Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as „data“) we process, for what purposes and to what extent. The Privacy Policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the „Online Offer“).

The terms used are not gender-specific.

Stand: 30. November 2024

Outline

• Introduction
• Person in charge
• Overview of processing
• Relevant legal bases
• Safety measures
• Transfer of personal data
• Data processing in third countries
• Deletion of data
• Use of cookies
• Provision of the online offer and web hosting
• Contact and Enquiry Management
• Advertising communication via e-mail, post, fax or telephone
• Presence in social networks (social media)
• Plugins and embedded functions and content
• Modification and update of the Privacy Policy
• Rights of data subjects
• Definitions

Person in charge

a2 Beteiligungs GmbH

Brunnhuberstraße 24

4501 Neuhofen an der Krems

E-Mail-Adresse:

a2.aigner@gmx.at

Overview of processing

The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed

• File dating.
• The contact date.
• Content Data.
•  Usage.
• Meta/Communication Data.

Categories of data subjects

•  Communication.
•  User.

Purposes of processing

• Provision of contractual services and customer service.
• Contact requests and communication.
• Security Measures.
• Direct marketing.
• Managing and responding to requests.
•  Feedback.
•  Marketing.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or purposes.
• Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or to take steps taken at the request of the data subject prior to entering into a contract.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – FADP). In particular, the Data Protection Act contains special provisions on the right of access, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases.

Safety measures

In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability and separation. We have also put in place procedures to ensure that the rights of data subjects are exercised, that data is deleted and that data is compromised. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technical design and through data protection-friendly default settings.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transfer of personal data

As part of our processing of personal data, the data may be transmitted to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to explicit consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents to processing are revoked or other permissions cease to apply (e.g. if the purpose of the processing of this data has ceased to apply or it is not necessary for the purpose). Unless the data is deleted because it is necessary for other and legally permissible purposes, its processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or the storage of which is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notice may also contain further information on the retention and deletion of data, which applies primarily to the respective processing.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the accessed content or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purposes of functionality, security and convenience of online offers as well as for the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with the legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. In particular, consent is not necessary if the storage and reading of the information, i.e. also of cookies, is absolutely necessary in order to provide the users with a telemedia service (i.e. our online offer) that they expressly request. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.

Information on data protection legal bases: The legal basis on which we process users‘ personal data with the help of cookies depends on whether we ask users for consent. If the users consent, the legal basis for the processing of their data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing processes.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

• Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via the settings of their browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further information on processing processes, procedures and services:

• Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of the users to the use of cookies, or the processing and providers mentioned in the context of the cookie consent management procedure, can be obtained, as well as managed and revoked by the users. In this case, the declaration of consent is stored in order not to have to repeat its query again and to be able to prove consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or his device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is formed and stored at the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.

Provision of the online offer and web hosting

We process users‘ data in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

• Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security Measures.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a „web host“); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called „server log files“. The server log files can include the address and name of the websites and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the load on the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.

Contact and Enquiry Management

When contacting us (e.g. via contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons will be processed insofar as this is necessary to answer the contact requests and any requested measures.

The response to contact inquiries as well as the administration of contact and enquiry data within the framework of contractual or pre-contractual relationships is carried out in order to fulfil our contractual obligations or to answer (pre-)contractual enquiries and otherwise on the basis of the legitimate interests in answering the enquiries and maintaining user or business relationships.

• Types of data processed: contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners.
• Purposes of processing: contact requests and communication; Managing and responding to requests; Feedback (e.g. collecting feedback via online form); Provision of our online offer and user-friendliness; Provision of contractual services and customer service.
• Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the request communicated. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in answering the concerns and our statutory retention obligations; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Advertising communication via e-mail, post, fax or telephone

We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.

Recipients have the right to revoke their consent at any time or to object to advertising communications at any time.

After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending you data for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the users, we also store the data necessary to avoid renewed contact (e.g. e-mail address, telephone number, name, depending on the communication channel).

• Types of data processed: inventory data (e.g. names, addresses); Contact details (e.g. e-mail, telephone numbers).
• Data subjects: Communication partners.
• Purposes of processing: Direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the area of the European Union. This can result in risks for users, for example, because it could make it more difficult to enforce the rights of users.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the user behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users‘ computers, in which the user’s usage behaviour and interests are stored. Furthermore, data may also be stored in the user profiles regardless of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.

• Types of data processed: contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

1. Instagram: Social network; Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
2. Facebook pages: Profiles within the social network Facebook – Together with Meta Platforms Ireland Limited, we are responsible for the collection (but not the further processing) of data of visitors to our Facebook page (so-called „fan page“). This data includes information about the types of content users view or interact with, or the actions they take (see „Things You and Others Do and Provide“ in Facebook’s Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language preferences, cookie data; see under „Device Information“ in the Facebook Data Policy: https://www.facebook.com/policy). As explained in Facebook’s Data Policy under „How do we use this information?“, Facebook also collects and uses information to provide analytics services called „Page Insights“ to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have concluded a special agreement with Facebook („Page Insights Information“, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to comply with the rights of data subjects (i.e. users can, for example, direct information or deletion requests to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the „Information on Page Insights“ (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guarantee of the level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; For more information, please see: Joint Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular with regard to the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as „third-party providers“). This can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as „content“).

The integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of these contents or functions. We make every effort to only use content whose respective providers use the IP address only for the delivery of the content. Third-party vendors may also use pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes. The „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 contain, among other things, technical information about the browser and the operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

• Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online offer and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

1. Google Fonts (obtained from Google Server): Acquisition of fonts (and symbols) for the purpose of a technically safe, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform display and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
2. YouTube videos: video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.

Modification and update of the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing we carry out make it necessary. We will inform you as soon as the changes require you to cooperate (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of data subjects

As a data subject, you are entitled to various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out on the basis of Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is related to such direct advertising.
• Right to withdraw consent: You have the right to revoke consent at any time.
• Right of access: You have the right to request confirmation as to whether the data in question is being processed and to access this data, as well as to obtain further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the legal requirements.
• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request that it be transmitted to another controller.
• Complaint to 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 habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the requirements of the GDPR.

Definitions

This section provides an overview of the terminology used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to serve understanding. The terms are sorted alphabetically.

• Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who identifies directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more special characteristics which are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
• Controller: „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.
• Processing: „Processing“ means any operation or set of operations which is performed on Personal Data, whether or not by automated means. The term is far-reaching and encompasses practically any handling of data, whether it is collecting, evaluating, storing, transmitting or deleting.

Terms and Conditions

Here you will find the link to our general terms and conditions.  Booking conditions:

In our house, the General Terms and Conditions for the Hotel Industry (AGBH) apply

http://www.hotelverband.at/down/AGBH_061115.pdf