This is a translation. Only the German version is legally binding.

With the following privacy policy we inform you which personal data we process in connection with our activities and operations, including our aparthotel-al-lago.ch website. In particular, we inform you about why, how and where we process which personal data. We also inform you about the rights of persons whose data we process.

Further privacy policies and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply to individual or additional activities and operations.

We are subject to Swiss data protection law and to any applicable 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 adequate data protection.

1. CONTACT ADDRESSES

Responsible for the processing of personal data:

Aparthotel Al Lago
Via Lungolago G. Motta 12
6600 Locarno
SWITZERLAND

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

1.1 DATA PROTECTION OFFICER OR DATA PROTECTION ADVISER

We have the following data protection officer or data protection adviser as a point of contact for data subjects and authorities for enquiries relating to data protection:

Daniel Heiserer
Aparthotel Al Lago
Via Lungolago G. Motta 12
6600 Locarno
SWITZERLAND

1.2 DATA PROTECTION REPRESENTATIVE IN THE EUROPEAN ECONOMIC AREA (EEA)

We have the following data protection representative in accordance with Art. 27 GDPR:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

The data protection representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries relating to the GDPR.

2. TERMS AND LEGAL BASES

2.1 TERMS

Personal data is any information relating 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, storing, reading, disclosing, obtaining, recording, collecting, deleting, revealing, arranging, organising, saving, 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 on Data Protection (Data Protection Ordinance, DPO).

If and to the extent that the General Data Protection Regulation (GDPR) applies, we process personal data on the basis of at least one of the following legal bases:

  • 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 the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the processing of personal data necessary to safeguard the legitimate interests of us or of third parties, unless the fundamental freedoms, fundamental rights and interests of the data subject prevail. Legitimate interests are in particular our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner 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 to comply with a legal obligation to which we are subject under any applicable law of member states of 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 to protect the vital interests of the data subject or of another natural person.

3. NATURE, SCOPE AND PURPOSE

We process the personal data that is necessary to be able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner. Such personal data may fall in particular into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data. We process personal data for the period required for the respective purpose or purposes or 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 transfer it to third parties. Such third parties are in particular specialised providers whose services we use. We also ensure data protection with such third parties.

We only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permitted, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, to safeguard our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.

Within this framework, we process in particular information that a data subject voluntarily provides to us when contacting us – for example by letter, e-mail, 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 transmitting persons are obliged to ensure data protection towards 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, if and to the extent that such processing is permitted for legal reasons.

4. PERSONAL DATA ABROAD

We generally process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer 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 and elsewhere in the universe, provided that the law there ensures adequate data protection according to a decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) applies – according to a decision of the European Commission.

We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. Exceptionally, 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 express consent of the data subjects or a direct connection with the conclusion or performance of a contract. On request, we will be happy to provide data subjects with information about any safeguards or provide a copy of any safeguards.

5. RIGHTS OF DATA SUBJECTS

5.1 DATA PROTECTION CLAIMS

We grant data subjects all claims under the applicable data protection law. Data subjects have in particular the following rights:

  • Information: Data subjects can request information as to whether we process personal data about them and, if so, which personal data is concerned. Data subjects also receive the information required to assert their data protection claims and to ensure transparency. This includes the processed personal data 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.
  • Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
  • Deletion and objection: Data subjects can have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
  • Data release and data portability: Data subjects can request the release of personal data or the transfer of their data to another controller.

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

Exceptionally, we may charge 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 with appropriate measures. Data subjects are obliged to cooperate.

5.2 RIGHT TO LODGE A COMPLAINT

Data subjects have the right to enforce their data protection claims through legal channels 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).

If and to the extent that the General Data Protection Regulation (GDPR) applies, data subjects have the right to lodge a complaint with a competent European data protection supervisory authority.

6. DATA SECURITY

We take appropriate technical and organisational measures to ensure a level of 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 the Hypertext Transfer Protocol Secure, HTTPS for short). Most browsers indicate transport encryption with a padlock in the address bar.

Like basically all digital communication, our digital communication is subject to mass surveillance without cause or suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police authorities and other security authorities.

7. USE OF THE WEBSITE

7.1 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 is stored in the browser. Such stored data does not have to be limited to traditional cookies in text form.

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

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

For cookies used for performance 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).

7.2 SERVER LOG FILES

For each access to our website, we may record the following information, provided that it is transmitted by 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, website last accessed in the same browser window (referer or referrer).

We store such information, which may also constitute personal data, in server log files. The information is necessary to be able to provide our website permanently, in a user-friendly and reliable manner 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.

7.3 TRACKING PIXELS

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those of third parties whose services we use – are small, usually invisible images that are retrieved automatically when you visit our website. Tracking pixels can record the same information as server log files.

8. NOTIFICATIONS AND COMMUNICATIONS

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

8.1 PERFORMANCE AND REACH MEASUREMENT

Notifications and communications may contain web links or tracking pixels that record whether an individual communication was opened and which web links were 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 use for performance and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner, as well as permanently, securely and reliably, based on the needs and reading habits of the recipients.

8.2 CONSENT AND OBJECTION

In principle, you must expressly consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure wherever possible, i.e. you will receive an e-mail 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 the Internet Protocol (IP) address as well as the date and time, for reasons of evidence and security.

In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement. Necessary notifications and communications in connection with our activities and operations remain reserved.

8.3 SERVICE PROVIDERS FOR NOTIFICATIONS AND COMMUNICATIONS

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

9. SOCIAL MEDIA

We are present on social media platforms and other online platforms in order to be able to communicate with interested persons and to inform them 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 the privacy policies and other provisions of the individual operators of such platforms also apply. 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 to information.

For our social media presence on Facebook, including the so-called Page Insights, we are – if and to the extent that the General Data Protection Regulation (GDPR) applies – 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 nature, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and of Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Controller Addendum" with Facebook and thereby agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information about Page Insights", including "Information about Page Insights data".

10. THIRD-PARTY SERVICES

We use the services of specialised third parties in order to be able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content in our website. With such embedding, the services used record the Internet Protocol (IP) addresses of users at least temporarily for technically compelling 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 aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:

  • Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and in Switzerland; General information on data protection: "Privacy and security principles", privacy policy, "Google is committed to complying with applicable data protection laws", "Privacy guide for Google products", "How we use data from sites or apps that use our services" (information from Google), "Types of cookies and other technologies used by Google", "Personalised advertising" (activation / deactivation / settings).
  • Microsoft services: Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), in the United Kingdom and in Switzerland; General information on data protection: "Privacy at Microsoft", "Privacy (Trust Center)", privacy statement, privacy dashboard (data and privacy settings).

10.1 DIGITAL INFRASTRUCTURE

We use the services of specialised third parties in order to be able to use 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:

  • exigo: Hosting; Provider: exigo ag (Switzerland); Information on data protection: privacy policy, "Data protection / security".

10.2 CONTACT OPTIONS

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

10.3 AUDIO AND VIDEO CONFERENCES

We use specialised services for audio and video conferences in order to be able to communicate online. We can use them, for example, to hold virtual meetings or to 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, also apply.

Depending on your personal situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.

In particular, we use:

  • Microsoft Teams: Platform for, among other things, audio and video conferences; Provider: Microsoft; Teams-specific information: "Privacy and Microsoft Teams".

10.4 SOCIAL MEDIA FUNCTIONS AND SOCIAL MEDIA CONTENT

We use third-party services and plugins in order to be able to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.

In particular, we use:

  • Instagram platform: Embedding of Instagram content; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Information on data protection: privacy policy (Instagram), privacy policy (Facebook).

10.5 MAPS

We use third-party services in order to be able to embed maps in our website.

In particular, we use:

  • Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: "How Google uses location information".

10.6 DIGITAL AUDIO AND VIDEO CONTENT

We use the services of specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.

In particular, we use:

  • YouTube: Video platform; Provider: Google; YouTube-specific information: "Privacy and Safety Center", "My data on YouTube".

10.7 FONTS

We use third-party services in order to be able to embed selected fonts as well as icons, logos and symbols in our website.

In particular, we use:

  • Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: "Privacy and Google Fonts", "Privacy and data collection".

10.8 ADVERTISING

We use the possibility of having targeted advertising for our activities and operations displayed by third parties such as social media platforms and search engines.

With such advertising, we would like to reach in particular people who are already interested in our activities and operations or who could 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 logged in as a user may be able to assign the use of our online offering to your profile there.

In particular, we use:

  • Facebook advertising (Facebook Ads): Social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Information on data protection: remarketing and targeting in particular with the Facebook pixel as well as Custom Audiences including Lookalike Audiences, privacy policy, "Ad preferences" (login as a user required).
  • Google Ads: Search engine advertising; Provider: Google; Google Ads-specific information: advertising based on, among other things, search queries, with various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – being used for Google Ads, "Advertising" (Google), "Why am I seeing a particular ad?".
  • Instagram Ads: Social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Information on data protection: remarketing and targeting in particular with the Facebook pixel as well as Custom Audiences including Lookalike Audiences, privacy policy (Instagram), privacy policy (Facebook), "Ad preferences" (Instagram) (login as a user required), "Ad preferences" (Facebook) (login as a user required).
  • LinkedIn Ads: Social media advertising; Providers: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Information on data protection: remarketing and targeting in particular with the LinkedIn Insight Tag, "Privacy", privacy policy, cookie policy, objection to personalised advertising.
  • Microsoft Advertising: Search engine advertising on Bing, DuckDuckGo and Yahoo!; Provider: Microsoft; Microsoft Advertising-specific information: "Microsoft Advertising privacy policies", "Microsoft Advertising policies: legal, privacy and security", "Advertising settings" (objection to personalised advertising).

11. PERFORMANCE AND REACH MEASUREMENT

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

For performance 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 may be created for performance and reach measurement. Any user profiles created 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. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which 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:

  • Google Analytics: Performance and reach measurement; Provider: Google; Google Analytics-specific information: measurement also across different browsers and devices (cross-device tracking) and with pseudonymised Internet Protocol (IP) addresses, which are only transferred in full to Google in the USA in exceptional cases, "Privacy", "Browser add-on to deactivate Google Analytics". Google Tag Manager: Integration and management of other services for performance and reach measurement as well as further services from Google and from third parties; Provider: Google; Google Tag Manager-specific information: "Data collected with Google Tag Manager"; further information on data protection can be found at the individual integrated and managed services.

12. VIDEO SURVEILLANCE

We use video surveillance to prevent criminal offences and to secure evidence of criminal offences as well as to exercise our domestic authority. If and to the extent that the General Data Protection Regulation (GDPR) applies, these are 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 to secure evidence.

We may secure recordings on the basis of legal obligations, to enforce our own legal claims and in the event of suspected criminal offences and transmit them to competent authorities such as, in particular, courts or criminal prosecution authorities.

13. FINAL PROVISIONS

We have created this privacy policy with the data protection generator of Datenschutzpartner.

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