Privacy policy

The protection of your personal data is very important to us. Therefore we process your data exclusively on the basis of the legal regulations (GDPR, TKG 2003). In this privacy policy we inform you about the most important aspects of data processing within our website.

Scope

This privacy policy is for this website subretta.kappl.at and served by Apart Subretta, Familie Jäger Birgit und Otmar, Hof 524, 6555 Kappl, Austria (subretta@kappl.at) and governs the privacy of its users who choose to use it. Furthermore, this privacy policy informs about the data protection concerning reservation data and guest card.

Used data

We use the following data when you contract with us:

Master data: first and last name, full address, all contact information (e.g. e-mail address, telephone number), information about the nature and content of our contractual relationship.

Other personal data that you or third parties make available to us, with your consent or otherwise permissible, when the contract is initiated, during the contractual relationship (for example, to issue a guest card) or to fulfill legal obligations:
Date of birth or age, marital status, gender, profession, identity card details, bank details, subscription or representation authorization, contractual commitment, notice / cancellation deadlines or other personal information that you yourself have given us.

Data processors

The protection of your data is important to us. Even if we use a data processor (e.g. company Feratel – Gästeverzeichnis nach § 19 MeldeV), we make sure that the data processing takes place within the European Union.

Information Collection, Use, and Sharing

We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone. We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request.

Access data / server log files

We follow a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The logged data is used for statistical evaluations for the purpose of operation, security and optimization of the offer. However, the provider reserves the right to retrospectively review the log data if, on the basis of concrete evidence, the legitimate suspicion of unlawful use exists.

Integration of services and contents of third parties

It may happen that content from third parties, such as videos, maps or graphics from other websites are incorporated within this website. This always presupposes that the providers of this content (hereinafter referred to as "third party provider") perceive the IP address of the users. Because without the IP address, they could not send the content to the browser of each user. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. However, we do not have any influence on this if the third party providers store the IP address e.g. for statistical purposes. As far as we know, we will inform users about it.

Contents of the Paznaun – Ischgl Tourism Association

This website uses content from the websites of the Paznaun – Ischgl Tourism Association, which are integrated on this website. Such content includes, for example, pages of informative content or widgets (e.g., weather widget). This content is integrated into this website within an iFrame (own window within a website) and/or as infolink via a lightbox (such as Webcam, Wetter). All these contents of the Paznaun – Ischgl Tourism Association are integrated with SSL encryption. Information on data protection regarding this content can be found here.

Contact & Communication

If you contact us via inquiry form or e-mail, your given data will be stored for six months in order to process the request and in case of follow-up questions. We will not share this information without your consent.

Use of Google Maps

This website uses Google Maps to display maps and directions for the creation of plans. Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. By using this website you consent to the collection, processing and the use of automatically collected and the data you entered by Google, its agents, or third parties. For the terms and conditions of Google Maps, see Google Maps Terms. For more details, see the Google Privacy Center.

1. Reservation Data

1.1. Reporting Requirement

Pursuant to the Austrian Reporting Law you are required to provide us with the data specified in § 5 and § 10 of the Reporting Law. This relates to the following data: Name, date of birth, gender, nationality, country of origin, address plus postal code and - for international guests - type, number, issue location and issuing authority of a travel document, and also the date of arrival and departure.

1.2. Guest Registry

Owing to our legal obligation arising from § 19 of the Reporting Law-Implementation Order, we shall maintain this data in a Guest Registry and save it for a period of 7 (seven) years, unless it is needed for a longer period of time for other purposes which are named in this Data Protection Statement.
The Guest Registry shall be maintained by us in electronic format, and for this purpose we shall transfer the data to an IT services provider. The data shall thus be saved locally. No transmittal into a third country shall occur.

1.3. Transmittal of Data

The data categories of “arrival” and “departure,” linked with the country of origin, shall be transmitted to the community where the hospitality company is located, in accordance with § 6 of the Tourism Statistical Order. Also, aggregate data regarding the total number of overnight stays and total number of persons obligated to pay the room tax shall be provided to the Tourism Association of Paznaun - Ischgl, where we are members, and/or to the community. This shall be handled on the basis of § 19 of the Tyrol Accommodation Law.

1.4. Legal Basis for Data Processing

Data processing pursuant to the above Sections 1.1 to 1.3 shall be based on Art. 6 para. 1 lit. c of the DSGVO.

1.5. Additional Data Transmittal to the TVB/Municipality

In addition, we shall provide your postal code and year of birth (in a pseudonymized and/or anonymized form) to our municipality and to our TVB for statistical purposes in order to prepare and evaluate the origin and age statistics by the Tourism Association (TVB). This transmittal is based on Art. 6 para. 1 lit. e (transmittal in the public interest) and lit. f (predominate lawful interest) DSGVO. However, you may file an opposition at any time for reasons relating to your particular situation (Art. 21 para. 1 DSGVO).

2. Guest Card

2.1. General Information

You are entitled to obtain a guest card. The guest card grants the owner benefits and/or services at various companies in the region (e.g. reduced admission fees). The guest card is valid for the period of your visit.

2.2. Issuance of the Guest Card

The guest card will be issued and validated by the accommodation provider solely at your request. It will be issued according to the Guest Card system employed by the TVB and/or by the accommodation company, either in the form of

• an electronically generated guest card,
• a Guest Card issued on your cell phone or
• a copy of your reservation slip.

2.3. Processed Personal Data

The following personal data, obtained from the reservation data (see Section 1 above) will be processed both for the electronically generated, and also for the cell phone-provided Guest Card: First and last name, date of birth, country of origin/postal code and the date of arrival and departure. If the Guest Card is issued in the form of the “reservation slip,” then it will contain the information required by § 5 in connection with § 9 of the Reservations Law (see Section 1.1 “Reservation Data”). In this case, no electronic processing will be performed relating to the Guest Card.

When using the Guest Card, the following additional personal data will be processed: Data relating to the frequency of use of the particular card, service requested, reservations, transaction logging, reference to the reservation data and accommodation company.

This data is required firstly to verify your identity and secondly to verify the validity of the Guest Card for the particular service requests, and if necessary, to allow invoicing of the benefits between the service providers, the TVB and any accommodation companies involved.

2.4. Legal Basis for Data Processing

Processing of the data for purposes of the Guest Card shall proceed pursuant to your consent (Art. 6 para. 1 lit. a DSGVO).

Your consent can be withdrawn at any time by giving oral or written instructions to the accommodation provider at the email address subretta@kappl.at.

2.5. Operation of the Guest Card System

The Guest Card System is operated by the local tourism association (TVB). In addition, local accommodation operators and local companies (service providers) are involved. The data that is processed for the Guest Card will be deleted after 48 (fortyeight) months, unless additional retention is necessary for other lawful purposes (e.g. reporting requirements).

2.6. Receivers of the Data

Data processed for purposes of the Guest Card will be provided to the local Tourist Association for invoicing to the service providers and/or accommodation operators.

The individual service providers who provide beneficial services based on the Guest Card, likewise will receive the data, provided you have used the Guest Card services provided by these companies.

To claim the benefits, you must present the particular Guest Card on which the data is recorded, and thus disclose the data to the service provider. The company will then check whether the card is (still) valid, usually by reading the bar code on the Guest Card and by transmitting the bar code data to our IT services provider. At this time personal data will be transmitted to the company, in particular also your identity data (to verify your identity and date of birth).

If the Guest Card has been issued in the form of a reservation slip, then its validity will be checked based on the copy of the reservation slip.

Other processing of your data

Basically, we only process those data which is absolutely necessary for the conclusion of the contract or for the fulfillment of the contract. If you have also given us the appropriate consent, we will process your data in such a way that we will provide you with information about our services until further notice. In doing so, we use the following communication channels, if you have given us this: Phone, Email, SMS, Post or Social Media Channels.

Your rights

In principle, you have the rights of information, correction, deletion, restriction, data portability, revocation and opposition. If you believe that the processing of your data violates the data protection law or if your data protection claims have otherwise been violated in a way, you can complain to the supervisory authority. In Austria, this is the data protection authority (Datenschutzbehörde).

Data deletion

Your personal data will be deleted if they are no longer necessary for the fulfillment of the purpose for which they were stored - usually after 7 (seven) years - or if the storage becomes inadmissible for legal reasons.

Instead of a deletion, anonymization of the data can be made, which means that any personal reference is irretrievably removed.

Confirmation of identity

To protect your rights and your privacy, we are entitled to request proof of identity in case of doubt.

Overuse of rights

If you claim that one of these rights is manifestly unfounded or particularly frequent, we are entitled to demand a reasonable processing fee or refuse to process the application.

Compulsory participation

Within the scope of obligations to cooperate we are obliged to provide data according to the legal regulations (for example BAO, registration form, ZPO, StPO, ...) on request.

Duration

This privacy policy applies from 25 May 2018 and supersedes the existing privacy policy.

You can contact us under the following contact details:

Apart Subretta
Familie Jäger Birgit und Otmar
Hof 524, 6555 Kappl, Austria

Tel. & Fax: +43 (0) 5445 6728
Mobil: +43 (0) 650 630 11 45
E-Mail: subretta@kappl.at