “YouTube”)

The data processing occurs based on your consent, if you have granted it, and otherwise on the basis of our legitimate interests. Our legitimate interest lies in the economic operation of our website and the optimization of our overall online offering. We expressly reserve the right to rely on other legal grounds. 

The embedded YouTube videos on our website, which are stored at http://www.youtube.com and can be played directly from our website, are integrated in “enhanced privacy mode.” This means that, according to YouTube, no data about you as a user is transmitted to YouTube when you do not play the videos. However, when accessing the embedded video, a connection to YouTube’s servers is established and certain information (e.g., your IP address) is sent to the provider, even if you are not logged in with that account. We generally do not know the nature and extent of the data collected by YouTube and have no influence on its use. Provided that you have given us your consent, YouTube’s services may also be used for retargeting/remarketing purposes (see details in Section 13). 

For more information on the purposes and scope of data collection, as well as on the further processing and use of the data by the third party, your related rights, and the available options for protecting your privacy, please refer to the third party’s privacy policy:

• Privacy Policy of Google, which also includes YouTube: (https://www.google.de/intl/de/policies/privacy/).

If you do not want the third party to associate your visit to our website with your user account there, you must log out of the corresponding service before visiting our website. Even if you are not logged into the third party, websites with videos may still send data to the third party via cookies, allowing the third party to create an anonymized or pseudonymized user profile.

You can revoke your consent for the storage and use of cookies in connection with the embedded videos in the cookie settings of our website (see Section 10 above). Furthermore, you can technically prevent the storage and use of cookies at any time by adjusting your browser settings or using browser add-ons (see Section 10 above).

15. Additional Services and Content from Third Parties 

On our website, we also use plugins from third parties to integrate their content and services, such as maps (collectively referred to as “Content”). The processing of your data occurs based on our legitimate interests. We have a legitimate interest in the economic operation and optimization (especially user-friendliness) of our website.

The third-party providers of this content will always become aware of your IP address, as they cannot transmit the content to your device without it. The IP address is required for displaying the content. Additionally, third parties may place cookies on your device.

You can disable the loading of plugins or their storage and use of cookies in your browser settings or through browser add-ons, such as “Adblock Plus” (https://adblockplus.org/de/) in combination with the “EasyPrivacy” list (https://easylist.to/). However, we would like to inform you that in this case, not all functions of our website may be available for use.

Google Maps

We use the “Google Maps” service from the third-party provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to display maps. The data processed may include IP addresses and location data, which, however, will not be collected without your consent (typically through the relevant device settings). For more information on data usage by Google, as well as settings and options to object, please visit Google’s website at the following link: [Privacy Policy](https://policies.google.com/privacy?hl=de).

16. Links to Our Social Media Presence; Sharing Content 

a) On this website, you will find links (hyperlinks) to the social networks and platforms of Facebook, LinkedIn, and Instagram. These services are provided by the following companies (hereinafter referred to as “third parties”): 

• Facebook is operated by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)
• LinkedIn is operated by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”) 
• Instagram is operated by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”) 

The purpose and scope of data collection, as well as the further processing and use of the data by Facebook and LinkedIn, as well as your related rights and the available options for protecting your privacy, can be found in the privacy policies of the respective third-party providers: 

• Facebook Data Policy: (https://www.facebook.com/privacy/explanation), (https://de-de.facebook.com/legal/terms/)(https://www.facebook.com/about/privacy/update) and (https://www.facebook.com/policies/cookies/) 
• LinkedIn Privacy Policy: (https://www.linkedin.com/legal/privacy-policy) 
• Instagram Privacy Policy: (https://help.instagram.com/519522125107875)

If you do not want a third party to link the clicking of a link to its service to your user account, you must log out of that service before clicking such a link. Even if you are not logged into the third-party services, data may still be sent to the third party via cookies upon clicking the link.

b) Additionally, you have the option to share your saved accommodations (“Favorites”) as well as the “Property Detail Page” of individual accommodations. You can use services from various third-party providers, such as Facebook, Twitter, WhatsApp, or via email, to send a link to the respective property detail pages or your favorites list. By selecting the individual provider, you will be redirected directly to the respective service offer of the third-party provider via the link. Even if you are not logged into the respective third-party service, data may be sent to the third party when you click the link, including through the use of cookies. The terms of use and privacy policies of the relevant provider will apply, as provided on the respective third-party provider’s websites.

The third-party services Twitter and WhatsApp are provided by the following companies (for Facebook, see the previous section): 

• Twitter is operated by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland (“Twitter”)
• WhatsApp is operated by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“WhatsApp”) 

You can find the privacy policies of these third parties here: 

• Twitter Privacy Policy: (https://twitter.com/privacy) and (https://business.twitter.com/de/resources/global-audience.html)
• WhatsApp Privacy Policy: (https://www.whatsapp.com/legal/privacy-policy)

17. Recipients of Personal Data 

We only share your personal data with external recipients if this is necessary for the processing of your request, if we have your consent, or if there is another legal basis for doing so. 

External recipients may include: 

• Processors: These are service providers we engage for the provision of services, for example, in the areas of technical infrastructure and maintenance of our website. Such processors are carefully selected and regularly reviewed by us to ensure that your privacy is maintained. These service providers are permitted to use the data only for the purposes specified by us and according to our instructions. We are entitled, subject to legal requirements, to engage such processors. 
• Public authorities: These are government bodies, state institutions, and other public-law entities, such as regulatory authorities, courts, public prosecutors, or tax authorities. Personal data will only be transmitted to such public authorities for legally mandatory reasons. The legal basis for such a transmission may be the fulfillment of a legal obligation. 
• Private entities: Service providers and assistants to whom data is transmitted based on a legal obligation or to protect legitimate interests, such as tax consultants or auditors, as well as landlords of accommodations offered for rental on our website. The transmission occurs based on your consent, the necessity for fulfilling a contractual or legal obligation, or our legitimate interests.

18. Data Processing in Third Countries 

If we transfer your data to third countries outside of Switzerland, the EU, or the EEA as described above, we ensure before the transfer that, apart from legally permitted exceptions, an appropriate level of data protection exists at the recipient or that you consent to the transfer of data. An appropriate level of protection is, for example, ensured by entering into EU Standard Contractual Clauses or the existence of so-called Binding Corporate Rules (BCR). Please contact us via the aforementioned communication channels to receive a copy of the specific guarantees for the transfer of your data to third countries.

19. Storage Duration and Deletion 

We will only store your personal data as long as it is necessary to fulfill the purposes for which it was collected or—if consent was given—as long as you do not revoke your consent. In case of an objection, we will no longer process your personal data unless its further processing is permitted or even required by applicable legal provisions (e.g., under commercial and tax retention obligations). We will also delete your personal data if we are legally required to do so. 

For details on the storage duration of your personal data, please refer to the respective sections outlined above.

20. Your Rights 

As a data subject, you have numerous rights. Specifically, these are: 

• Right to Information: You have the right to obtain information about the personal data we have stored about you. 
• Right to Rectification and Deletion: You can request the rectification of incorrect data and, if the legal requirements are met, the deletion of your data. 
• Right to Restriction of Processing: You can request from us—if the legal requirements are met—that we restrict the processing of your data. 
• Right to Data Portability: If you provided us with data based on a contract or consent, you can, when the legal requirements are met, request that we provide the data you provided to us in a structured, commonly used format or that we transmit this data to another controller. 
• Right to Object to Processing Based on Legitimate Interests: You have the right to object at any time, for reasons arising from your particular situation, to the processing of your data by us, where this is based on legitimate interests. If you exercise your right to object, we will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms. 
• Withdrawal of Consent: If you have given us consent to process your data, you can withdraw this consent at any time with future effect. The legality of the processing of your data until the withdrawal remains unaffected. If you wish to withdraw your consent for the use of certain cookies, please refer to the information in Section 10. 
• Right to Lodge a Complaint with a Supervisory Authority: You can also lodge a complaint with the competent supervisory authority if you believe the processing of your data violates applicable law. You may contact the data protection authority responsible for your residence, your workplace, or the location of the alleged violation, or the data protection authority responsible for us. The competent supervisory authority for data protection for us is: Federal Data Protection and Information Commissioner (EDÖB), Feldeggweg 1, CH-3003 Bern, Switzerland, Phone: +41 (0)58 462 43 95, Fax: +41 (0)58 465 99 96. 

If you have questions regarding the processing of your personal data, your rights as a data subject, or any consent given, our data protection officer is available through the communication channels mentioned above. Please also contact our data protection officer directly to exercise your rights as a data subject.

21. Security 

We take technical and organizational security measures to protect your personal data against accidental or intentional manipulation, loss, destruction, or unauthorized access by third parties. These security measures are continuously updated in accordance with the current state of technology. 

Your personal data transmitted in the course of using our website will be securely transmitted via encryption. We use the encryption protocol Transport Layer Security (TLS), widely known by its predecessor name Secure Socket Layer (SSL). 

Our employees are bound to confidentiality.

22. Changes 

From time to time, it may be necessary to adjust the content of this privacy policy. We therefore reserve the right to change this at any time. If your consent is required for a change, we will obtain this from you. We will also publish the amended version of the privacy policy at this location. When you revisit our website, you should therefore read the privacy policy again. 

Status: October 2024