Privacy policy

This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as ‘data’) in the context of the provision of our services and within our online offering and the associated websites, functions and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as ‘online offering’) . With regard to the terms used, such as ‘processing’ or ‘administrator’, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Website manager

Hotel Villa Wittstock
Blumenthaler Landstr. 7
39288 Burg (bei Magdeburg)
Germany

Email: webmaster@villawittstock.de
Proprietor: Mirko Wittstock

Types of data processed

– Inventory data (e.g. personal master data, names or addresses).
– Contact details (e.g. email, telephone numbers).
– Content data (e.g. text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g. device information, IP addresses).

Categories of data subjects

Visitors and users of the online offering (hereinafter, we also refer to the persons concerned collectively as ‘users’).

Purpose of processing

– Provision of the online offering, its functions and content.
– Responding to contact requests and communicating with users.
– Safety measures.
– Reach measurement/marketing

Terms used

‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’); A natural person is considered identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

‘Pseudonymisation’ means processing personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

‘Profiling’ means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

The ‘administrator’ is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the administrator.

Relevant legal bases

In accordance with Art. 13 GDPR, we hereby inform you of the legal basis for our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not specified in the privacy policy:
The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR;
The legal basis for processing for the performance of our services and the implementation of contractual measures as well as for responding to enquiries is Art. 6 (1) (b) GDPR;
The legal basis for processing to fulfil our legal obligations is Art. 6(1)(c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the administrator is Art. 6 para. 1 lit. e GDPR.
The legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which it was collected is determined by the provisions of Art. 6 para. 4 GDPR.

Safety measures

We take appropriate technical and organisational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, transfer, availability and separation. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted and responses are made to data breaches. Furthermore, we take the protection of personal data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings.

Cooperation with processors, joint administrators and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors, joint administrators or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the fulfilment of a contract), users have consented, a legal obligation requires it, or it is based on our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose data to other companies within our group, transfer it to them or otherwise grant them access to it, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with legal requirements.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons or companies, this will only take place if it is necessary for the fulfilment of our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the data to be processed in a third country if the legal requirements are met. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection equivalent to that of the EU (e.g. for the USA through the ‘Privacy Shield’) or compliance with officially recognised special contractual obligations.

Rights of data subjects

You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.

In accordance with legal requirements, you have the right to request that data concerning you be completed or that incorrect data concerning you be corrected.

In accordance with legal requirements, you have the right to request that the data in question be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with legal requirements.

You have the right to request that the data concerning you that you have provided to us be retained in accordance with legal requirements and to request that it be transferred to other administrators.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with the statutory provisions.

Right of withdrawal

You have the right to revoke any consent you have given with effect for the future.

Right of objection

You may object to the future processing of data concerning you at any time in accordance with the statutory provisions. In particular, you may object to the processing of data for direct marketing purposes.

Cookies and right to object to direct marketing

Cookies are small files that are stored on users' computers. Various types of information can be stored in cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or ‘session cookies’ or ‘transient cookies’, are cookies that are deleted after a user leaves an online service and closes their browser. Such cookies can store, for example, the contents of a shopping basket in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as ‘permanent’ or ‘persistent’. For example, the login status can be stored if users visit the site after several days. Such cookies can also store the interests of users, which are used for reach measurement or marketing purposes. Cookies that are offered by providers other than the administrator operating the online service are referred to as ‘third-party cookies’ (otherwise, if they are only the administrator's cookies, they are referred to as ‘first-party cookies’).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Excluding cookies may lead to functional restrictions of this online offer.

A general objection to the use of cookies for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website httpss://www.aboutads.info/choices/ or the EU website httpss://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by disabling them in your browser settings. Please note that this may mean that not all functions of this online service can be used.

Deletion of data

The data we process will be deleted or restricted in its processing in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention obligations preventing its deletion.

Unless the data is deleted because it is required for other, legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

Changes and updates to the privacy policy

We ask that you regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make this necessary. We will inform you as soon as the changes require action on your part (e.g. consent) or other individual notification.

Business-related processing

In addition, we process
– Contract data (e.g., subject matter of the contract, term, customer category).
– Payment data (e.g., bank details, payment history)
from our customers, interested parties and business partners for the purpose of providing contractual services, customer care, marketing, advertising and market research.

Contractual services

We process the data of our contractual partners and interested parties as well as other clients, customers, clients or contractual partners (collectively referred to as ‘contractual partners’) in accordance with Art. 6 (1) lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose of its processing, and the necessity of its processing are determined by the underlying contractual relationship.

The data processed includes the master data of our contractual partners (e.g. names and addresses), contact details (e.g. email addresses and telephone numbers), contract data (e.g. services used, contract content, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).

We do not process special categories of personal data as a matter of principle, unless they are part of commissioned or contractual processing.

We process data that is necessary for the establishment and fulfilment of contractual services and point out the necessity of providing this data if it is not evident to the contractual partners. Disclosure to external persons or companies only takes place if it is necessary within the framework of a contract. When processing data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements.

When you use our online services, we may store your IP address and the time of the respective user action. This storage is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorised use. This data is not passed on to third parties unless it is necessary to pursue our claims in accordance with Art. 6 (1) lit. f. GDPR or there is a legal obligation to do so in accordance with Art. 6 (1) lit. c. GDPR.

The data will be deleted when it is no longer required for the fulfilment of contractual or statutory duties of care or for the handling of any warranty and comparable obligations, whereby the necessity of storing the data is reviewed every three years. In all other respects, the statutory retention obligations apply.

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks and the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the context of providing our contractual services. The basis for processing is Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified for these processing activities. 

We disclose or transfer data to the tax authorities, advisors such as tax consultants or auditors, as well as other fee collection agencies and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, event organisers and other business partners, e.g. for the purpose of contacting them at a later date. We generally store this data, most of which is company-related, on a permanent basis.

Hosting and email delivery

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services and technical maintenance services, which we use for the purpose of operating this online offering.

In doing so, we or our hosting provider process inventory, contact, content, contract, usage, meta and communication data from customers, interested parties and visitors to this online offering on the basis of our legitimate interests in the efficient and secure provision of this online offering in accordance with Art. 6 (1) lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

Collection of access data and log files

We, or our hosting provider, collect data about every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. The access data includes the name of the website accessed, the file, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum period of 7 days and then deleted. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Integration of third-party services and content

Within our online offering, we use third-party content or service offerings on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR) We use content or service offerings from third-party providers to integrate their content and services, such as videos or fonts (hereinafter collectively referred to as ‘content’).

This always requires that the third-party providers of this content recognise the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, and may be linked to such information from other sources.

Google Fonts

We incorporate fonts (‘Google Fonts’) from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: httpss://www.google.com/policies/privacy/, opt-out: httpss://adssettings.google.com/authenticated. 

Google Maps

We integrate maps from the Google Maps service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The data processed may include, in particular, users' IP addresses and location data, but this data is not collected without their consent (usually given in the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

Created in 2021