Privacy statement
pursuant to Art. 13 of REGULATION (EU) 2016/679
of the company Kaja S.N.C di Katharina Sparer & Jan Waldner ("Company"), with its registered office in Campi al Lago 14, I-39051 Vadena.
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Table of contents
1. General information
2. Visiting our website
3. Contacting us via our contact forms on the website, contacting us via e-mail, calling us ("contacting us")
4. Integration of services and contents of third parties
5. The protection of minors
6. Your rights
7. Contact information
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1. General information
1.1 The protection of your personal data is of particular concern to us. We therefore process your data exclusively on the basis of the EU General Data Protection Regulation No. 679/2016 (hereinafter, "GDPR"), as well as the Italian Legislative Decree No. 196/2003.
1.2 In this privacy policy, we inform you about the most important aspects of data processing when you contact us and when you use our services via our internet site www.leuchtenburg.it (hereinafter, "internet site" or "website").
1.3 All terms used in this privacy policy have the meaning defined in the legal sources mentioned in point 1.1.
1.4 Information about the use of cookies on this website can be found in our cookie declaration.
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2. Visiting our website
2.1 When you visit our website, your IP address is collected, the pages you visit, the time of your request, the amount of data transmitted, the type of operating system you use, the navigation path and other data are stored.
Without the collection of the aforementioned data, our website cannot be accessed.
2.2 The following purposes are pursued with the processing of the above-mentioned data:
a. To display the website;
b. To ensure the protection of our rights, property and safety and those of third parties. In this regard, it should be noted that the website hosting company may collect the IP address through an automated process whenever our website is accessed if there is reasonable suspicion of unlawful access (e.g. hacker attack).
2.3 The processing of your data is based on the following lawful grounds:
a. When you visit our website, you give your consent to the collection of the above-mentioned personal data;
b. Furthermore, the processing is carried out within the framework of our legitimate interests. This consists of maintaining our IT security, protecting our rights and those of third parties, as well as our interest in making our website more user-friendly.
2.4 The personal data will be passed on to the following third parties:
Processor | Categories of data transmitted | Purpose of the transmission |
Hosting/Cloud provider/etc. | All categories of personal data mentioned under point 2.1 | System maintenance, improvement and upkeep of the IT system |
External IT consultants | All categories of personal data mentioned under point 2.1 | System maintenance, improvement and upkeep of the IT system |
Your personal data will not be transferred outside the European Economic Area.
2.5 Personal data is deleted as soon as it is no longer required to fulfil the purpose. In exceptional cases, e.g. to block an IP address, certain data may be retained for a longer period of time if we have a legitimate interest in doing so.
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3. Contacting us via our contact forms on the website, contacting us via e-mail, calling us ("contacting us")
3.1 When you contact us, we collect, on a case-by-case basis, your first and last name, email address, place of residence, telephone number and any other additional information and content that you submit, upload or share.
3.2 The aforementioned data form the basis for our offer and for answering any questions, without which we cannot offer our service.
3.3 Any additional personal data provided by you in the course of contacting us, which may include special categories of personal data, will be evaluated by us and processed only in the event that they are necessary for the execution of your order. Otherwise, they will be immediately and irrevocably deleted.
3.4 The following purposes are pursued with the processing of the above-mentioned data:
a. To inform you about services and products;
b. To communicate offers, availability of rooms, quotations, to book stays/vacations/vouchers and to invoice accordingly;
c. To let you participate in a competition, if you request so;
d. To be able to integrate our services, such as the leisure offer with those of third parties;
e. To tailor our services to your preferences, such as food and entertainment;
f. To allow you access to our website areas for registered users;
g. To comply with any other legal obligations.
3.5 The processing of your data is based on the following lawful grounds:
a. When contacting us, you give your implicit consent to the processing of the above-mentioned also special categories of personal data, which in this case are processed on the basis of the lawfulness ground "contract" upon your request.
b. Processing may also take place on the basis of a legal obligation (such as official reporting obligations regarding guests, tax legislation, etc.).
3.6 Personal data may be disclosed to the following third parties:
Processor | Categories of data transmitted | Purpose of the transmission |
External IT consultant | All data stored in our IT system | System maintenance, improvement and upkeep of the IT system |
Accounting | Invoice data | Fulfilment of obligations under tax law |
E-mail provider | All data transmitted when contacting us | Purposes mentioned under 3.4 |
Hotel software | All data transmitted when contacting us | Purposes mentioned under 3.4 |
Your personal data will not be transferred outside the European Economic Area.
3.7 Personal data will be deleted as soon as it is no longer necessary for the fulfilment of the above-mentioned purposes.
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4. Integration of services and contents of third parties
4.1 Based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer), we use service and content offers from third-party providers within our online offer in order to integrate their content and services (hereinafter uniformly referred to as "services/content").
This always requires that the third-party providers of these services/content are aware of the IP address of the user, as without the IP address they would not be able to send the services/content to their browser. The IP address is therefore necessary for the execution of the services or display of this content. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may use so-called tracking codes and pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Tracking codes and "pixel tags" can be used to analyse 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
a. Google Analytics
Google Analytics may be integrated within our online offer. Google Analytics is a web analysis service offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
The information collected by Google Analytics about your use of this website is generally transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymisation on these websites, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.
You can prevent the collection by Google Analytics by downloading and installing the browser plug-in available under the following link: Browser add-on to disable Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=en).
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). For more information on Google's use of data, settings and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).
b. Google Ads Remarketing
We use Google Remarketing to re-link users of the Google Display network. Google uses cookies, which are stored on your computer, to enable analysis of your use of the website. The information generated by the cookie on the use of the website (including your IP address) will be sent to a Google server in the United States and stored there. Google then removes the last three digits from the IP address; it is therefore no longer possible to assign it to a unique IP address. Google respects the privacy policy of the “USA Safe Harbor” agreement and is registered with the “Safe Harbor” program of the United States Department of Commerce. Google will use this information to assess the website use, compile reports on the website’s activities for the website operators and provide other services connected with the use of the website and the internet. Google can also transfer this information to third parties if required by law or if such third parties process this information on behalf of Google. Third party suppliers, including Google, display ads on internet sites. Third party suppliers, including Google, use the stored cookies to show ads on the basis of previous visits by a user of this site. Google will not associate your IP address with any other data held by Google. The collection and archiving of data may be withdrawn at any time with future effect. Google’s use of cookies can be deactivated by visiting the page for deactivating Google ads. However, please note that in this case you may not be able to use all the functionalities of this website. By using this site you agree to the processing of your data by Google for the procedures described above and for the above-mentioned purposes. The collection and archiving of data may be withdrawn at any time with future effect.
Remarketing is not used on sensitive content of the site with personal data.
c. Google Ads Conversion
This website also uses Google Conversion Tracking. Here, a cookie is set on the computer by Google Ads, if you have reached our site via a Google ad. These cookies expire after 30 days and are not used for personal identification. If the user visits particular pages on the site of an Ads customer, Google and the customer can see that the user has clicked on an ad and has been redirected to this page. Every Ads advertiser receives a different cookie. Cookies cannot therefore be monitored on the advertisers’ websites. Information obtained via cookie conversion information is used to create conversion statistics for Ads customers who have opted for conversion monitoring. Advertisers know the total number of users who have clicked on their ad and have been directed to a page which has a conversion-tracking-tag. However, they will not receive information with which it might be possible to identify the users personally. The collection and archiving of data may be withdrawn at any time with future effect.
d. Conversion measurement and Custom Audience with the Facebook Pixel:
The Facebook Pixel is a JavaScript code used for tracking and optimising conversions as well as for the definition of remarketing target groups (Custom Audience).
Conversion tracking allows following a user’s path on the website by means of a specific tracking code which is personalised on the basis of target indicators.
The Custom Audience is a targeting option by which the users who visited a website can be reached on Facebook. It is possible to automatically group these users through the specific actions on the website. Such information is forwarded to Facebook via tracking code.
During this process the Facebook ID is also detected. Please be informed that the personal data of each individual user are encrypted locally in the system and remain anonymous to us. Data are thus forwarded securely to Facebook, where they are stored and processed. However, Facebook may link them to your Facebook account and utilise them for its own promotional purposes, in compliance with Facebook’s privacy policy. For further information on Facebook’s data use policy, please visit: https://www.facebook.com/about/privacy/.
The encrypted data are used for matching purposes only; they are not shared with third parties or other advertisers and are deleted immediately upon completion of the matching process.
If you wish to deny your consent to the use of the Facebook Pixel, please visit: https://www.youronlinechoices.eu
e. Vimeo Plugins
We use the provider Vimeo, among others, for the integration of videos. Vimeo is operated by Vimeo, LLC with headquarters at 555 West 18th Street, New York, New York 10011.
On some of our pages, we use plugins from the provider Vimeo. When you call up the Internet pages of our website that are provided with such a plugin - for example, our media library - a connection is established to the Vimeo servers and the plugin is displayed. This transmits to the Vimeo server which of our Internet pages you have visited. If you are logged in as a Vimeo member, Vimeo assigns this information to your personal user account. When using the plugin, such as clicking on the start button of a video, this information is also assigned to your user account. You can prevent this assignment by logging out of your Vimeo user account before using our website and deleting the corresponding cookies from Vimeo.
Further information on data processing and notes on data protection by Vimeo can be found at https://vimeo.com/privacy.
f. ADDITIVE+ VOUCHERS
On our website you have the possibility to buy vouchers by using the integrated voucher software. To process your purchase and to save and store your data we use software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”) in the context of voucher marketing. Through the use of these services and systems your data will be processed and stored in the EU.
The data you provide is required to fulfil the contract or to carry out pre-contractual measures. Without this data we cannot conclude a contract with you. The data will not be transferred to an outside third party, except for your credit card data which will be transferred to the payment provider and to our tax accountant to fulfil our tax obligations.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) and/or lit b (processing necessary for the performance of a contract) of the GDPR.
g. 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 s.n.c., 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.
h. SÜDTIROL ALTO ADIGE GUEST PASS
Purpose: The personal data provided will be transmitted to the single coordinating body of the Guest Pass in order to enable the creation and use of the Guest Pass and to provide the associated services.
Recipient: In connection with the issue of the Guest Pass, your data will be transmitted to the Mobilitätskonsortium, VAT Nr. 02735170215, which acts as the cardholder and unified coordinating body and assumes the role of autonomous data controller in processing the transferred data. For further information regarding the processing to which the data will be subjected, you can send an email to privacy@moko.bz.it.
Legal basis: The legal basis for processing is Art. 6 (1) (b) of the GDPR.
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5. The protection of minors
5.1 We do not offer our services to minors under the age of 14. If you are responsible for the supervision of a person under the age of 14 and notice that the minor has transmitted data to us without our consent, please contact us immediately [email: info@leuchtenburg.it; tel.: +39 0471 960 093] so that we can take the legal measures in the minor's interest.
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6. Your rights
6.1 You are generally entitled to the rights of access, rectification, deletion, restriction, data portability, revocation and objection pursuant to Art. 15-22 of Regulation 2016/679.
Of course, you have the right to revoke your consent to receive the newsletter at any time (for example, via the opt-out function in the newsletter footer).
6.2 If you revoke your consent to data processing, this will not affect the lawfulness of the data processing prior to the revocation. In certain cases, your personal data may still be processed by us after your revocation; however, this will only be the case if there is a lawful reason other than consent. You can object to direct marketing at any time.
6.3 You have the right at any time to contact the national data protection authority (www.garanteprivacy.it) and lodge a complaint if you believe that your data is not processed in accordance with the purposes listed in this information document and on the basis of the grounds of lawfulness set out accordingly.
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7. Contact information:
For any questions regarding the processing of your personal data, please contact us at the following address:
Kaja S.N.C di Katharina Sparer & Jan Waldner
Legal representative: Katharina Sparer
Address: Campi al Lago 14, I-39051 Vadena
E-mail address: info@leuchtenburg.it
Tel.: +39 0471 960 093