Privacy Policy
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration below.
2. Hosting und Content Delivery Networks (CDN)
External Hosting
This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.
The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR).
Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.
We are using the following host:
Mittwald CM Service GmbH & Co. KG
Königsberger Straße 4-6
32339 Espelkamp
Execution of a contract data processing agreement
In order to guarantee processing in compliance with data protection regulations, we have concluded an order processing contract with our host.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.
Note on the responsible body
The responsible body for data processing on this website is:
Kirsten Vahl-Voss
Friedrichstraße 27
25980 Sylt
Phone: 04651 98880
E-Mail: info@hotel-gutenberg.de
The responsible body is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).
Storage period
Unless a specific storage period is mentioned in this data protection declaration, your personal data will remain with us until the purpose for the data processing no longer applies. If you make a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have any other legally permissible reasons for storing your personal data (e.g. tax or commercial retention periods); in the latter case, the deletion takes place after these reasons no longer apply.
Statutory data protection officer
We have appointed a data protection officer for our company.
compolicy GmbH
Dr. Christian Wolff
Schwedenkai 1
24103 Kiel
Phone: 04319089480
Email: info@compolicy.de
Note on data transfer to the USA
Tools from companies based in the USA are integrated on our website. When these tools are active, your personal data can be passed on to the US servers of the respective companies. We would like to point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to surrender personal data to security authorities without you as the person concerned being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence on these processing activities.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can revoke your consent at any time. The legality of the data processing carried out before the revocation remains unaffected by the revocation.
Right to object to the collection of data in special cases and to direct advertising (Art. 21 GDPR)
IF THE DATA PROCESSING BASED ON ART. 6 ABS. 1 LIT. E OR F GDPR, YOU HAVE AT ANY TIME THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR SPECIAL SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RELEVANT LEGAL BASIS ON WHICH PROCESSING IS REQUIRED, CAN BE REFERRED TO IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN PROVIDE COMPULSORY REASONS FOR PROCESSING THAT OWN YOUR INTEREST, EXECUTE OR OVERVIEW THE RIGHTS OBJECTION ACCORDING TO ART. 21 PARA. 1 GDPR).
IF YOUR PERSONAL DATA ARE PROCESSED FOR DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME AGAINST THE PROCESSING OF PERSONAL DATA FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT IN CONNECTION WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION ACCORDING TO ART. 21 (2) GDPR).
Right of appeal to the competent supervisory authority
In the event of violations of the GDPR, the data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation. The right of appeal exists without prejudice to other administrative or judicial remedies.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another person responsible, this will only be done if it is technically feasible.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the website operator, this site uses 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: //” and 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.
Information, deletion and correction
Within the framework of the applicable statutory provisions, you have the right to free information about your stored personal data, their origin and recipient and the purpose of the data processing and, if necessary, a right to correct or delete this data. You can contact us at any time if you have any further questions on the subject of personal data.
Right to restriction of processing
You have the right to request that the processing of your personal data be restricted. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we usually need time to check this. For the duration of the test you have the right to request that the processing of your personal data be restricted.
- If the processing of your personal data happened / happens unlawfully, you can request the restriction of the data processing instead of the deletion.
- If we no longer need your personal data, but you need them to exercise, defend or assert legal claims, you have the right to request that the processing of your personal data be restricted instead of being deleted.
- If you have lodged an objection in accordance with Art. 21 Paragraph 1 GDPR, your interests and ours must be weighed up. As long as it is not yet clear whose interests prevail, you have the right to request that the processing of your personal data be restricted.
If you have restricted the processing of your personal data, these data – apart from their storage – may only be allowed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest processed by the European Union or a member state.
4. Data collection on this website
Cookies
Our Internet pages use so-called “cookies”. Cookies are small text files and do not cause any damage to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser automatically deletes them.
In some cases, cookies from third-party companies can also be stored on your device when you enter our site (third-party cookies). These enable us or you to use certain third-party services (e.g. cookies for processing payment services).
Cookies have different functions. Numerous cookies are technically necessary because certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or to display advertising.
Cookies that are required to carry out the electronic communication process (necessary cookies) or to provide certain functions you require (functional cookies, e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) on the basis of Art. 6 Para. 1 lit.f GDPR, unless a different legal basis is given. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies has been requested, the cookies concerned are stored exclusively on the basis of this consent (Art. 6 Para. 1 lit. a GDPR); the consent can be revoked at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when you close the browser. If cookies are deactivated, the functionality of this website may be restricted.
Insofar as cookies are used by third-party companies or for analysis purposes, we will inform you of this separately in the context of this data protection declaration and, if necessary, request your consent.
Cookie consent with Usercentrics
This website uses Usercentrics’ cookie consent technology to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies and to document them in compliance with data protection regulations. The provider of this technology is Usercentrics GmbH, Rosental 4, 80331 Munich, website:
When you enter our website, the following personal data is transferred to Usercentrics:
- Your consent (s) or the revocation of your consent (s)
- Your IP address
- Information about your browser
- Information about your device
- Time of your visit to the website
Usercentrics also saves a cookie in your browser in order to be able to assign the consent you have given or to be able to revoke it. The data collected in this way will be stored until you ask us to delete it, delete the Usercentrics cookie yourself or the purpose for data storage no longer applies. Mandatory statutory retention requirements remain unaffected.
Usercentrics is used to obtain the legally required consent for the use of certain technologies. The legal basis for this is Article 6, Paragraph 1, Sentence 1, Letter c GDPR.
Order processing contract
We have concluded an order processing contract with Usercentrics. This is a contract stipulated by data protection law, which ensures that Usercentrics processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
Server log files
The website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
This data will not be merged with other data sources.
This data is recorded on the basis of Art. 6 Paragraph 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – the server log files must be recorded for this.
contact form
If you send us inquiries using the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.
This data is processed on the basis of Article 6 (1) (b) GDPR, provided that your request is related to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries sent to us (Art. 6 Para. 1 lit. f GDPR) or on your consent (Art. 6 Para. 1 lit. a GDPR) if this was queried.
The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.
Inquiries by email, phone or fax
If you contact us by e-mail, telephone or fax, your request, including all personal data derived from it (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent.
This data is processed on the basis of Art. 6 Para. 1 lit. b GDPR, if your request is related to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries sent to us (Art. 6 Para. 1 lit. f GDPR) or on your consent (Art. 6 Para. 1 lit. a GDPR) if this was queried.
The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
5. Analysis tools and advertising
Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, length of stay, operating systems used and the origin of the user. This data may be summarized by Google in a profile that is assigned to the respective user or their device.
Google Analytics uses technologies that enable the user to be recognized for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transmitted to a Google server in the USA and stored there.
This analysis tool is used on the basis of Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), processing takes place exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; the consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/ .
IP anonymization
We have activated the IP anonymization function on this website. As a result, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before it is transmitted to the USA. The full IP address is only transmitted to a Google server in the USA and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
Browser plugin
You can prevent Google from collecting and processing your data by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de .
You can find more information on how Google Analytics handles user data in the Google Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=de .
Order processing
We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Storage period
Data stored by Google at user and event level that are linked to cookies, user IDs (e.g. user ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) are anonymized after 14 months or deleted. You can find details on this under the following link: https://support.google.com/analytics/answer/7667196?hl=de
6. Plugins and Tools
Google Maps
This site uses the Google Maps map service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To use the functions of Google Maps, it is necessary to save your IP address. This information is usually transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of an appealing presentation of our online offers and an easy findability of the places we have indicated on the website. This represents a legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR. If a corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; the consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/ .
You can find more information on handling user data in Google’s privacy policy: https://policies.google.com/privacy?hl=de .
OpenStreetMap
We use the map service of OpenStreetMap (OSM). The provider is the Open Street Map Foundation (OSMF), 132 Maney Hill Road, Sutton Coldfield, West Midlands, B72 1JU, United Kingdom.
When you visit a website on which OpenStreetMap is integrated, your IP address and other information about your behavior on this website are forwarded to the OSMF. OpenStreetMap may save cookies in your browser or use comparable recognition technologies.
Your location can also be recorded if you do this in your device settings – e.g. B. on your mobile phone. The provider of this site has no influence on this data transfer. Details can be found in the data protection declaration of OpenStreetMap under the following link: https://wiki.osmfoundation.org/wiki/Privacy_Policy .
The use of OpenStreetMap takes place in the interest of an appealing presentation of our online offers and an easy findability of the places indicated by us on the website. This represents a legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR. If a corresponding consent has been requested (e.g. consent to the storage of cookies), processing takes place exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; the consent can be revoked at any time.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to check whether data is entered on this website (e.g. in a contact form) by a person or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, length of stay of the website visitor on the website or mouse movements made by the user). The data collected during the analysis are forwarded to Google.
The reCAPTCHA analyzes run completely in the background. Website visitors are not informed that an analysis is taking place.
The data is stored and analyzed on the basis of Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offers from abusive automated spying and from SPAM. If a corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; the consent can be revoked at any time.
For more information about Google reCAPTCHA, see the Google Privacy Policy and the Google Terms of Use under the following links: https://policies.google.com/privacy?hl=de and https://policies.google.com/terms?hl=de .
7. eCommerce and Payment Providers
Processing of data (customer and contract data)
We collect, process and use personal data only insofar as they are necessary for the establishment, content or change of the legal relationship (inventory data). This is done on the basis of Art. 6 Para. 1 lit. b GDPR, which allows the processing of data for the performance of a contract or pre-contractual measures. We collect, process and use personal data on the use of this website (usage data) only insofar as this is necessary to enable the user to use the service or to bill.
The customer data collected will be deleted after the order has been completed or the business relationship has ended. Statutory retention periods remain unaffected.
8. Own services
Handling of applicant data
We offer you the opportunity to apply to us (e.g. by email, post or via the online application form). In the following, we will inform you about the scope, purpose and use of your personal data collected during the application process. We assure you that your data will be collected, processed and used in accordance with the applicable data protection law and all other statutory provisions and that your data will be treated as strictly confidential.
Scope and purpose of the data collection
If you send us an application, we process your related personal data (e.g. contact and communication data, application documents, notes in the context of job interviews, etc.), insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 BDSG-new according to German law (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and – if you have given your consent – Art. 6 para. 1 lit. a GDPR. The consent can be withdrawn at any time. Your personal data will only be passed on to persons within our company who are involved in processing your application.
If the application is successful, the data you submit will be processed on the basis of Section 26 BDSG-new and Art. 6 Para. 1 lit. b GDPR stored in our data processing systems for the purpose of carrying out the employment relationship.
Retention period of the data
If we cannot make you a job offer, you reject a job offer or withdraw your application, we reserve the right to store the data you have transmitted on the basis of our legitimate interests (Art. 6 Para. 1 lit.f GDPR) for up to 6 months to be kept with us from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. The storage serves in particular for evidence purposes in the event of a legal dispute. If it is evident that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), it will only be deleted when the purpose for further storage no longer applies.
Longer storage can also take place if you have given your consent (Art. 6 Para. 1 lit. a GDPR) or if statutory retention requirements prevent deletion.
Inclusion in the applicant pool
If we do not make you a job offer, you may be able to be included in our applicant pool. In the event of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you if there are suitable vacancies.
The inclusion in the applicant pool takes place exclusively on the basis of your express consent (Art. 6 Para. 1 lit. a GDPR). Giving your consent is voluntary and has no relation to the current application process. The person concerned can revoke his consent at any time. In this case, the data will be irrevocably deleted from the applicant pool, provided there are no legal reasons for retention.
The data from the applicant pool will be irrevocably deleted no later than two years after the consent has been given.