Privacy Information According to Art. 13 and 14 GDPR
1.1 Responsibility for the Processing of your Data
The responsible person (“controller” within the meaning of Art. 4 no. 7 GDPR) of the processing of your personal data (“personal data” within the meaning of Art. 4 no. 1 GDPR) is:
Salzkammergut Tourismus-Marketing GmbH
A-4820 Bad Ischl
Tel. +43 6132 26909
Data protection officer:
We take the protection of personal data seriously and have appointed an external data protection officer for this purpose. Our data protection officer is MMag. Martin Zeppezauer, Thurnbichlweg 50, A-6353 Going am Wilden Kaiser (www.zepedes.com). You can contact our data protection officer at the email address email@example.com.
1.2. Purposes, Categories of Data and Lawfulness of the Processing of Personal Data
Purposes of the processing of personal data
The purposes of processing your personal data generally result from our business activities as a tourism organization: making our online offers available, processing customer inquiries / orders / bookings, accounting, communication with business partners and customers. Detailed information on the purposes of processing and, if necessary, further processing for other compatible purposes as well as the processed data categories can be found in the detailed descriptions of the individual data processing processes.
General categories of data
- Personal master data (e.g. name, date of birth and age, address)
- Contact details (e.g. email address, telephone number, fax number)
- Communication data (time and content of communication)
- Order or booking data (e.g. ordered goods or commissioned services and invoice data such as service period, payment method, invoice date, tax identification number ...)
- Payment details (e.g. account number, credit card details)
- Contract data (content of contracts of any kind)
- Web usage data (e.g. server data, log files and cookies)
Processing of special categories of personal dataaccording to Art. 9 GDPR
- Health data (only if you have given us your explicit consent to process your order (e.g. mediation of a hotel specializing in guests with food intolerances or allergies))
Lawfulness of the processing of personal data
There is basically no obligation to provide the data for the data processing described in this data protection declaration. Failure to provide this data simply means that we cannot offer these services. The legal basis for the processing of your personal data, which is necessary for the fulfilment of a contract with you or an order from you to us, is Art. 6 (1) lit. b GDPR. Insofar as the processing of personal data is necessary on our part to fulfil a legal obligation (accounting obligation, bookkeeping obligation or other legal documentation obligations), Art. 6 (1) lit. c GDPR serves as the legal basis. If the processing of the data takes place in your own vital interest, the legal basis for the data processing is Art. 6 (1) lit. d GDPR. If we process your data to carry out the task assigned to us in the public interest (“sovereign action”), the legal basis is Art. 6 (1) lit. e GDPR. If processing is necessary to safeguard a legitimate interest of our company or a third party and your interests, fundamental rights and freedoms do not outweigh our interests, Art. 6 (1) lit. f GDPR (“legitimate interest”) serves as the legal basis for processing. In this case, we will also inform you about our legitimate interests. Unless we have any other legal basis explained above for the processing of personal data, we will ask for your consent to data processing, whereby in these cases we refer to Art. 6 (1) lit. a GDPR or in the case of the processing of special categories of data based on Art. 9 (2) lit. a GDPR as the legal basis. You can revoke this consent at any time free of charge without affecting the legality of the processing carried out on the basis of the consent until the revocation.
1.3. Transfer of Personal Data to Data Processors and Third Parties
We process your personal data with the support of data processors who support us in providing our services. These data processors are through a corresponding agreement within the meaning of Art. 28 GDPR with us obliged to strictly protect your personal data and may not process your personal data for any purpose other than to provide our services. You can find out which data processors are involved in the detailed descriptions of the individual data processing processes.
Your personal data will be passed on to companies other than our data processors to typical economic service providers such as banks, tax consultants or auditors. Transfer of personal data to state institutions and authorities only takes place within the framework of mandatory national legal provisions.
Depending on your order (e.g. for bookings and inquiries), your personal data will only be transmitted to hotel partners or other tourist service providers (members of our organization)
to the extent necessary to fulfil your order. The transmitted personal data vary depending on the service.
1.4. Transfer of Personal Data to Thrid Countries or Internatinal Organisations
In principle, we process your personal data in the EU. If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if we use the services of our data processors or third parties, this will only take place if the requirements of Art. 44 ff. GDPR are available for the transfer to third countries: i.e. on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU or in compliance with officially recognized contractual obligations, the so-called "EU standard contractual clauses". If we rely on the EU standard contractual clauses as the legal basis for the transmission of your personal data, we will also check the admissibility of this data transmission as part of a comprehensive risk assessment. If we come to a negative result, we will not transfer these data without your explicit consent in accordance with Art. 49 (1) lit. a GDPR to a third country.
1.5. Data Erasure and Period of Data Storage
Your personal data will be deleted by us as soon as the purpose for which we collected your data no longer applies. Storage can also take place if we process the data for a purpose that is compatible with the original purpose. It can also take place if this is provided for by laws, ordinances or other provisions to which our company is subject.
1.6. Data Sources
We only collect your personal data from you and do not use any other data sources.
We do not use any automated decision-making or profiling processes that have a legal effect on you or that significantly affect you in a similar manner. With your consent, however, we will use your usage data to get to know your interests better and thus to be able to display information of interest to you or to be able to make you tailor-made offers or to be able to display corresponding information to you on third-party websites or social media platforms.
1.8. Safeguarding your Data Protection Rights
In principle, you have the right to information, correction, deletion and restriction of the processing of personal data in accordance with the GDPR. If the legal basis for the processing of your personal data is your consent or a contract concluded with you, you also have the right to data portability. You have the right to revoke any consent you may have given to the processing of your personal data. The lawfulness of the processing of your personal data up to the time of revocation is not affected by this. You have the right to object to the processing of your personal data for the purpose of direct marketing. In the event of an objection, your personal data will no longer be processed for the purpose of direct marketing. A detailed explanation of these rights can be found here in Chapter III.
Right of complaint
If you believe that the processing of your data violates data protection law or your data protection claims have otherwise been violated in any way, you can complain to the competent supervisory authority. In Austria, this is the data protection authority (Wickenburggasse 8, 1080 Vienna, email: firstname.lastname@example.org).
2. Visiting our Website
In this section we inform you how we process your personal data when you visit our website.
2.1. Presentation of the Website
For technical reasons, based on the legal basis of Section 165 (3) S 3 TKG 2021 (required for the operation of our website), inter alia. The following data, which your internet browser transmits to us or to our web space provider, collects (so-called "server log files"):
- Browser type and version
- Operating system and device type used (e.g. desktop / mobile)
- Website from which you are visiting us (referrer URL)
- Website you visit
- Date and time of your access
- Your internet protocol address (IP address)
This data, which is anonymous to us, is stored separately from any personal data you may have provided and therefore does not allow us to draw any conclusions about a specific person. They are evaluated for statistical purposes in order to be able to optimize our website and our offers.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, such as B. Orders or inquiries that you send to us as the website operator, an SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http: //” to “https: //” or by the lock symbol in your browser line. If the SSL or TLS encryption is activated, the data that you transmit to us cannot be read by third parties.
Technical service providers
We create and edit the content of our website with the help of the following service provider. With this service provider we have concluded a corresponding agreement according to Art. 28 GDPR to process your data exclusively to the extent of our order:
- TTG Tourismus Technologie GmbH (Freistädter Str. 119, A-4040 Linz). More information on data protection at: https://www.ttg.at/datenschutz
- Mittwald CM Service GmbH & Co.KG (Königsberger Str. 4 - 6, D-32339 Espelkamp). More information on data protection at: https://www.mittwald.de/datenschutz
Cookie Banner - Cookies on our website
Change the cookie settings in your web browser
How the web browser you are using handles cookies, i.e. which cookies are allowed or rejected, can be determined in the settings of your web browser. You can delete cookies already stored on your computer / device yourself at any time. Where exactly these settings are located depends on the respective web browser. Detailed information on this can be called up using the help function of the respective web browser.
In addition, it is possible to generally object to cookies and similar tracking technologies using the services listed below by setting your individual preferences - which technologies you want to allow for usage and interest-based advertising:
- European Interactive Digital Advertising Alliance (EDAA): https://www.youronlinechoices.com/uk/your-ad-choices
- Network Advertising Initiative (NAI):
2.3. Communication with us
Contact form and email
On our website, we offer you the option of contacting us by email and / or using a contact form. In this case, the information you provide will be processed for the purpose of processing your contact based on the legal basis of contract fulfilment in accordance with Art. 6 (1) lit. b GDPR. There is a legitimate interest on our part pursuant to Article 6 (1) lit. f GDPR for the use of a contact form. The legitimate interest lies in offering our website visitors an opportunity to contact us that does not require them to call up their own e-mail client. There is no legal or contractual obligation to provide this personal data. Failure to provide it simply means that you do not submit your request and we cannot process it. The data will only be passed on to third parties if this is stated on the website or in this data protection declaration or is necessary for the fulfilment of the contract or if this is required by statutory provisions. We only save your data for as long as is expedient for processing your inquiries or for any queries you may have.
2.4. Online Shop (s) / Booking Portal (s)
For the purpose of providing contractual services as well as their payment and execution in the context of online purchases, bookings and prospectus orders, we process your personal master data, contract and payment data and communication data (IP address and server log files) on the basis of the legal bases of Art. 6 (1) lit. b GDPR (fulfilment of the contract) as well as Art. 6 (1) lit. c GDPR (legal obligation for invoicing and archiving).
We store this data as long as the purpose requires it, statutory provisions provide for this (retention period of invoices according to § 132 BAO for 7 years; voucher orders until the expiry of the redemption period for 30 years) or we store this data on the basis of the legal basis of Art. 6 (1) lit. f GDPR (legitimate interest) to defend against possible liability claims. If you cancel the order process, we will save the data to clarify possible problems during the order process for 14 days.
There is no legal or contractual obligation to provide personal data. Failure to provide them simply means that we cannot process your bookings / orders.
Feratel DESKLINE online bookings, booking requests and brochure orders
For the processing of online bookings, brochure orders and inquiries, we process your personal data in order to be able to provide you with the booked services with the help of our service provider feratel Media Technologies AG (Maria-Theresien-Straße 8, A-6020 Innsbruck). For this purpose, we store and process inventory data, communication data, contract data, payment data of our customers, interested parties and other business partners. The processing takes place for the purpose of providing contractual services or for the fulfilment of pre-contractual services on the basis of the legal basis of Art. 6 para. 1 lit. b GDPR (booking processes, answering requests for quotations and sending brochures) as well as Art. 6 (1) lit. c GDPR (legally required retention periods of bookings or invoices). For this purpose, the data fields marked as required are required for the establishment and fulfilment of the contract. We disclose your personal data in the context of this data processing to third parties (hotel partners or other tourist service providers) on the basis of the legal basis of Art. 6 (1) lit. b GDPR (if it is necessary for the processing of a booking process), or on the basis of our legitimate interest according to Art. 6 (1) lit. f GDPR for the use of appropriate booking software. We have concluded a corresponding agreement with feratel in accordance with Art. 28 GDPR as a data processor, which ensures that your data is processed exclusively within the scope of our order. Further information on the data protection of feratel under: https://www.feratel.com/en/privacy-policy.html.
External payment service providers
To pay for the order processes / bookings, we use external payment service providers on the legal basis of Art. 6 (1) lit. b GDPR (fulfilment of the contract), via whose platforms you can make your payments. The payment data entered by you as part of the order (e.g. account numbers, credit card numbers including check digits, passwords / TANs, etc.) are processed exclusively by our payment service providers and are not visible to us. We only receive a confirmation of the payment made or information from our payment service providers that the payment could not be made. Further information on the data protection and terms and conditions of our payment service providers can be found at:
- Datatrans AG, Kreuzbühlstrasse 26, CH-8008 Zürich.
Tel. +41 44 256 81 91
2.5. Links to other External Online Shops
In order to enable our users to book accommodation quickly, we link to the booking portal of Booking.com B.V. (Herengracht 597, 1017 CE Amsterdam, Netherlands). This link is integrated into the page using an HTML link. Clicking on the link opens a new window of the browser. On this page you can book the desired accommodation online by entering your specific data. For further information on the purpose and scope of the data collection and the further processing and use of the data by Booking.com B.V. as the controller (responsible for the further processing of your personal data) as well as setting options for the protection of your privacy, please refer to the data protection information of Booking.com B.V. :
2.6. Email Newsletter
Email newsletter (TTG)
On our website there is the possibility to register for our newsletter. The legal basis for sending the newsletter is your consent according to Art. 6 (1) lit. a GDPR. The registration for our newsletter takes place in the so-called double opt-in procedure. This ensures that no one can log in with foreign email addresses (e.g. with your email address). Your consent can be revoked at any time free of charge by clicking on the "unsubscribe link" at the end of each mailing. The legality of the data processing operations already carried out up to that point remains unaffected by the revocation. After unsubscribing from your email address, we will store it for a period of 3 years on the basis of our legitimate interest (Art. 6 (1) lit. f GDPR) in order to obtain your original consent to be able to prove if necessary. To send out our newsletter, we use the service provider TTG Tourismus Technologie GmbH (Freistädter Str. 119, A-4040 Linz). With the help of TTG we can analyze our newsletter campaigns. When opening an email sent with the TTG newsletter tool, a connection is established with the servers of TTG (server location Linz, Austria). This allows us to determine whether a newsletter message has been opened and which links have been clicked on, if any. The purpose of these analyses is to better adapt future newsletters to the interests of the recipients. In addition, technical information such as the time of retrieval, the IP address, browser type and operating system of the recipient are registered. Also on the basis of our legitimate interest pursuant to Art. 6 (1) lit. f GDPR, we will use information from our customer database on your previous orders / bookings / inquiries in order to send you only newsletters with content that is of interest to you. We have concluded a data processing agreement with TTG within the meaning of Art. 28 GDPR to ensure that your data is only processed to the extent desired by us and permitted by you. General data protection information from TTG can be found at: https://www.ttg.at/datenschutz/.
2.7. Web Analysis - Statistical Analyses of our Website
Google Tag Manager
We use the service of the provider Google Ireland Limited ("Google") (Gordon House, Barrow Street, Dublin 4, Ireland) to be able to manage website tags via a common tool of Google. The Google Tag Manager tool itself (which implements the tags) is a domain that does not set cookies and does not collect any other personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, it will remain in place for all tracking tags implemented with Google Tag Manager. Google is a certified partner of the EU-US Data Privacy Framework. The legal basis for (at least a case-by-case) data transfers to the USA is thus an adequacy decision of the European Commission within the meaning of Art. 45 (3) GDPR, with which the European Commission certifies that the USA has an adequate level of data protection. Further information on Google's data protection can be found at: https://policies.google.com/privacy?hl=en-GB.
Google Ads Conversion Tracking
Our Website uses the open source web analytics service Matomo, a service provided by InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, NZBN 6106769, ("Matomo"). Matomo uses technology that enables cross-page user recognition to analyze user behavior. Matomo is hosted exclusively on our own servers, so all analytics data remains with us and is not shared. The IP address is anonymized before storage (shortened by the last two bytes).
With the help of Matomo, we are able to collect and analyze data about the use of our website by website visitors. This allows us to find out which page views were made when and from which region they came. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors perform certain actions (e.g. click behavior).
The processing of the data is based on our legitimate interest in the anonymized analysis of user behavior in order to optimize our website (Art. 6 (1) lit. f DSGVO). If you have given us your consent to set "analysis" cookies, cookies are also set by Matomo. This also allows us to recognize returning users and "analyze" their behavior on our website in more detail. The processing of this data is based on Art. 6 (1) lit. a DSGVO. You can revoke your consent at any time in the cookie settings.
On the legal basis of your consent pursuant to Art. 6 (1) lit. a GDPR, our website uses the functions of "Google Analytics Remarketing" in conjunction with the cross-device functions of Google AdWords and Google DoubleClick. The provider is Google Ireland Ltd. (Gordon House, Barrow Street, Dublin 4, Ireland). This feature makes it possible to link the advertising target groups created with Google Analytics Remarketing with the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC). If you have given your consent, Google will link your web and app browsing history to your Google Account for this purpose. In this way, the same personalized advertising messages can be displayed on every device on which you sign in with your Google Account. To support this feature, Google Analytics collects Google-authenticated user IDs, which are temporarily linked to our Google Analytics data to define and create audiences for cross-device advertising. Cookies are deleted after 1 year. Google is a certified partner of the EU-US Data Privacy Framework. The legal basis for (at least case-by-case) data transfers to the USA is thus an adequacy decision of the European Commission within the meaning of Art. 45 (3) GDPR, with which the European Commission certifies that the USA has an adequate level of data protection. You can permanently object to cross-device remarketing/targeting by deactivating personalized advertising in your Google Account; follow this link here: https://www.google.com/settings/ads/onweb/. The summary of the collected data in your Google Account takes place exclusively on the basis of your consent, which you can give or revoke with Google (Art. 6 (1) lit. a GDPR). Further information on Google's data protection can be found at: https://www.google.com/policies/privacy/.
2.9. Integration of other Third-Party Services and Content
We integrate content or functions of third parties within our website. This always presupposes that the providers of this content or functions perceive the IP address of the users. Without the IP address, they would not be able to send the content to the browser of the respective user. The IP address is therefore required for the presentation of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. However, we have no influence on whether the third-party providers store the IP address, e.g. for statistical purposes. The legal basis for the use of these services, insofar as they are necessary for the functioning of our website, is our legitimate interest in accordance with Art. 6 (1) lit. f GDPR, otherwise your consent according to Art. 6 (1) lit a GDPR. Information on the purpose and scope of the further processing and use of the data by the providers of the embedded services/content as well as further information within the meaning of the Art. 13 and 14 GDPR can be found under the information links listed below. The following services/content are embedded in our website:
We use the map service "Basemap" for cartographic representation, a cartographic product based on the administrative geodata of the nine federal states, the graph integration platform (GIP.at), as well as the country partners, above all the cities and municipalities of Austria. These maps are integrated into our site via our service provider TTG Tourismus Technologie GmbH (Freistädter Str. 119, A-4040 Linz). The legal basis for the processing of your data is Art. 6 (1) lit. f GDPR (legitimate interest). Our legitimate interest consists in an appealing presentation of our online offer or the geographical presentation of the offers of our region. We have concluded a data processing agreement with TTG within the meaning of Art. 28 GDPR to ensure that your data is only processed to the extent desired by us and permitted by you. General data protection information from TTG can be found at: https://www.ttg.at/datenschutz/.
3. Other Data Processing in Business an Customer Contact
In this section we inform you about other data processing processes outside our website.
3.1. Job Applications
The contact data and application documents transmitted to us in the course of a job application will be processed by us exclusively internally for the purpose of selecting suitable candidates for an employment relationship. There is no legal or contractual obligation to provide the personal data. Failure to do so will only result in you not submitting your request and we will not be able to process it. The personal data transmitted in this way will be stored by us in accordance with the statutory provisions for a maximum of 6 months, in the case of the explicit consent of the applicant to keep the documents in evidence, for a maximum of 2 years.
3.2. Online Presence in Social-Media
In addition to our website, we maintain online presences within social networks and platforms: Facebook, Instagram and YouTube in order to communicate with customers and business partners and to connect to them via these networks to be able to inform about our services. Further data protection information can be found when you access our content on these platforms.
Your personal data provided for participation in our competitions (e-mail address, name, address) will be used by us exclusively to identify a winner, inform him of the prize and send him prizes. Your data will not be passed on to third parties. The legal basis for the processing of your personal data is the fulfilment of the contract in accordance with Article 6 (1) lit. b GDPR. There is no legal or contractual obligation to provide the personal data. Failure to provide the data will only result in you not being able to participate in the competition. Your data will be stored for the duration of the competition and – for the processing of any prizes and claims for damages – for a maximum of 3 years thereafter and then deleted. By participating, you also agree that your name will be published on our website as well as on our public social media channels in the event of winning.
3.4. Photo/Video documentation at events
In the case of events, it may happen that we create photos and videos of these events or have them created by photographers commissioned by us, on which you are recognizable as a participant of these events. We need these photos / videos to document and advertise our events and will therefore also publish them in our media (e.g., print brochures, website and social media) and make them available to other media owners (print and online) for the promotion of our event. There is no legal or contractual obligation on your part to provide this data. The legal basis for the processing of your personal data (images and videos on which you are recognizable) is our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. Our legitimate interest lies in our right to public relations (presentation of our activities) and the promotion of our events. You have the right to object to the processing. Please address your objection to the e-mail address provided by us in this data protection declaration. However, it can be assumed that our above-mentioned interest in the use of the photos does not unduly interfere with your rights as a person depicted. This is especially true because we create these photos / videos in public space and point out the production and use of the photos / videos in the run-up to each event. We also always make sure that no legitimate interests of persons depicted are violated. If, for reasons particularly worthy of consideration, your personal rights and freedoms are violated by an image / video created by us, we will refrain from further processing / publication. Removal from print media that have already been circulated cannot take place. In this case, however, we will make a deletion on our website or in our social media channels. We generally delete photos / videos of events if we no longer need these images to document and advertise these events.