Data Protection Policy

POSCOM Tour Operating AG (Tscharnerstrasse 37, 3007 Berne, Switzerland), is the operator of the websites ferienverein.ch, bikeholiday.ch, hotel-altein.ch, hotel-schweizerhof-sils.ch, hotel-victoria-lauberhorn.ch, hotel-valaisia.ch, pastaandmore-wengen.ch, tirreno-resort.com, giverola-resort.com and campingpola.es and is therefore responsible for the collection, processing and use of your personal data and the compatibility of data processing with Swiss law. 

Your trust is important to us, which is why we take the subject of data protection seriously and pay close attention to taking appropriate security measures on your behalf. Of course, we observe the legal provisions of the Federal Data Protection Act (DSG), the Ordinance to the Federal Data Protection Act (VDSG), the Telecommunications Act (FMG) and, if applicable, other data protection regulations, in particular the General Data Protection Regulation of the European Union (hereinafter referred to as "GDPR").

In order for you to know what personal data we collect from you and for what purposes we use it, please take note of the information below.

1. Nature, scope and purpose of collection, processing and use

a. When visiting one of the websites mentioned above

When you visit our website, our servers temporarily save each access to a log file. The following data is recorded without your intervention and stored for 30 days:

  • IP address of the requesting computer
  • the date and time of access;
  • name and URL of the retrieved file
  • the website from which the access was made
  • the operating system of your computer and the browser you are using

These data are collected and processed for the purpose of enabling the use of our websites (connection establishment), to permanently guarantee system security and stability and to enable the optimisation of our Internet offer as well as for internal statistical purposes. This is our legitimate interest in data processing within the meaning of Art. 6 para. 1 (f) of the GDPR. 

In addition, we use so-called pixels and cookies to display personalised advertising and to use web analysis services when you visit our websites. For further details, please refer to No. 2, No. 6 and No. 7 of this data protection declaration.

b. When using our form for requests for offers

You have the option of using an offer request form to send a booking request to a hotel. The entry of the following personal data is mandatory:

  • Title
  • First and last name
  • Email address

The mandatory entries are marked with an asterisk (*). Failure to provide this information may hinder the provision of our services. Providing other information is optional and has no influence on the use of our websites.

We use this data only to be able to answer your contact inquiry in the best possible and personalised way. We have a legitimate interest in processing your contact enquiry within the meaning of Art. 6 para. 1 (f) of the GDPR. You can object to this data processing at any time (for contact data, see further points under No. 10).

c. Using our form for massage appointments

You can use a massage form to send an appointment request to a hotel. The entry of the following personal data is mandatory:

  • First and last name
  • Telephone
  • Email address
  • Offer (desired massage)
  • Date and time

The mandatory entries are marked with an asterisk (*). Failure to provide this information may hinder the provision of our services. Providing other information is optional and has no influence on the use of our websites.

We use this data only to be able to answer your contact inquiry in the best possible and personalised way. We have a legitimate interest in processing your contact enquiry within the meaning of Art. 6 para. 1 (f) of the GDPR. You can object to this data processing at any time (for contact data, see further points below). 10).

d. When registering for our newsletter

On our website you have the possibility to subscribe to our newsletter. This requires registration. The following data must be provided during registration:

  • Title
  • First and last name
  • Email address

The above data is necessary for data processing. 

By registering, you give us your consent to the processing of the data provided for the regular dispatch of the newsletter to the address you have provided and for the statistical evaluation of usage behaviour and optimisation of the newsletter. This consent constitutes, within the meaning of Art. 6 para. 1 (a) of the GDPR, our legal basis for processing your email address. We are entitled to commission third parties with the technical handling of advertising measures and are entitled to pass on your data for this purpose (cf. below No. 3).

At the end of each newsletter you will find a link to unsubscribe at any time. 

e. When booking a hotel room or a package tour

On our website there are various options for making bookings or reservations or requesting information material. With the websites hotel-victoria-lauberhorn.ch, hotel-schweizerhof-sils.ch, giverola-resort.com and tirreno-resort.com you can access the booking platform of a third-party provider. The Terms of Use and data protection of this provider apply there. Depending on the service, various data are collected in this context. This involves at least the following data:

  • Title and/or company
  • First and last name
  • Address (street, house number, post code, town, country)
  • Further contact details (email address, telephone number)
  • Credit card data, if applicable
  • Data that is required to book a flight trip due to the requirements of the airline or the authorities
  • Data about fellow travellers
  • Other data such as place of boarding when travelling by bus to Spain, desired parking space, body size when renting bicycles, etc.

The mandatory entries are marked with an asterisk (*). Failure to provide this information may hinder the provision of our services. Providing other information is optional and has no influence on the use of our websites.

The legal basis for the processing of the aforementioned data is the fulfilment of a contract within the meaning of Art. 6 para. 1 (b) of the GDPR.

f. Competition forms

From time to time we organise competitions, sweepstakes or similar events. In the event of participation, we will then process your contact data and details for the implementation of the competitions and prize draws and, if necessary, also later for communication with you in this context and for advertising purposes. Further details can be found in the respective conditions of participation. 

g. Job ads

If you send us your application documents on our online job advertisements, we will collect and process your application data electronically for the purpose of processing the application procedure. If your application is followed by the conclusion of an employment contract, your transmitted data may be stored by us in your personnel file for the purpose of the usual organisational and administrative process in compliance with the relevant legal regulations. If you voluntarily tell us things about yourself beyond what is necessary, this is done within the framework of a consent in accordance with Art. 6 para. 1 s. 1 (a) of the GDPR. Within the framework of processing, your data may be transferred to persons within our company, as well as service providers who are contractually bound and bound to secrecy and who perform partial tasks of data processing.

2. Use of your data for advertising purposes

a. Creation of pseudonymised usage profiles

In order to provide you with personalised services and information on our websites (on-site targeting), we use and analyse the data we collect about you when you visit the websites. If necessary, cookies may also be used for the corresponding processing (see section on this further below). 6). The analysis of your user behaviour can lead to the creation of a usage profile. The usage data is merged only with pseudonymous personal data, but never with non-pseudonymised personal data.

Facebook
Terms of Use
Privacy policy

To enable personalised marketing in social networks, we include remarketing pixels from Facebook on our websites. If you have an account with a social network that is linked to this site and are logged in at the time you visit the site, this pixel links the site visit to your account. Log out of your account before visiting the site in order to prevent a link. You can make further settings for advertising in the respective social networks in your user profile. We base the creation of pseudonymised user profiles for advertising and analysis purposes on a legitimate interest as defined in Art. 6 para. 1 (f) of the GDPR. This applies to all listed data processing operations in this No.  2. The legitimate interest is in direct marketing and analysis of the use of our website.

b. Re-Targeting

We use re-targeting technologies on our websites. Your user behaviour on our websites is analysed in order to be able to offer you advertising tailored to your individual needs on partner websites. Your user behaviour is recorded pseudonymously.

Most re-targeting technologies work with cookies (see No. 6 below).

Google Adwords Remarketing
Terms of Use
Privacy policy

These websites use Google AdWords Remarketing Pixel and Google AdWords Conversion Pixel, services of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043,USA ("Google"), to serve ads based on the use of previously visited websites. The information generated by the cookie about your visit to this website (including your IP address) will be transmitted to and stored by Google on servers in the United States and elsewhere (for transfers of personal data to the United States, please refer No. 9 below for additional information).

Google will use this information to evaluate your use of the website with regard to the advertisements, to compile reports on website activities and advertisements for website operators and to provide others with website and internet use related services. Google may also transfer this information to third parties as required by law or if said third parties process this data on behalf of Google. 

We also use Google Tag Manager to manage usage-based advertising services. The Tag Manager tool itself (which implements the tags) is a cookieless domain and does not collect any personal data. Rather, the tool triggers other tags that may in turn collect data (see above). If deactivation occurs at domain or cookie level, it remains in use for all tracking tags, insofar as they are implemented with Google Tag Manager.

Bing conversion tracking
Terms of Use
Privacy policy

Our websites also use conversion tracking of Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). Microsoft Bing Ads will place a cookie on your computer if you have accessed our website via a Microsoft Bing ad. Microsoft Bing and we can see in this way that someone has clicked on an ad, has been redirected to our web pages and has reached a predetermined target page. We only see the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No personal information about the identity of the user will be disclosed. 

You can prevent the re-targeting at any time by rejecting or deactivating the relevant cookies in the menu bar of your web browser (see section on this topic). below). You can also apply for an opt-out for the other advertising and retargeting tools mentioned on the Digital Advertising Alliance website at optout.aboutads.info.

3. Disclosure of data to third parties

We only pass on your personal data if you have expressly consented, if there is a legal obligation or if this is necessary for the enforcement of our rights, in particular for the enforcement of claims arising from the relationship between you and POSCOM Tour Operating AG. 

In particular, we may pass on your data within the Group to other Group companies, in particular our hotels, for administration and for the various processing purposes. 

Furthermore, we pass on your data to third parties as far as this is necessary in the context of the use of the web pages for the provision of the services requested by you as well as the analysis of your user behaviour. Insofar as this is necessary for the purposes mentioned in sentence 1, the transfer may also take place abroad. If the websites contain links to third-party websites, POSCOM Tour Operating AG no longer has any influence on the collection, processing, storage or use of personal data by the third party after clicking on these links and accepts no responsibility for this.

Please note that when you book a trip with us, we will pass on your personal data to the transport companies (especially bus companies, airlines, etc.) and other service providers (external tour operators, car rental companies, etc.) depending on the content of the booking. The responsibility for your data is then incumbent on these recipients. Especially in connection with air travel, it may also be necessary for us or the airlines to pass on the data of your trip to the respective authorities. 

Finally, we may disclose your personal data to third parties (e.g. authorities in Switzerland and abroad) if this is required by law. We also reserve the right to process your personal data in order to comply with a court order or to assert or defend legal claims if we transfer claims against you to other companies (e.g. debt collection) or if we consider it necessary for other legal reasons.

4. Transmission of personal data abroad

POSCOM Tour Operating AG is entitled to transfer your personal data to third parties (contracted service providers) abroad if this is necessary for the data processing described in this data protection declaration. These are obliged to the same extent as we ourselves to data protection. If the level of data protection in a country does not correspond to that in Switzerland or Europe, we contractually ensure that the protection of your personal data corresponds at all times to that in Switzerland or the EU.

5. Data security

We use appropriate technical and organisational security measures to protect your stored personal data against manipulation, partial or complete loss, as well as against unauthorised access. Our security procedures are continually enhanced as new technology develops. 

You should keep your access information confidential and close the browser window when you have finished your session, especially if your computer is also used by other people.

We also take internal company privacy very seriously. Our employees and the service providers appointed by us are sworn to secrecy and to comply with data protection regulations.

6. Cookies

Cookies help in many ways to make your visit to our website easier, more pleasant and more meaningful. Cookies are information files that your web browser automatically stores on your computer's hard drive when you visit our websites. Cookies neither damage the hard disk of the computer, nor do they transmit any personal data of the user to us.

For example, we use cookies to better tailor the information, offers and advertising displayed to your individual interests. The use does not result in us receiving new personal data about you as an online visitor. Most internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer, or a message always appears before a new cookie is created.

Disabling cookies may prevent you from using all the features of our website.

7. Google Analytics tracking tool

Google Analytics
Terms of use
Privacy policy

On our web pages we use Google Analytics, a web analysis service of Google Inc. ("Google"). With this tracking tool your surfing behaviour on our websites is monitored. This monitoring is carried out for the purpose of demand-oriented design and continuous optimisation of our websites. 

Google Analytics uses "cookies", which are text files stored on your computer. These enable the analysis of your website use. The information regarding your use of these websites and online services which is generated by the cookies will be forwarded to a Google server in the USA and stored there. Google will use this information to evaluate your use of the website, to compile reports on website activities for website operators and to provide others with website and internet related services. Google may also pass this information on to third parties in so far as this is required by law or if third parties process the data on Google's behalf.

Google will, under no circumstances, associate your IP address with any other data held by Google. These websites also always use Google Analytics with the extension " anonymizeIP ", so that IP addresses are only processed further in order to exclude a direct reference to your person. This extension ensures that no detailed IP address data is collected from you when you visit the website.

You may block the use of cookies by selecting the appropriate settings in your browser. However, please be advised that if you opt out of using cookies, you may not be able to use all the features of this website to their fullest extent.

By using this website, you agree that the data that Google collects about you may be processed as described above and for the purpose described above.

If you do not want Google to receive data from your browser when you visit the pages, you can find the link to the OptOut solution for Google Analytics here (tools.google.com/dlpage/gaoptout). This plug-in prevents the browser from requesting the Analytics code, so that Google does not receive any data when you access the page. The plug-in is available for different browser types. According to Google, the browser blocks the Google Analytics script after installation.

If there is no such plug-in for your browser (e.g. because you visit this website using a mobile device), you can prevent the collection of data by clicking the following link: Google Analytics deactivate. javascript:gaOptout()

This sets what is referred to as an OptOutCookie, which prevents the future collection of your data when you visit this website (only applies to the current browser). For the OptOutCookie to function properly, your browser must be set so that this cookie can be stored permanently.

8. Links on our web pages

If the websites contain links to third-party websites, such as Instagram, Facebook, YouTube, Flickr or other websites, POSCOM Tour Operating AG no longer has any influence on the collection, processing, storage or use of personal data by the operators of these websites after clicking on these links and accepts no responsibility for this. Please therefore observe the respective data protection regulations of these web pages.

9. Note on data transmission to the USA

For the sake of completeness, we would like to point out that in the USA, the surveillance measures of US authorities allow the general storage of all personal data of all persons whose data has been transmitted from the EU or Switzerland to the USA. This is done without differentiation, restriction or exception with respect to the aim pursued and without an objective criterion that would make it possible to restrict the US authorities' access to data and its subsequent use to very specific, strictly limited purposes which justify the interference associated with both access to, and use, of such data. Furthermore, we would like to point out that, in the USA, there are no legal remedies available to data subjects that would allow them to gain access to the data concerning them and to obtain its correction or deletion, and that there is no effective legal protection against general access rights by US authorities. We explicitly point out this legal and factual situation to the person concerned in order to make an appropriately informed decision to consent to the use of his data.

Users residing in an EU Member State are advised that the US does not have an adequate level of data protection from the point of view of the European Union, partly because of the issues mentioned in this section. To the extent that we have stated in this Privacy Policy that recipients of data (such as Google or Facebook) are located in the United States, we will ensure that your data is protected at an appropriate level with our partners either by contractual arrangements with these companies or by ensuring that these companies are certified under the EU-US Privacy Shield.

10. Right of access, rectification, cancellation and restriction of processing; right to data transferability

You have the right, upon request and free of charge, to receive information about the personal data that we store about you. In addition, you have the right to correct incorrect data and to have your personal data deleted, insofar as this does not conflict with any legal obligation to retain data or an event of authorisation which allows us to process the data. In accordance with Articles 18 and 21 of the GDPR, you also have the right to demand a restriction on data processing and to object to data processing.

You also have the right to reclaim from us the data that you have provided to us (right of data portability). Upon request, we will also pass the data on to a third party of your choice. You have the right to receive the data in a common file format.

You can contact us for the above-mentioned purposes via the email address datenschutz(at)ferienverein.ch Your contact person is POSCOM Tour Operating AG, Tscharnerstrasse 37, 3007 Berne, Switzerland.

Our Data Protection Officer is also available to you for contacts from the EU area under the email: datenschutz(at)ferienverein.ch

We may, at our sole discretion, require proof of identity to process your applications.

You can also tell us what to do with your data after your death by giving us appropriate instructions.

11. Storage of data

We store personal data only as long as necessary

  • to use the tracking, advertising and analysis services mentioned above within the scope of our legitimate interest;
  • to carry out services to the extent mentioned above, which you have requested or for which you have given your consent (e.g. for newsletters in accordance with No. 1 (d);
  • to meet our legal compliance obligations.

We keep contractual data for a longer period of time, as this is prescribed by legal storage obligations. Storage obligations, which oblige us to store data, result from accounting regulations and tax regulations. According to these regulations, business communications, contracts concluded and accounting records must be kept for up to 10 years. If we no longer need this data to perform the services for you, the data will be blocked. This means that the data may then only be used for accounting and tax purposes.

12. The right of appeal to a data protection supervisory authority

If you reside in an EU country, you have the right to complain to a data protection supervisory authority at any time.

13. Changes to this Data Protection Declaration

We reserve the right to change the Data Protection Declaration at any time in order to adapt it to a changed legal situation or to changes in our services or data processing. In general, the Data Protection Declaration in its current version at the beginning of the respective processing applies to data processing.

14. Governing law

The use of our web pages and the use of our services are subject to Swiss law. The place of jurisdiction is Berne.

 
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