Privacy Policy

1. Data Protection at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data refers to any data that can be used to personally identify you. Detailed information on the subject of data protection can be found in our Privacy Policy set out below.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the section „Information on the Controller“ in this Privacy Policy.

How do we collect your data?

Some data is collected when you provide it to us. This may include, for example, data that you enter into a contact form.

Other data is collected automatically or after you have given your consent when you visit this website through our IT systems. This primarily includes technical data (e.g. internet browser, operating system, or the time the page was accessed). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders, or other inquiries relating to contractual services.

What rights do you have regarding your data?

You have the right at any time to receive free information about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you may revoke this consent at any time with effect for the future. Furthermore, under certain circumstances, you have the right to request the restriction of the processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time if you have further questions regarding data protection.

Google Analytics

This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland („Google“). Google Analytics is integrated via the WordPress plugin „MonsterInsights“. The service collects information such as the number of visits to our website, the pages viewed, and the amount of time visitors spend on the site. Google Analytics uses cookies and other browser technologies to analyze user behavior and recognize returning users. This information is used, among other things, to compile reports on website activity.

Google Analytics enables us to analyze and statistically evaluate the behavior of website visitors. Among other things, the following data is processed:

Pages visited
Time spent on the site
Click paths
Technical information about the device used (e.g. browser, operating system, screen resolution)
Approximate geographic location (region/country)
Referrer URL

Google Analytics uses cookies and comparable technologies to recognize users.

Legal Basis

Processing is carried out exclusively on the basis of your consent pursuant to Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG.

You may withdraw your consent at any time with effect for the future (e.g. via the consent management tool used on this website).

IP Anonymization

IP anonymization is enabled by default in Google Analytics 4.

Your IP address is shortened within the European Union or the European Economic Area before any further processing takes place.

Transfer of Data to Third Countries

A transfer of personal data to the United States cannot be ruled out.

Google is certified under the EU-U.S. Data Privacy Framework (DPF). Data transfers are therefore based on the adequacy decision of the European Commission pursuant to Art. 45 GDPR.

In addition, Standard Contractual Clauses (SCCs) pursuant to Art. 46 GDPR have been concluded with Google.

Further information on Google’s privacy practices can be found at:
https://policies.google.com/privacy.

Storage Period

The data we send and that is linked to cookies is automatically deleted after 14 months (configured in our Google Analytics account).

Google Tag Manager

Nature and Scope of Processing

We use Google Tag Manager, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is used to manage website tags via a central interface and enables us to precisely control the integration of services on our website.

This allows us to integrate additional services flexibly and to analyze how users interact with our website.

Purpose and Legal Basis

Google Tag Manager is used on the basis of your consent pursuant to Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG.

We intend to transfer personal data to third countries outside the European Economic Area, in particular to the United States. In cases where no adequacy decision by the European Commission exists (e.g. the United States), we have agreed with the recipients of the data on other appropriate safeguards within the meaning of Art. 44 et seq. GDPR. Unless otherwise stated, these safeguards consist of the European Commission’s Standard Contractual Clauses pursuant to Implementing Decision (EU) 2021/914 of 4 June 2021. A copy of these Standard Contractual Clauses is available at
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914.

In addition, before any such transfer to a third country, we obtain your consent pursuant to Art. 49 (1)(a) GDPR, which you provide via our consent manager (or other forms, registrations, etc.). Please note that transfers to third countries may involve risks that are not known in detail (e.g. processing of data by security authorities in the third country, the exact scope and consequences of which are unknown to us, beyond our control, and of which you may not become aware).

Storage Period

The specific storage period for the processed data is determined by Google Ireland Limited and is beyond our control. Further information can be found in the Google Tag Manager Privacy Policy:
https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/.

2. Hosting

We host the content of our website with the following provider:

External Hosting

This website is hosted externally. Personal data collected on this website is stored on the servers of the hosting provider(s). This may include, in particular, IP addresses, contact requests, metadata and communication data, contract data, contact details, names, website access data, and other data generated via a website.

External hosting is carried out for the purpose of fulfilling our contractual obligations towards potential and existing customers (Art. 6 (1)(b) GDPR) and in the interest of providing our online services securely, quickly, and efficiently through a professional provider (Art. 6 (1)(f) GDPR). Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Our hosting provider(s) will process your data only to the extent necessary to fulfill their contractual obligations and will follow our instructions regarding this data.

We use the following hosting provider:

Cloud56
IT56 GmbH
Bendorfer Straße 28
56191 Weitersburg
Germany

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) with the provider mentioned above. This is a contract required under data protection law, ensuring that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Information

Data Protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this Privacy Policy.

When you use this website, various personal data is collected. Personal data is any data that can be used to personally identify you. This Privacy Policy explains which data we collect, what we use it for, and how and for what purpose this is done.

Please note that data transmission over the Internet (e.g. communication by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the Controller

The controller responsible for data processing on this website is:

Hotel 41 GmbH
Emil-Schüller-Str. 41 – 43
56068 Koblenz
Germany

Phone: +49 261 30140
Email: info@hohenstaufen.de

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of processing personal data (e.g. names, email addresses, etc.).

Storage Period

Unless a more specific storage period has been specified within this Privacy Policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods required under tax or commercial law). In the latter case, deletion will take place once these reasons no longer apply.

General Information on the Legal Bases for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6 (1)(a) GDPR or Art. 9 (2)(a) GDPR if special categories of personal data pursuant to Art. 9 (1) GDPR are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g. via device fingerprinting), data processing is additionally based on Section 25 (1) TDDDG. Consent may be revoked at any time. If your data is required for the performance of a contract or for carrying out pre-contractual measures, we process your data on the basis of Art. 6 (1)(b) GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation pursuant to Art. 6 (1)(c) GDPR. Data processing may also be based on our legitimate interest pursuant to Art. 6 (1)(f) GDPR. The relevant legal basis applicable in each individual case is explained in the following sections of this Privacy Policy.

Recipients of Personal Data

As part of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of data. When using data processors, we only pass on our customers‘ personal data on the basis of a valid Data Processing Agreement (DPA). In the case of joint processing, a joint controller agreement is concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You may revoke your consent at any time. The legality of the data processing carried out before the revocation remains unaffected.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 (1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO ANY PROFILING BASED ON THOSE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 (1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL THEREAFTER NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21 (2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or the place of the alleged infringement. This right exists without prejudice to any other administrative or judicial remedies.

Right to Data Portability

You have the right to receive data that we process automatically on the basis of your consent or in fulfillment of a contract in a commonly used, machine-readable format, either for yourself or for transmission to a third party. If you request the direct transfer of the data to another controller, this will only be done where technically feasible.

Access, Rectification, and Erasure

Within the framework of the applicable legal provisions, you have the right at any time to obtain free information about your stored personal data, its origin, its recipients, and the purpose of the data processing, and, if applicable, a right to have this data corrected or deleted. You may contact us at any time regarding this or any other questions relating to personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing applies in the following cases:

If you contest the accuracy of your personal data stored by us, we generally require time to verify this. During the verification period, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was or is unlawful, you may request the restriction of processing instead of deletion.
If we no longer need your personal data, but you require it for the establishment, exercise, or defence of legal claims, you have the right to request restriction of processing instead of deletion.
If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data may – apart from being stored – only be processed with your consent or for the establishment, exercise, or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a Member State.

SSL or TLS Encryption

This website uses 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. You can recognize an encrypted connection by the browser’s address bar changing from „http://“ to „https://“ and by the lock symbol in your browser’s address bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to Promotional Emails

The use of contact data published within the scope of our legal notice obligations for sending unsolicited advertising and information material is hereby prohibited. The operators of this website expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam emails.

4. Data Collection on This Website

Cookies

Our website uses so-called „cookies.“ Cookies are small data packages and do not cause any damage to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted after your visit. Persistent cookies remain stored on your device until you delete them yourself or they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (third-party cookies). Third-party cookies enable the integration of certain third-party services within websites (e.g. cookies for processing payment services).

Cookies serve various functions. Many 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 may be used to analyze user behavior or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions requested by you (e.g. the shopping cart function), or to optimize the website (e.g. cookies used to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 (1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG); consent may be revoked at any time.

You can configure your browser to notify you when cookies are set and to allow cookies only in individual cases, to exclude the acceptance of cookies for specific cases or in general, and to activate the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.

If additional cookies or services are used on this website, you will find information about them in this Privacy Policy.

Server Log Files

The provider of this website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These include:

Browser type and browser version
Operating system used
Referrer URL
Hostname of the accessing computer
Time of the server request
IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6 (1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website. For this purpose, server log files must be collected.

Contact Form

If you send us inquiries via the contact form, the information you provide in the inquiry form, including the contact details you enter there, will be stored by us for the purpose of processing your inquiry and in case of follow-up questions. We do not pass this data on without your consent.

The processing of this data is based on Art. 6 (1)(b) GDPR if your inquiry is related to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Art. 6 (1)(f) GDPR) or on your consent (Art. 6 (1)(a) GDPR), where such consent has been requested. Consent may be revoked at any time.

The data you enter into the contact form will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your inquiry has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Inquiries by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of handling your request. We do not pass this data on without your consent.

The data you send to us via contact inquiries will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Newsletter

Newsletter Data

If you would like to subscribe to the newsletter offered on this website, we require an email address from you as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive the newsletter. No additional data is collected unless provided voluntarily. We use this data exclusively for sending the requested information and do not disclose it to third parties.

The processing of the data entered into the newsletter subscription form is carried out exclusively on the basis of your consent (Art. 6 (1)(a) GDPR). You may revoke your consent to the storage of your data, your email address, and its use for sending the newsletter at any time, for example via the „unsubscribe“ link included in every newsletter. The legality of the data processing already carried out remains unaffected by the revocation.

The data you provide for the purpose of subscribing to the newsletter will be stored by us or by the newsletter service provider until you unsubscribe from the newsletter. After you unsubscribe or once the purpose no longer applies, your data will be deleted from the newsletter distribution list. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6 (1)(f) GDPR.

Data stored by us for other purposes remains unaffected.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or by the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist is used solely for this purpose and is not merged with other data. This serves both your interests and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1)(f) GDPR). Storage in the blacklist is not limited in time. You may object to this storage if your interests outweigh our legitimate interest.

Brevo (formerly Sendinblue)

We use Brevo, a service provided by Brevo SAS, 106 Boulevard Haussmann, 75008 Paris, France.

Brevo is used for sending emails, communicating with customers, and managing contact data. If you contact us via a form, subscribe to our newsletter, or receive emails from us in connection with a booking or the purchase of a voucher, the personal data required for these purposes may be processed through Brevo.

The processing is carried out on the basis of Art. 6 (1)(a) GDPR (consent), Art. 6 (1)(b) GDPR (performance of a contract), or Art. 6 (1)(f) GDPR (legitimate interest), depending on the nature of the respective processing.

We have concluded a Data Processing Agreement (DPA) with Brevo.

6. Processing of Customer and Contract Data

We collect, process, and use personal data insofar as this is necessary for establishing, performing, or terminating a contractual relationship. This includes, in particular, your name, address, email address, telephone number, and booking and contract data.

The processing is carried out on the basis of Art. 6 (1)(b) GDPR and only to the extent necessary for the performance of the contract or for carrying out pre-contractual measures.

Data Transfer upon Conclusion of a Contract for Services and Digital Content

Contracts for hotel services and the purchase of digital vouchers can be concluded via our website. For the purpose of contract processing, we only transfer personal data to third parties to the extent necessary for the performance of the contract.

The processing is carried out on the basis of Art. 6 (1)(b) GDPR.

7. Plugins and Tools

Google Fonts (Local Hosting)

This website uses so-called Google Fonts provided by Google for the consistent display of fonts. The Google Fonts are installed locally. No connection to Google’s servers is established.

Further information about Google Fonts can be found at
https://developers.google.com/fonts/faq
and in Google’s Privacy Policy:
https://policies.google.com/privacy?hl=en.

Google Maps

This website uses the Google Maps mapping service. The provider is Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland. This service enables us to integrate maps into our website.

To use the functions of Google Maps, it is necessary to store your IP address. This information is generally transmitted to a Google server in the United States and stored there. The provider of this website has no influence over this data transfer. If Google Maps is activated, Google may use Google Fonts for the consistent display of fonts. When accessing Google Maps, your browser loads the required web fonts into its browser cache to display text and fonts correctly.

The use of Google Maps is in the interest of providing an attractive presentation of our online services and making the locations specified on our website easy to find. This constitutes a legitimate interest within the meaning of Art. 6 (1)(f) GDPR. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses (SCCs). Details can be found here:
https://privacy.google.com/businesses/gdprcontrollerterms/
and
https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

Further information on how Google handles user data can be found in Google’s Privacy Policy:
https://policies.google.com/privacy?hl=en.

The company is certified under the EU-U.S. Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the United States intended to ensure compliance with European data protection standards for data processing in the United States. Every company certified under the DPF is committed to complying with these data protection standards. Further information is available from the provider at the following link:
https://www.dataprivacyframework.gov/participant/5780.

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.

reCAPTCHA is used to verify whether data entered on this website (e.g. in a contact form) is entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of website visitors based on various characteristics. This analysis begins automatically as soon as the visitor accesses the website. For the analysis, reCAPTCHA evaluates various types of information (e.g. IP address, length of time the visitor spends on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run entirely in the background. Website visitors are not informed that an analysis is taking place.

In this context, Google acts solely as a data processor within the meaning of Art. 28 GDPR and will not use the data collected for its own purposes. The use of the tool is based on a Data Processing Agreement (DPA) concluded with Google.

The storage and analysis of the data are based on Art. 6 (1)(f) GDPR. The website operator has a legitimate interest in protecting its web services against abusive automated spying and spam. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

hCaptcha

We use hCaptcha (hereinafter „hCaptcha“) on this website. The provider is Intuition Machines, Inc., 2211 Selig Drive, Los Angeles, CA 90026, USA (hereinafter „IMI“).

hCaptcha is used to verify whether data entered on this website (e.g. in a contact form) is entered by a human or by an automated program. For this purpose, hCaptcha analyzes the behavior of website visitors based on various characteristics.

This analysis begins automatically as soon as a visitor accesses a website on which hCaptcha is activated. For the analysis, hCaptcha evaluates various types of information (e.g. IP address, length of time spent on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to IMI. If hCaptcha is used in „invisible mode“, the analyses run entirely in the background. Website visitors are not informed that an analysis is taking place.

Data processing is based on Standard Contractual Clauses (SCCs), which are included in IMI’s Data Processing Addendum to its General Terms and Conditions or in the applicable Data Processing Agreements.

Further information about hCaptcha can be found in the Privacy Policy and Terms of Service at the following links:
https://www.hcaptcha.com/privacy
and
https://hcaptcha.com/terms.

8. Applications

Handling Applicant Data

We offer you the opportunity to apply for positions with us by email.

If you send us an application, we process your personal data (e.g. contact details, application documents, and the information contained therein) to the extent necessary for carrying out the application process.

The processing is carried out on the basis of Section 26 BDSG and Art. 6 (1)(b) GDPR.

If no employment relationship is established, your application documents will be deleted no later than six months after completion of the application process, unless statutory retention obligations prevent deletion or you have expressly consented to a longer storage period.

Source:
https://www.e-recht24.de