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Privacy policy

With this privacy policy, we inform you which personal data we process in connection with our activities and operations, including our www.randolina.ch website. In particular, we inform you for what purposes, how and where we process which personal data. We also inform you about the rights of persons whose data we process.

For individual or additional activities and operations, further privacy policies and other legal documents such as General Terms and Conditions (GTC), terms of use or conditions of participation may apply.

We are subject to Swiss data protection law and, where applicable, to foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures an adequate level of data protection.

1. Contact addresses

Responsibility for the processing of personal data:

Hotel Chesa Randolina
Tomas & Tanija Courtin
Via da Baselgia 40
CH-7515 Sils-Baselgia
hotel@randolina.ch

We will point out if, in individual cases, there are other controllers responsible for the processing of personal data.

2. Terms and legal bases

2.1 Terms

Personal data is all information that relates to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, for example querying, matching, adapting, archiving, retaining, reading, disclosing, procuring, recording, collecting, deleting, disclosing, sorting, organising, storing, modifying, disseminating, linking, destroying and using personal data.

The European Economic Area (EEA) comprises the Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

2.2 Legal bases

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, FADP) and the Ordinance to the Federal Act on Data Protection (Data Protection Ordinance, DPO).

We process personal data – insofar and to the extent that the General Data Protection Regulation (GDPR) is applicable – on the basis of at least one of the following legal grounds:

  • Art. 6 para. 1 lit. b GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for carrying out pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the processing of personal data necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental freedoms and fundamental rights as well as the interests of the data subject. Legitimate interests include, in particular, our interest in being able to carry out our activities and operations on a permanent, user-friendly, secure and reliable basis and to communicate about them, ensuring information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the processing of personal data necessary for compliance with a legal obligation to which we are subject under the applicable law of Member States in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the processing of personal data necessary in order to protect the vital interests of the data subject or of another natural person.

3. Type, scope and purpose

We process those personal data that are necessary in order to be able to carry out our activities and operations on a permanent, user-friendly, secure and reliable basis. For example, to enable and carry out the guest’s booking; to conduct the guest’s stay; to tailor the stay to the guest’s wishes and interests; to be able to offer services in the future in line with the guest’s interests; marketing in connection with the hotel’s services and improvement of the hotel’s services. Such personal data may fall in particular into the categories of inventory and contact data, browser and device data, content data, meta or peripheral data and usage data, location data, sales data as well as contract and payment data.

We process personal data for the period that is necessary for the respective purpose or purposes or as required by law. Personal data whose processing is no longer necessary is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are in particular specialised providers whose services we use. For example, to service providers and their auxiliary persons who offer cloud-based software and data processing solutions for the hotel and, on behalf of the hotel, analyse and process the guest’s data (for the above purposes). We also ensure data protection with such third parties.

As a rule, we process personal data only with the consent of the data subjects. If and to the extent that processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to safeguard overriding interests.

Within this framework, we process in particular information that a data subject voluntarily transmits to us when contacting us – for example by letter post, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the persons transmitting the data are obliged to ensure data protection vis-à-vis these persons and to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, insofar and to the extent that such processing is permissible for legal reasons.

4. Applications

We process personal data about applicants insofar as it is necessary to assess their suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data result in particular from the information requested, for example in the context of a job advertisement. We also process those personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.

We process – insofar and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular in accordance with Art. 9 para. 2 lit. b GDPR.

5. Personal data abroad

As a rule, we process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, in particular in order to process it there or have it processed there.

We may export personal data to all countries and territories on earth as well as elsewhere in the universe, provided that the law in force there guarantees an adequate level of data protection in accordance with the decision of the Swiss Federal Council and – insofar and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with the decision of the European Commission.

We may transfer personal data to countries whose law does not guarantee adequate data protection if data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements for this are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. On request, we will gladly provide data subjects with information about any guarantees or provide a copy of any guarantees.

6. Rights of data subjects

6.1 Data protection claims

We grant data subjects all claims in accordance with the applicable data protection law. In particular, data subjects have the following rights:

  • Access: Data subjects may request information as to whether we process personal data about them and, if so, which personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
  • Rectification and restriction: Data subjects may have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
  • Erasure and objection: Data subjects may have personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data provision and data transfer: Data subjects may request the provision of personal data or the transfer of their data to another controller.

We may defer, restrict or refuse the exercise of the rights of data subjects within the legally permissible framework. We may draw the attention of data subjects to any requirements that must be met in order to exercise their data protection claims. For example, we may refuse to provide information in whole or in part with reference to trade secrets or the protection of other persons. For example, we may also refuse to erase personal data in whole or in part with reference to statutory retention obligations.

We may, in exceptional cases, provide for costs for the exercise of rights. We will inform data subjects in advance of any costs.

We are obliged to identify data subjects who request information or assert other rights by means of appropriate measures. Data subjects are obliged to cooperate.

6.2 Right to lodge a complaint

Data subjects have the right to enforce their data protection claims through legal action or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

Data subjects have – insofar and to the extent that the General Data Protection Regulation (GDPR) is applicable – the right to lodge a complaint with a competent European data protection supervisory authority.

7. Data security

We take appropriate technical and organisational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.

Access to our website is via transport encryption (SSL / TLS, in particular with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication is subject – like in principle all digital communication – to mass surveillance without cause and suspicion as well as other monitoring by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities.

8. Use of the website

8.1 Cookies

We may use cookies. Cookies – our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data do not have to be limited to traditional text-form cookies.

Cookies can be stored in the browser temporarily as “session cookies” or for a certain period as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies make it possible, in particular, to recognise a browser the next time our website is visited and thereby, for example, to measure the reach of our website. However, permanent cookies can also be used, for example, for online marketing.

Cookies can be deactivated in whole or in part and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request explicit consent to the use of cookies – at least insofar and to the extent necessary.

For cookies that are used for success and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

8.2 Server log files

For each access to our website, we may record the following information, insofar as it is transmitted from your browser to our server infrastructure or can be determined by our web server: date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including the amount of data transferred, last website accessed in the same browser window (referrer).

We store such information, which may also constitute personal data, in server log files. The information is necessary in order to be able to provide our website on a permanent, user-friendly and reliable basis and to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.

8.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when our website is visited. The same information as in server log files can be collected using tracking pixels.

9. Notifications and communications

We send notifications and communications by email and via other communication channels such as instant messaging or SMS.

9.1 Success and reach measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked. Such web links and tracking pixels can also record the use of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner as well as on a permanent, secure and reliable basis, according to the needs and reading habits of the recipients.

9.2 Consent and objection

As a rule, you must expressly consent to the use of your email address and other contact addresses, unless use is permitted for other legal reasons. For any consent, we use the “double opt-in” procedure where possible, i.e. you will receive an email with a web link that you must click to confirm so that no misuse by unauthorised third parties can occur. We may log such consents, including Internet Protocol (IP) address and date and time, for evidentiary and security purposes.

As a rule, you can object at any time to receiving notifications and communications such as newsletters. With such an objection, you can simultaneously object to the statistical recording of usage for success and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.

9.3 Service providers for notifications and communications

We send notifications and communications with the help of specialised service providers.

In particular, we use:

10. Social media

We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and terms of use as well as privacy policies and other provisions of the individual platform operators apply in each case. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, which include, for example, the right of access.

For our social media presence on Facebook, including the so-called Page Insights, we are – insofar and to the extent that the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights in order to be able to provide our social media presence on Facebook effectively and in a user-friendly manner.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook’s data protection officer can be found in the Facebook privacy policy. We have concluded the so-called “Controller Addendum” with Facebook and have thereby agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the page “Information about Page Insights”, including “Information about Page Insights data”.

11. Services of third parties

We use services from specialised third parties in order to be able to carry out our activities and operations on a permanent, user-friendly, secure and reliable basis. With such services, we can embed functions and content into our website, among other things. In the case of such embedding, the services used necessarily collect at least temporarily the Internet Protocol (IP) addresses of the users for technical reasons.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:

11.1 Digital infrastructure

We use services from specialised third parties in order to obtain the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

In particular, we use:

11.2 Contact options

We use services from selected providers in order to be able to communicate better with third parties such as potential and existing customers.

11.3 Appointment scheduling

We use services from specialised third parties in order to be able to schedule appointments online, for example for meetings. In addition to this privacy policy, any conditions of the services used that are directly visible, such as terms of use or privacy policies, also apply.

11.4 Audio and video conferences

We use specialised services for audio and video conferences in order to be able to communicate online. This enables us, for example, to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services such as privacy policies and terms of use apply in addition.

Depending on your life situation, we recommend that you mute your microphone by default and blur the background or display a virtual background when participating in audio or video conferences.

In particular, we use:

  • Microsoft Teams: Platform, among other things, for audio and video conferences; provider: Microsoft; Teams-specific information: “Privacy and Microsoft Teams”.
  • Skype: Audio and video conferences; Skype-specific providers: Skype Communications SARL (Luxembourg) / Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), in the United Kingdom and in Switzerland; information on data protection: “Skype legal”, “Privacy and security”.

11.5 Maps

We use services from third parties in order to be able to embed maps into our website.

In particular, we use:

11.6 Advertising

We use the option of displaying targeted advertising for our activities and operations with third parties such as social media platforms and search engines.

With such advertising, we particularly want to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our website to your profile there.

In particular, we use:

12. Extensions for the website

We use extensions for our website in order to be able to use additional functions.

In particular, we use:

  • Google reCAPTCHA: Spam protection (distinguishing between desired comments from humans and unwanted comments from bots and spam); provider: Google; Google reCAPTCHA-specific information: “What is reCAPTCHA?”.

13. Success and reach measurement

We endeavour to determine how our online offering is used. In this context, we may, for example, measure the success and reach of our activities and operations as well as the impact of third-party links to our website. However, we may also, for example, test and compare how different parts or versions of our online offering are used (“A/B testing” method). Based on the results of success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.

For success and reach measurement, the Internet Protocol (IP) addresses of individual users are stored in most cases. In this case, IP addresses are generally truncated (“IP masking”) in order to follow the principle of data minimisation through the corresponding pseudonymisation.

Cookies may be used and user profiles created for success and reach measurement. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. As a rule, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services where users are logged in may be able to assign the use of our online offering to the user account or user profile at the respective service.

In particular, we use:

14. Video surveillance

We use video surveillance to prevent criminal offences and to secure evidence in the event of criminal offences as well as to exercise our house rules. Insofar and to the extent that the General Data Protection Regulation (GDPR) is applicable, this constitutes overriding legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR.

We store recordings from our video surveillance for as long as they are required for securing evidence.

We may retain recordings and transmit them to competent authorities such as courts or law enforcement authorities on the basis of legal obligations, for the enforcement of our own legal claims and in the event of suspected criminal offences.

15. Final provisions

We created this privacy policy using the data protection generator from Datenschutzpartner.

We may amend and supplement this privacy policy at any time. We will inform about such amendments and supplements in an appropriate form, in particular by publishing the current privacy policy on our website.

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