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Status: September 2022

The protection of personal data is an important concern for us. Therefore, the processing of personal data is carried out in accordance with the applicable European and national legislation.

You can, of course, revoke your declaration(s) of consent at any time with effect for the future. For this purpose, please contact the responsible person according to § 1.

The following declaration provides an overview of the type of data collected, how this data is used and passed on, what security measures we take to protect your data and how you can obtain information about the information given to us.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) sentence 1 lit. a) of the EU General Data Protection Regulation (DSGVO) serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) S. lit. b) DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

If processing of personal data is necessary for compliance with a legal obligation to which we are subject, Art. 6 (1) S. 1 lit. c) DSGVO serves as the legal basis.

If processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) S.1 lit. f) DSGVO serves as the legal basis for the processing.

Data deletion and storage period

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which we are subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or performance of a contract.

Data protection in the context of the partnership with Miles & More

As part of our partnership with the frequent flyer programme Miles & More, we transmit personal data to qiibee AG (Alpenstrasse 7, 6300 Zug, Switzerland), which processes it on behalf of Miles & More.

If you participate in our Miles & More loyalty programme and apply for mileage credit, we will transfer the necessary data to qiibee AG. This data includes in particular

Invoice amount
Stay data (e.g. booking or stay dates)
Your Miles & More service card number

Your data will be transmitted and processed solely for the purpose of fulfilling your request for mileage credit and crediting your miles to your Miles & More account.

The processing of your personal data in the context of mileage crediting is based on Art. 6 para. 1 lit. b GDPR (fulfilment of contract), as this data is required for the fulfilment of the contract between you and us or between you and Miles & More.

Your personal data will be transmitted to qiibee AG, which processes the data on behalf of Miles & More and forwards it for mileage crediting. The data will be forwarded exclusively for the above-mentioned purpose.

qiibee AG is based in Switzerland, which is not part of the European Union or the European Economic Area. However, the EU Commission has decided that Switzerland offers an adequate level of data protection, which is why the transfer of your data to qiibee AG is considered secure.

The data transmitted by us to qiibee AG will only be stored for as long as is necessary to fulfil your request for mileage credit. The data will then be deleted, provided that there are no statutory retention obligations.

You have various rights in connection with the processing of your personal data. You have the right to request information about the personal data stored about you at any time and to request its correction, deletion or restriction of processing, provided that there are no statutory retention obligations to the contrary. You also have the right to data portability.

If you believe that your personal data is not being processed in accordance with data protection regulations, you can lodge a complaint with the competent supervisory authority.

Further information on the processing of your personal data by qiibee AG can be found in their privacy policy: https://www.qiibee.com/privacy-policy

§ 1 The person responsible and the data protection officer

(1) Name and address of the person responsible

The responsible person within the meaning of the General Data Protection Regulation and other national

data protection laws of the member states as well as other data protection regulations is:

CPH Hotelmarketing GmbH

Sabine Möller

Weissenhof 7c

22159 Hamburg

Germany

Tel.: 040 6569410

E-Mail:cph@cph-hotels.com

Website: https://www.cph-hotels.com

(2) Name and address of the data protection officer

The data protection officer of the responsible party is:

Data Protection & Privacy – Nicole Christiane Grohmann

DPO: Dieter Grohmann

Welserstraße 3

87463 Dietmannsried

Germany

Phone: 0831 52098680

E-mail: dg@datenschutzprivacy.de

Website: www.datenschutzprivacy.de

§ 2 Definitions

The data protection declaration is based on the terms used by the European legislator in the adoption of the EU General Data Protection Regulation (hereinafter: “GDPR”). The data protection declaration is intended to be easy to read and understand. To ensure this, the most important terms are explained below:

(a) Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

c) Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Profiling means any automated processing of personal data that consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

e) Pseudonymization means the processing of 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 organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

(f) Controller or controller means 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.

(g) Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

h) Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

(i) Third party means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or the processor, are authorized to process the personal data.

j) Consent shall mean any freely given indication of the data subject’s wishes for the specific case in an informed and unambiguous manner, in the form of a statement or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

§ 3 Provision of the website and creation of log files

(1) During the mere informational use of the website, i.e. if you do not register or otherwise transmit information to us, we automatically collect the following data and information from the computer system of the calling computer each time the website is called up:

– IP address of the requesting computer

– Date and time of file retrieval

– URL of the retrieved file

– URL of the website from which access is made (via HTTP referrer header)

– Browser used and, if applicable, the operating system of the accessing computer

– HTTP status code and HTTP protocol version

This data is also stored in the log files of our system. Not affected by this are the IP addresses of the user or other data that allow the data to be assigned to a user. This data is not stored together with other personal data of the user.

(2) The legal basis for the temporary storage of the log files is Art. 6 para. 1 p. lit. f) DSGVO.

(3) The temporary storage of the IP address by the system is necessary in order to

a) enable delivery of the website to the user’s computer. For this purpose, the IP address of the user must remain stored for the duration of the session.

b) to optimize the content of our website as well as the advertising for it

c) to ensure the functionality of our information technology systems and the technology of our website

d) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.

These purposes also include our legitimate interest in data processing pursuant to Art. 6 (1) p. 1 lit. f) DSGVO.

(4) The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected – in this case, at the end of the usage process.

(5) The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website, which is why there is no possibility to object.

§ 4 Use of cookies

(1) This website uses so-called cookies. Cookies are small text files that, as soon as you visit a website, are sent by a web server to your browser and stored locally on your end device (PC, notebook, tablet, smartphone, etc.) and are stored on your computer and provide the user (i.e. us) with certain information. Cookies are used to make the website more customer-friendly and secure, and in particular to collect usage-related information, such as frequency of use and number of users of the pages and behavioral patterns of page use. Cookies do not harm the computer and do not contain viruses. This cookie contains a characteristic string of characters (so-called cookie ID), which enables the browser to be uniquely identified when the website is called up again.

(Some of our web offers (blogs) are created with the blog system “Blogger.com” by Google. For these pages*, we refer to the cookie guidelines of Google: https://policies.google.com/technologies/partner-sites?hl=de).

(2) We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change. The following data is stored and transmitted in the cookies:

– language settings

– pages already visited

– log-in information

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 p. 1 lit. f) DSGVO.

(3) The purpose of using technically necessary cookies is to simplify the use of websites for you. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.

We require cookies for the following applications:

– Acceptance of language settings

– Remembering search terms

– Remembering login information (online store)

– The user data collected through technically necessary cookies are not used to create user profiles.

(4) Cookies remain stored even if the browser session is terminated and can be retrieved when you visit the site again. However, cookies are stored on your computer and transmitted from it to our site. Therefore, you also have full control over the use of cookies. If you do not wish data to be collected via cookies, you can set your browser via the menu under “Settings” so that you are informed about the setting of cookies or generally exclude the setting of cookies or also delete cookies individually. It should be noted, however, that the functionality of this website may be limited if cookies are deactivated. As far as session cookies are concerned, they will be deleted automatically after leaving the website anyway.

§ 5 Newsletter

(1) With your consent, you can subscribe to our free newsletter, with which we inform you about our current interesting offers. The advertised goods and services are named in the declaration of consent.

For the registration to our newsletter we use the so-called double-opt-in procedure. This means that after your registration we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your respective IP addresses used and times of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

The only mandatory data for sending the newsletter is your e-mail address. The provision of further data [title, first name, last name, address, date of birth] is voluntary and will be used to address you personally. The data will be used exclusively for sending the newsletter.

(2) The legal basis for the processing of the data after registration for the newsletter by the user is, in the case of consent, Art. 6 para. 1 p. 1 lit. a) DSGVO as well as applies to the legal basis for sending the newsletter pursuant to Art. 7 para. 3 UWG.

(3) The collection of the user’s email address serves to deliver the newsletter.

(4) The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Accordingly, your e-mail address will be stored as long as the subscription to the newsletter is active.

(5) You can cancel the receipt of our newsletter at any time and thus revoke your consent by clicking on the “Unsubscribe Newsletter” field in our newsletter unsubscribe or by sending us an e-mail to [newsletter@cph-hotels.com] or a message to the contact details provided in the imprint.

This also enables you to revoke your consent to the storage of the personal data collected during the registration process.

§ 6 Registration (Online Shop)

(1) We offer you the opportunity to register on our website (https://shop.cph-hotels.com) by providing personal data. The data is entered in an input mask and transmitted to us and stored. As a matter of principle, this data is not passed on to third parties, unless there is a legal obligation to pass it on or the passing on serves criminal or legal prosecution.

The following data is collected during the registration process:

– First name, last name

– e-mail address

– Your address

– Self-selected password (there is no obligation to use a clear name, a pseudonymous use is possible)

– Freely chosen username

– IP address

– Date and time of registration

All information can be managed and changed in the protected customer area. Within the

the registration process, the user’s consent to the processing of these

data is obtained.

(2) We use the so-called double-opt-in procedure for registration. This means that after you have registered, we will send you an e-mail to the e-mail address you have provided in which we ask you to confirm that you wish to register. If you do not confirm your registration within 24 hours, your information will be blocked and deleted after one month. In addition, we store your respective IP addresses used and times of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data.

(3) The legal basis for the processing of the data is Art. 6 para. 1 p. 1 lit. a) DSGVO if the user has given his consent.

(4) Registration is necessary for the provision of certain content and services on our website as well as for the prevention of misuse and, if necessary, for the investigation of criminal offences. (further description of the contents and services).

(5) The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected.

This is the case for the data collected during the registration process as soon as you delete your access. We also store the voluntarily provided data for the time until the account is deleted, unless you delete it yourself beforehand. You can delete the account by sending us an e-mail to online-shop@cph-hotels.com with the request to delete your account.

(6) If the data is required for the performance of a contract or for the implementation of pre-contractual measures, early deletion of the data is only possible insofar as contractual or legal obligations do not prevent deletion.

Otherwise, you are free to have the personal data provided during registration completely deleted from the data stock of the controller. Upon request, the controller will provide you at any time with information about which personal data is stored about the data subject. Furthermore, the controller shall correct or delete personal data at the request or indication of the data subject, provided that this does not conflict with any statutory retention obligations. You may write to the data controller or the data protection officer pursuant to § 1 at any time via e-mail or by post and request deletion/amendment of the data.

(7) Competitions: From time to time, you have the opportunity to participate in competitions, or similar promotions on our website. In the context of these promotions, personal data (e-mail address, name, address and, if necessary, other data required for the promotion) may also be collected and stored for the purpose of processing. The personal data you provide to us in the context of such a promotion will be used exclusively for the purpose of processing the promotion (in the case of a competition, for example, for determining the prize, notifying the winner and sending the prize). After the end of the promotion, the participants’ data will be deleted. The data processing is based on Art. 6 para. 1 lit. a), c) and f) DSGVO.

§ 7 E-commerce

(1) If you would like to order in our webshop (https://shop.cph-hotels.com), it is necessary for the conclusion of the contract that you provide your personal data, which we need for the processing of your order. Mandatory data necessary for the processing of the contract are marked separately, other data are voluntary. The data is entered into an input mask and transmitted to us and stored. The following data is collected in the context of the webshop:

– Name

– Address (if necessary different delivery address)

– e-mail address

– IP address

– Date and time of order

– Ordered articles

The data will only be passed on to third parties if this is necessary for the purpose of processing the contract or for invoicing purposes or for collecting the payment, or if you have expressly consented to this. In this regard, we only pass on the data required in each case. The data recipients are

– The respective delivery/shipping company (transfer of name and address)

– Collection companies, insofar as the payment must be collected (disclosure of name, address, order details).

– If you choose PayPal in the payment process and are not yet registered with PayPal, we will transfer your personal data such as name, address and email address from your information in the ordering process to the registration mask of PayPal.

– You can voluntarily create a customer account, through which we can store your data for future purchases. When you create an account under “My Account”, the data you provide will be stored revocably. You can always change all further data, including your user account, in the customer area.

(2) The legal basis is Art. 6 para. 1 p. 1 lit. b) DS-GVO. With regard to the voluntary data, the legal basis for the processing of the data is Art. 6 para. 1 p. 1 lit. a) DSGVO.

(3) The mandatory data collected is required for the fulfillment of the contract with the user (for the purpose of sending the goods and confirming the content of the contract). We therefore use the data to answer your inquiries, to process your order, if necessary to check creditworthiness or to collect a debt, and for the purpose of technical administration of the websites. The voluntary data is used to prevent misuse and, if necessary, to investigate criminal offences. We may also process the data you provide to inform you about other interesting products from our portfolio or to send you e-mails with technical information.

(4) The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. We are obliged by commercial and tax law to store your address, payment and order data for a period of ten years after the execution of the contract. However, we will restrict processing after [two years], i.e. your data will only be used to comply with legal obligations. If a continuing obligation exists between us and the user, we store the data for the entire term of the contract and for ten years thereafter (see above). With regard to data provided voluntarily, we will delete the data upon expiration of [two] years after execution of the contract, provided that no further contract is concluded with the user during this period; in this case, the data will be deleted upon expiration of [two] years after execution of the last contract.

(5) If the data is required for the performance of a contract or for the execution of pre-contractual measures, early deletion of the data is only possible insofar as contractual or legal obligations do not prevent deletion.

Otherwise, you are free to have the personal data provided during registration completely deleted from the data stock of the controller. The controller will provide you with information about which personal data is stored about you at any time upon request. Furthermore, the controller will correct or delete personal data at the request or notice of the data subject, provided that this does not conflict with any statutory retention obligations. You can write to the data controller or the data protection officer in accordance with § 1 at any time via e-mail or post and ask for deletion/modification of the data.

§ 8 Disclosure of personal data to third parties

1. integration of YouTube videos

(1) We have integrated YouTube videos into our online offer, which are stored on http://www.YouTube.com and can be played directly from our website. [These are all embedded in “extended data protection mode”, i.e. no data about you as a user is transmitted to YouTube if you do not play the videos. Only when you play the videos will the data mentioned in paragraph 2 be transmitted. We have no influence on this data transmission. By visiting the website, YouTube receives the information that you have accessed the corresponding sub-page of our website.

The following data is transmitted in this context

– Device-specific information, for example the hardware used; the version of the operating system; unique device identifier and information about the mobile network including your telephone number.

– Log data in the form of server logs. These include, but are not limited to, details of how the services were used, for example, search queries; IP address; hardware settings; browser type; browser language; date and time of your request; originating page; cookies that uniquely identify your browser or Google account.

– Location-based information. Information about your actual location may be collected by Google. This includes, for example, your IP address, your WLAN access points or mobile phone masts.

– For more information about the data collected by Google LLC, please see the following link: https://policies.google.com/privacy?hl=de&gl=de

This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account.

(2) The legal basis for the processing of the users’ personal data is Art. 6 para. 1 p.1 lit. f) DSGVO.

(3) The integration of the videos serves to make the website more descriptive for the user and to increase the search engine ranking of the website on Google. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) for the provision of needs-based advertising and to inform other users of the social network about your activities on our website.

(4) If you do not wish to be associated with your profile on YouTube, you must log out before activating the button.

(5) You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

(6) Further information on the purpose and scope of data collection and processing by YouTube can be found in the privacy policy. There you will also find further information on your rights and setting options to protect your privacy: https://www.google.de/intl/de/policies/privacy .

2. links to external websites

This website contains links to external sites. We are responsible for our own content. We have no influence on the contents of external links and are therefore not responsible for them, in particular we do not adopt their contents as our own. If you are directed to an external site, the privacy policy provided there applies. If you notice illegal activities or content on this site, you are welcome to inform us. In this case we will check the content and react accordingly (notice and take down procedure).

3. google web fonts [SB1]

Our pages, which are created with *blogger.com, use so-called web fonts provided by Google for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly. When you visit these web pages, your browser therefore sends requests to the Google server. In doing so, Google logs the following data:

– IP address

– Browser information (name, version)

– web page

– Operating system of the user

– Screen resolution of the user

– Language settings of the user’s browser or operating system

– Font file

This is done regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. Google Web Fonts are used in the interest of a uniform and appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 (1) p. 1 lit. f DSGVO.

(a) The legal basis for the processing of personal data is Art. 6 para. 1 lit. p.1 f) DSGVO.

(b) Google stores your data as usage profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) for the provision of needs-based advertising and to obtain information about your activities on our website.

(c) You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right.

(d) For more information on the purpose and scope of data collection and its processing by the plug-in provider, please refer to the provider’s privacy policy. There you will also find further information on your rights in this regard and setting options for protecting your privacy: http://www.google.de/intl/de/policies/privacy.

4 Google Maps

This site uses the map service Google Maps via an API. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transmission. The use of Google Maps is in the interest of an appealing presentation of our online offers and an easy location of the places indicated by us on the website. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO. More information on the handling of user data can be found in Google’s privacy policy: https://www.google.de/intl/de/policies/privacy/.

5. use of the online booking tool DIRS21 of TourOnline AG.

Our online presence uses the online booking tool DIRS21 (hereinafter “OBT”) of the company TourOnline AG, Borsigstraße 26, 73249 Wernau, Germany (www.dirs21.de, hereinafter “TOAG”) to enable online bookings of accommodation services and other travel services as well as to process inquiries. Within the framework of the OBT, TOAG processes the data as the responsible party. The notes and provisions on data protection can be found in TOAG’s privacy policy on OBT, which you can access at any time from OBT or view at www.dirs21.de/datenschutz.

6. Meta pixel (formerly Facebook pixel)

The so-called meta pixel of the social network Facebook (Meta Platforms Inc., 1601 Willow Road, Menlo Park, CA 94025, USA) is used on our website. This code enables us to track the behavior of users after they have been redirected to our website via a Facebook or Instagram ad. This allows us to measure the effectiveness of our ads and optimize our marketing measures.

The data collected by the pixel is anonymous to us and does not allow us to draw any conclusions about your identity. However, Meta can link this data to an existing Facebook or Instagram account and use it for its own purposes.

The Meta pixel is only used with your express consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time via our cookie banner.

Please note that if your data is processed by Meta, it may be transferred to the USA, where there is no level of data protection comparable to that in the EU.

Further information on data processing by Meta can be found at: https://www.facebook.com/privacy/policy

§ 9 Contact form and e-mail contact

(1) Our website contains contact forms that can be used for electronic contact. If you take advantage of this option, the data entered in the input mask will be transmitted to us or the respective hotel as an e-mail.

Alternatively, it is possible to contact us via the e-mail address provided. In this case, the personal data transmitted with the e-mail will be stored.

Insofar as this involves information on communication channels (for example, e-mail address, telephone number), you also consent to us contacting you via this communication channel, if necessary, in order to answer your request.

In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.

(2) The legal basis for the processing of the data is Art. 6 para. 1 p. lit. a) DSGVO if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 S.1 lit. f) DSGVO. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1S. 1 lit. b) DSGVO.

(3) The processing of personal data from the input mask serves us solely to process the contact. We will, of course, use the data from your e-mail inquiries exclusively for the purpose for which you provide them to us when contacting us. In the case of contact by e-mail, the necessary legitimate interest in the processing of the data also lies in its reply. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

(4) The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation shall be deemed to have ended when it is clear from the circumstances that the matter in question has been conclusively clarified.

(5) You have the option to revoke his consent to the processing of personal data at any time. If you contact us by e-mail, you can object to the storage of his personal data at any time. In such a case, the conversation can not be continued. Regarding the revocation of consent/opposition to storage, we ask you to contact the person responsible or the data protection officer as per § 1 via e-mail or by post. All personal data stored in the course of contacting us will be deleted in this case.

§ 10 Data protection and GDPR compliance when using our voicebots

The General Data Protection Regulation (GDPR) requires the lawful, purposeful and transparent processing of personal data. Our voicebot systems are based on the central principles of the GDPR, in particular

Purpose limitation
Data minimization
transparency
Storage limitation
Integrity and confidentiality

If personal data is transferred to so-called third countries (e.g. the USA) as part of our Voicebot solutions, this is done exclusively in compliance with the requirements of the GDPR. We rely on suitable guarantees, in particular Standard Contractual Clauses (SCCs) adopted by the EU Commission. These are implemented by the technology partners we use, such as Twilio or OpenAI. This ensures an appropriate level of protection.

Voice processing by our voicebots takes place in real time to generate responses. Personal data is not stored permanently unless this is expressly activated at the customer’s request (e.g. for the documentation or analysis of call content). In these cases, processing takes place on the basis of a corresponding legal basis (e.g. consent pursuant to Art. 6 para. 1 lit. a GDPR or fulfillment of contract pursuant to Art. 6 para. 1 lit. b GDPR).

If call recording is activated, automated information is provided at the beginning of the call and, if necessary, consent is obtained by the voicebot.

To protect personal data, we implement suitable technical and organizational measures (TOMs) in accordance with Art. 32 GDPR. These include, among others:

Pseudonymization and data minimization
Implementation of deletion and storage concepts
Access controls and role-based authorizations
Logging and monitoring (surveillance)
No disclosure to third parties without contractual protection

All measures implemented are based on current security standards and are regularly reviewed.

We support our customers in the data protection-compliant integration of Voicebot systems into existing processes and systems. We are happy to provide additional information or documentation (e.g. on the order processing contract in accordance with Art. 28 GDPR) on request.

§ 11 Social media (plugins)

We currently do not use social media plugins on our website. However, we have social media presences on Twitter, Instagram, Facebook. Should you visit our social media profiles, data will be collected by the respective platforms. In the following, we point out the data collection when using the social media platforms (also in the case under use of plugins). For the purpose and scope of the data collection on the respective platform, please refer to the corresponding provision:

Facebook: https://de-de.facebook.com/about/privacy/

Google: https://policies.google.com/privacy?hl=de

Instagram: https://help.instagram.com/155833707900388

Twitter: https://twitter.com/de/privacy

Facebook

Social plugins of the social network Facebook (Meta-Platforms Ireland Ltd, 4 Grand Canal Square Grand Canal, Harbour Dublin 2 Ireland) are used on these pages. This plugin allows you to bookmark these pages and thus share them with other participants of the social network. You can recognize it by the Facebook logo. You can find an overview of the Facebook plugins at http://developers.facebook.com/docs/plugins/. The data transfer takes place regardless of whether you have an account with Facebook and are logged in there.

– If you click the Facebook button while logged into your Facebook account, the content of these pages can also be linked to the Facebook profile. In this case, Facebook can also assign the visit of these pages to your user account. If you click the activated button and link the page, for example, Facebook will also store this information in your user account and share it publicly with your contacts. We recommend that you log out regularly after using a social network, but especially before activating the button, as this will help you avoid being assigned to your profile.

– If you are not a member of Facebook or have logged out of Facebook before visiting this site, there is still the possibility that Facebook will find out and store your IP address.If you do not want Facebook to be able to assign the visit to our pages to your Facebook user account, you must log out of Facebook before visiting our website or must not activate the plugin.

Basically, the following data is transmitted to Facebook:

– Browser-related data such as IP address, browser type, operating system, time and date of the request, website visited.

– User ID (For logged in Facebook account).

According to Facebook in Germany, the IP addresses are anonymized immediately after collection. By activating the plugin, personal data is therefore transmitted from you to Facebook and stored in the USA. Since Facebook collects data in particular via cookies, we recommend that you delete all cookies via your browser’s security settings before clicking on the logo.

We have no influence on the collected data and data processing operations, nor are we aware of the full extent of the data collection, the purposes of the processing, the storage periods. We also have no information on the deletion of the collected data by Facebook.

Facebook stores the data collected about you as usage profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (also for non-logged-in users) for the display of needs-based advertising and to inform other users of the social network about your activities on our website. Through the plugins, we offer you the opportunity to interact with the social networks and other users, so that we can improve our offer and make it more interesting for you as a user.

The legal basis for the use of the plugins is Art. 6 para. 1 p. 1 lit. a DS-GVO.

You have the right to object to the creation of these user profiles, whereby you must contact Facebook to exercise this right.

Settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings at https://www.facebook.com/settings?tap=ads. Further information on the purpose and scope of the data collection and its processing as well as your respective rights by and against Facebook can be found at http://www.facebook.com/policy.php, http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo.

Facebook Insights:

Meta-Platforms Ireland Ltd also provides us as Facebook Fanpage operators with statistics (Facebook Insights) that show how our Fanpage is being used. You can find more precise and detailed information about this here: https://www.facebook.com/business/a/page/page-insights

We ourselves have no influence on the storage of data in the Facebook Insights. However, according to Art. 26 DSGVO, we are jointly responsible for this data as soon as we operate a Facebook Fanpage. In this regard, the agreement between Meta-Platforms Ireland Ltd and us automatically applies. You can find more information here: https://www.facebook.com/legal/terms/page_controller_addendum

Note: If you do not want your usage data, to be used in the Facebook Insights data provided for us by Meta-Platforms Irleland Ltd, then you should not visit our Facebook Fanpage.

§ 12 Rights of the data subject

If personal data is processed by you, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:

Right to information,

Right to rectification

Right to restriction of processing,

Right to deletion

Right to information

Right to data portability.

Right to object to processing

Right to withdraw consent granted under data protection law

Right not to apply an automated decision

Right to complain to a supervisory authority

1. right to information

(1) You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If such a

processing exists, you may at any time request from the controller free of charge information about the personal data stored about you and about the following information:

(a) the purposes for which the personal data are processed;

b) the categories of personal data which are processed;

c) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;

d) the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period;

e) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

(f) the existence of a right of appeal to a supervisory authority;

(g) any available information on the origin of the data, if the personal data are not collected from the data subject;

(h) the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

(2) You have the right to request information about whether the personal data concerning you are transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.

2. right to rectification

You have a right to rectification and/or completion without undue delay vis-à-vis the controller, insofar as the personal data processed concerning you are inaccurate or incomplete.

3. right to restriction of processing

(1) Under the following conditions, you may request the controller to immediately restrict the processing of personal data concerning you:

(a) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

b) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;

(c) the controller no longer needs the personal data for the purposes of processing, but you need it for the establishment, exercise or defense of legal claims; or

(d) if you have objected to the processing pursuant to Article 21(1) DSGVO and it is not yet clear whether the controller’s legitimate grounds override your grounds.

(2) If the processing of personal data relating to you has been restricted, such data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense 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 Union or a Member State. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. right to erasure

(1) You may request the controller to erase the personal data concerning you without undue delay if one of the following reasons applies:

(a) the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

b) You revoke your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a DSGVO and there is no other legal basis for the processing.

c) You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.

d) The personal data concerning you have been processed unlawfully.

e) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.

(f) the personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

(2) If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.

(3) The right to erasure does not exist insofar as the processing is necessary for

(a) for the exercise of the right to freedom of expression and information;

(b) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

c) for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, where the right referred to in section (a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or

e) for the assertion, exercise or defense of legal claims.

5. right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification/erasure/restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right vis-à-vis the controller to be informed about these recipients.

6 Right to data portability

(1) You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that

a) the processing is based on consent pursuant to Art. 6 (1) a DSGVO or Art. 9 (2) a DSGVO or on a contract pursuant to Art. 6 (1) b DSGVO and

(b) the processing is carried out with the aid of automated procedures.

(2) In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

(3) The right to data portability shall not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

(4) To assert the right to data portability, the data subject may contact the controller at any time.

7. right of objection

(1) You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.

(2) The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

(3) If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

(4) You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.

(5) To exercise the right to object, the data subject may contact the controller directly.

8 Right to revoke the declaration of consent under data protection law.

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. For this purpose, you can contact the controller.

9 Automated decision in individual cases including profiling.

(1) You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects vis-à-vis you or similarly significantly affects you. This does not apply if the decision

a) is necessary for the conclusion or performance of a contract between you and the controller,

b) is permissible on the basis of legal provisions of the Union or the Member States to which the controller is subject and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests, or

(2) However, such decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and

appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.

(3) With regard to the cases mentioned in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, which include at least the right to obtain the intervention of a data subject on the part of the controller, to express his or her point of view and to contest the decision.

(4) If the data subject wishes to exercise the rights concerning automated decisions, he or she may, at any time, contact the controller.

10. right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

§13 Changes to the privacy policy

We reserve the right to modify our privacy practices and this Policy to adapt them to changes in relevant laws or regulations, if any, or to better meet your needs. Possible changes to our privacy practices will be posted here accordingly. Please refer to the current version date of the Privacy Policy.

Addendum: This privacy statement applies to https://www.cph-hotels.com and other websites of CPH Hotelmarketing GmbH:

* Additional web offers created with blogger.com:

https://blog.cph-hotels.com

https://hotelbewertungen.cph-hotels.com

https://www.lieblingsplatz-in-meiner-stadt.de

https://romantik-am-rhein.cph-hotels.com

https://weihnachtsgeschichte.cph-hotels.com