Privacy policy
With this privacy policy, we provide information about which personal data we process in connection with our activities and operations, including our website. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.
Individual or additional activities and operations may be subject to additional privacy statements as well as other legal documents such as General Terms and Conditions (GTC), Terms of Use or Conditions of Participation.
1. contact addresses
Responsibility for the processing of personal data:
Fabienne Hormann-Wettach
Hotel Brienz GmbH
Main street 254
3855 Brienz on the lake
In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.
2. Terms and legal basis
2.1 Terms
Data subject: Natural person about whom we process personal data.
Personal data: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: data on trade union, political, religious, or ideological views and activities; data on health, privacy, or ethnic or racial origin; genetic data; biometric data that uniquely identifies a natural person; data on criminal and administrative sanctions or prosecutions, and data on social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, saving, changing, distributing, linking, destroying, and using personal data.
2.2 Legal basis
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
3. Type, scope, and purpose of personal data processing
We process personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also constitute particularly sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, insofar as such processing is permissible.
We process personal data, where necessary, with the consent of the individuals concerned. In many cases, we can process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also ask individuals for their consent even if their consent is not required.
We process personal data for the period of time necessary for the respective purpose. We anonymize or delete personal data, in particular in accordance with statutory retention and limitation periods.
4. Disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use.
We may disclose personal data within the scope of our activities and operations, in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.
5. Communication
We process personal data in order to communicate with individuals, authorities, organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example by letter or email. We may store such data in an address book or similar tools.
Third parties who provide us with data about other persons are obliged to independently ensure the data protection of these persons. In particular, they must guarantee that such data is accurate and may be transmitted.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We can also use such services to manage and otherwise process the data of the persons concerned beyond direct communication.
6. Data security
We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the processed personal data, without, however, being able to guarantee absolute data security.
Access to our website and our other digital presence is provided using transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption.
Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the processing of personal data by intelligence services, police stations, and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.
7. Personal data abroad
We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular for the purpose of processing it or having it processed there.
We may disclose personal data to any country in the world and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council.
We may disclose personal data to countries whose laws do not guarantee adequate data protection, provided that adequate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of guarantees.
8. Rights of data subjects
8.1 Data protection claims
We grant data subjects all rights under applicable law. Data subjects have the following rights in particular:
- Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
- Correction and restriction: Data subjects may correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
- Opportunity to express your own point of view and human review: Affected persons can express their own point of view and request verification by a human being in the case of decisions that are based exclusively on automated processing of personal data and have legal consequences for them or significantly affect them (automated individual decisions).
- Deletion and objection: Data subjects may have personal data deleted ("right to be forgotten") and object to the processing of their data with future effect.
- Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.
We may postpone, restrict, or refuse the exercise of data subjects' rights within the legally permissible scope. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the basis of confidentiality obligations, overriding interests, or the protection of other persons. We may also refuse to delete personal data in whole or in part, in particular on the basis of statutory retention obligations.
We may, in exceptional cases, charge a fee for exercising these rights. We will inform the persons concerned in advance of any costs.
We are obligated to identify affected persons who request information or assert other rights by taking appropriate measures. Affected persons are obligated to cooperate.
8.2 Legal protection
Affected persons have the right to enforce their data protection claims through legal action or to file a complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal agencies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
9. Use of the website
9.1 Cookies
We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as "session cookies" or for a specific period of time as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable us, in particular, to recognize a browser when it next visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
Cookies can be completely or partially deactivated, restricted, or deleted at any time in your browser settings. Browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively seek your express consent to the use of cookies, at least to the extent required by applicable law.
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).
9.2 Logging
We can log at least the following information for each access to our website and our other digital presence, provided that this information is determined or transmitted as standard when such accesses are made to our digital infrastructure: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpages of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence is permanently available, user-friendly, and reliable. The information is also necessary to ensure data security, including by third parties or with the help of third parties.
9.3 Tracking pixels
We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is recorded in log files.
10. Notifications and communications
10.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels may also record the use of notifications and messages on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner, as well as permanently, securely, and reliably, based on the needs and reading habits of the recipients.
10.2 Consent and objection
You must always consent to the use of your email address and other contact details, unless such use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double confirmation of your consent. In this case, you will receive a message with instructions for double confirmation. We may log the consents obtained, including IP address and timestamp, for evidence and security reasons.
You can object to receiving notifications and communications such as newsletters at any time. By objecting, you can also object to the statistical recording of usage for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.
10.3 Service providers for notifications and communications
We send notifications and communications with the help of specialized service providers.
11. Social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland.
The general terms and conditions (GTC) and terms of use, as well as privacy policies and other provisions of the individual operators of such platforms, also apply in each case. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
12. Third-party services
We use services from specialized third parties to enable us to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services enable us, among other things, to embed functions and content in our website. When embedding such content, the services used collect the IP addresses of users, at least temporarily, for technical reasons.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) in some cases for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Handling of data protection & protective measures, " data protection declaration, "More information on how Google uses personal data, " "Google is committed to complying with applicable data protection laws, " "Guide to data protection in Google products, " "How we use data from websites or apps on which our services are used," Cookie policy, "Advertising you can control" (settings for personalized advertising).
12.1 Digital infrastructure
We use services from specialized third parties to make use of required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
12.2 Advertising
We take advantage of the opportunity to display targeted advertising for our activities and operations on third-party platforms such as social media platforms and search engines.
We want to use this type of advertising to reach people who are already interested in our activities and services or who may be interested in them (remarketing and targeting). To do this, we may transfer relevant information—including personal data—to third parties who enable such advertising. We can also determine whether our advertising is successful, i.e., whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may assign your use of our website to your profile there.
We use in particular:
- Google Ads: Search engine advertising; provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, using various domain names—in particular double-click.net, google-adservices.com, and google-syndication.com—for Google Ads, privacy policy for advertising, "Manage ads displayed directly via ads."
- Meta Ads: Social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the US); data protection information: targeting, including retargeting, in particular with the Meta Pixel and Custom Audiences including Lookalike Audiences, privacy policy, "advertising preferences" (user registration required).
13. Measuring success and reach
We try to measure the success and reach of our activities and operations. In this context, we can also measure the impact of third-party feedback or test how different parts or versions of our digital presence are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content, or make improvements.
In most cases, the IP addresses of individual users are recorded for the purpose of measuring success and reach. In this case, IP addresses are always shortened ("IP masking") in order to comply with the principle of data minimization through the corresponding pseudonymization.
Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively on a pseudonymous basis and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service.
We use in particular:
- Google Marketing Platform: Success and reach measurement, in particular with Google Analytics; provider: Google; Google Marketing Platform-specific information: measurement also across different browsers and devices (cross-device tracking), privacy policy for Google Analytics, "Browser add-on to disable Google Analytics."
- Google Tag Manager: Integration and management of Google and third-party services, in particular for measuring success and reach; provider: Google; Google Tag Manager-specific information: Privacy policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.
14. Final notes on the privacy policy
We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current privacy policy on our website.