Private Policy

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as “data”) we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online services”).

The terms used are not gender-specific.

Last update: February 9th 2023

Table of contents

Controller

AAA-Appartments GmbH
Bahnhofstraße 10/1
6700 Bludenz
Austria

E-mail address:
servus@a-appartments.com

Phone:
+43 5552 20420

Overview of processing operations

The following table summarizes the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

Categories of Data Subjects

Purposes of Processing

Legal Bases for the Processing

Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Austria. This includes in particular the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). In particular, the Data Protection Act contains special provisions on the right of access, rectification or cancellation, processing of special categories of personal data, processing for other purposes and transmission and automated decision making in individual cases.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

TLS encryption (https): To protect your data transmitted via our online services, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission or if certifications or binding internal data protection regulations justify the processing (Article 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Our further information on individual processing operations may also contain additional and specific information on data retention and erasure applicable to the respective processing operations.

Use of Cookies

Cookies are small text files or other data records that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the contents accessed or the functions used. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Information on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is strictly necessary in order to provide an information society service explicitly requested by the subscriber or user. The revocable consent will be clearly communicated to the user and will contain the information on the respective cookie use.

Information on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the use of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online services and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For which purposes the cookies are processed by us, we do clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Retention period: With regard to the retention period, a distinction is drawn between the following types of cookies:

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Article 21 GDPR. Users can also declare their objection by means of the settings of their browser, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes, can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further information on processing methods, procedures and services used:

Provision of online services and web hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

Further information on processing methods, procedures and services used:

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

Further information on processing methods, procedures and services used:

Web Analysis, Monitoring and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Further information on processing methods, procedures and services used:

We use Google Analytics to perform measurement and analysis of the use of our online services by users based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: “city” (and the derived latitude and longitude of the city), “continent”, “country”, “region”, “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The IP address of users is not logged and is shortened by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal Basis: Consent (Article 6 (1) (a) GDPR);
Website: https://marketingplatform.google.com/intl/en/about/analytics/;
Datenschutzerklärung: https://policies.google.com/privacy;
Data Processing Agreement: https://business.safety.google/adsprocessorterms/;
Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://business.safety.google/adsprocessorterms;
Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated;
Further Information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).

Online Marketing

We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedure in which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed.

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Further information on processing methods, procedures and services used:

Online marketing process for purposes of placing content and advertisements within the provider’s advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR);
Website: https://marketingplatform.google.com;
Datenschutzerklärung: https://policies.google.com/privacy;
Further Information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices;
Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.

ADDITIVE+ NEWSLETTER
On our website you have the possibility to subscribe to our newsletter. For the subscription we need your email address and your consent to receive our newsletter through ADDITIVE, our provider for hotel e-mail marketing.

To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin in our hotel newsletter tool.

After signing up for our newsletter you will receive an email containing a link to confirm the subscription.

Your subscription can be cancelled any time by clicking on the cancellation link in the respective newsletter. To process your subscriptions and to send our newsletters we use software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”). Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

Further information on processing methods, procedures and services used:

Instagram plugins and contents – This can include content such as images, videos or text and buttons with which users can share content from this online service within Instagram. – We are jointly responsible (so-called “joint-controllership”) with Meta Platforms Ireland Limited for the collection or transmission (but not further processing) of “Event Data” that Facebook collects or receives as part of a transmission using Instagram functions that run on our website for the following purposes: a) displaying content advertising information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g. b) delivering commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving recognition of which content or advertising information is believed to be of interest to users). We have entered into a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which specifically addresses the security measures that Facebook must take (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of data subjects (i.e., users can, for example, submit information access or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain information on individual users and are anonymous to us), then this processing is not carried out within the scope of joint responsibility, but on the basis of a DPA (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of Standard Contractual Clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook;
Service provider: Meta Platforms Irland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland;
Legal basis: Einwilligung (Art. 6 Abs. 1 S. 1 lit. a) DSGVO);
Website: https://www.instagram.com;
Privacy Policy: https://instagram.com/about/legal/privacy.

Video contents;
Legal Basis: Consent (Article 6 (1) (a) GDPR); Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Website: https://www.youtube.com;
Privacy Policy: https://policies.google.com/privacy.

Provision and editing of geographic and other maps, plans, and location-based information;
Legal Basis: Consent (Article 6 (1) (a) GDPR); Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): see Data Processing Agreement; Data Processing Agreement: Provided by the service provider;
Service provider: Mapbox, Inc., 740 15th St Nw Suite 500 Washington, DC 20005 USA;
Website: https://www.mapbox.com/;
Privacy Policy: https://www.mapbox.com/legal/privacy.

We use Flockler, a social media aggregator tool, to curate social media feeds and present social media content that we think will be relevant to you. Flockler does not store any information about your visit. However, depending on the platform, the social media services that provide the relevant content (e.g. photos, videos) may store information about you. In our case, this concerns the social network Instagram. More information about data processing by Instagram can be found in the relevant section of this privacy policy.
Legal Basis: Consent (Article 6 (1) (a) GDPR);
Data Processing Agreement: https://flockler.com/dpa;
Further Information: The contents of the embedded posts are automatically retrieved from the respective social platforms according to the conditions and permissions of the authors and the authors can object to their presentation at any time. In general, the authors of the posts are responsible for the content of their posts. Without prejudice to the legal rights of the users, we recommend that in the event of complaints about posts not posted by us, to (also) contact the respective authors or platforms in order to remove the posts at the source;
Service provider: Flockler OyRautatienkatu 21 B33100 TampereFinland;
Website: https://flockler.com/;
Privacy Policy: https://flockler.com/privacy-policy.

We include widgets on our website for finding accommodation, for displaying accommodation on a map and for loading highlighted accommodation from the provider Avantio. This is software for managing holiday apartments and houses. Data is loaded from Avantio’s servers, which are located in the EU, for which purpose the IP addresses of the visitors must be transmitted to these servers. If the accommodation search is used, the search results are displayed on the subdomain booking.a-appartments.com on a website provided directly by the service provider Avantio. This subdomain has its own data protection conditions, which are informed separately and for which consent is obtained separately.
Legal basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Service provider:
Internet Tourism Solutions SL, C / Charles Robert Darwin 5, 46980 Paterna – Valencia, Spain;
Website: https://www.avantio.com;
Privacy Policy: https://www.avantio.com/privacy-policy/.

Rights of Data Subjects

As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

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