(As of: May 2018)
We are delighted by your interest in our website www.ludinmuehle.de, our company, and our products and services.
At Hotel Ludinmühle GmbH & Co. KG, we understand that protecting your privacy when using our website is important to you. We therefore consider compliance with the applicable data protection laws and regulations to be a matter of course. Furthermore, we believe it is important that you, as our customer, always know when and how we collect, store and use your personal data.
Below, we provide information about the collection and other processing of personal data (e.g. storage, retrieval, modification and disclosure) when you use our website. Personal data means any information relating to an identified or identifiable natural person, such as your name, address, email address or user behaviour.
If we process personal data in connection with your use of our website, engage external service providers to perform certain functions or provide specific services or features on our website involving the processing of personal data, or intend to use your data for advertising purposes, we will provide detailed information below about the respective processes. In particular, we will explain which data is processed, the intended retention period or, at the very least, the criteria used to determine the retention period, as well as the applicable legal basis for each processing activity.
I. Name and Address of the Data Controller
The data controller within the meaning of the General Data Protection Regulation (GDPR), other national data protection laws of the EU Member States, and other data protection provisions is:
Hotel Ludinmühle GmbH & Co.KG
Brettental 31
79348 Freiamt
Telefon: +49 7645 9119-0
Mail: info@ludinmuehle.de
II. Contact Details of the Data Protection Officer
You can contact our Data Protection Officer, Mr Michael Sachner, by email at datenschutz@ludinmuehle.de or by post at our postal address, marked for the attention of “The Data Protection Officer”.
III. Collection and Storage of Personal Data, Including the Nature, Purpose, Legal Basis and Duration of Its Processing
§ 1 When Visiting the Website
When using our website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal access data that your browser transmits to our server in so-called server log files. The following data is collected as part of these server log files:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page accessed)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request originates
- Browser
- Operating system and its interface
- Language and version of the browser software
This data is evaluated exclusively to ensure the smooth operation of the website in terms of stability and security and to improve our services. It is subsequently deleted. The legal basis for processing this data is Art. 6(1)(f) GDPR. Our legitimate interest arises from the aforementioned purposes of data collection.
The data is also stored in the log files of our system. This data is not stored together with other personal data relating to the user.
The collection of data for the provision of the website and the storage of such data in log files are essential for the operation of the website. Consequently, users have no right to object to this data processing.
The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. In the case of data collected for the provision of the website, this is when the respective browsing session has ended.
In addition, we use cookies and analytics services when you visit our website. Further information on this can be found in Sections V and VI of this Privacy Policy.
§ 2 Use of Additional Services, Functions and Features of Our Website
In addition to the purely informational use of our website, we offer various services, features and functions that you may use if you are interested. As a rule, this requires you to provide additional personal data, which we use to provide the respective service. The above-mentioned principles regarding data processing also apply in these cases. The individual services, features and functions are described in more detail below.
(1) Contacting Us by Email or via the Contact Form
When you contact us using our contact form, submit a general enquiry or request a quotation, we store the information you voluntarily provide (your company name, email address, first and last name, address and, where applicable, telephone number) in order to respond to your enquiry.
Providing your company name, email address, first and last name and address details is mandatory. All other information is voluntary. We will respond by email or, if
IV. Disclosure of Personal Data
Your personal data will not be transferred to third parties for purposes other than those listed below.
We will only disclose your personal data to third parties if:
- You have given your explicit consent pursuant to Art. 6(1)(a) GDPR;
- The disclosure is necessary pursuant to Art. 6(1)(f) GDPR for the establishment, exercise or defence of legal claims, and there is no reason to believe that you have an overriding legitimate interest in preventing the disclosure of your data;
- There is a legal obligation to disclose the data pursuant to Art. 6(1)(c) GDPR; or
- The disclosure is legally permissible and necessary pursuant to Art. 6(1)(b) GDPR for the performance of contractual arrangements with you.
V. Use of Cookies
§ 1 Scope of Data Processing
In order to make visiting our website user-friendly and effective and to enable the use of certain functions, we use so-called cookies on various pages. Cookies are small text files that are stored on your device and save certain settings and data for exchange with our system via your browser. Cookies transmit certain information to the entity that sets them (in this case, us). Cookies cannot execute programs or transfer viruses to your computer.
Cookies do not contain any personal data and therefore cannot be directly assigned to any specific user. Please note that certain cookies may already be set as soon as you visit our website. This website uses the following types of cookies:
Essential / Functional Cookies: These cookies are necessary to enable the operation of our website. They include, for example, cookies that allow you to log in to the customer area.
Session Cookies: These cookies are automatically deleted when you close your browser. They include, in particular, session cookies, which store a so-called session ID. This allows different requests from your browser to be assigned to the same session. As a result, your computer can be recognised when you return to our website. Session cookies are deleted when you log out or close your browser.
Persistent Cookies: These cookies are automatically deleted after a predetermined period, which may vary depending on the cookie. You can delete cookies at any time via your browser's security settings.
You can configure your browser settings according to your preferences and, for example, reject third-party cookies or all cookies. You can also configure your browser to notify you whenever a cookie is set. Please refer to the relevant browser provider for further information. We would like to point out that if you reject cookies, you may not be able to use all the functions of this website.
The legal basis for the use of cookies is Art. 6(1)(f) GDPR. Our legitimate interest arises from the purposes outlined above, namely making our website more user-friendly and effective.
VI. Use of Analytics Tools
Web analytics services are used on our website for the purposes of tailoring our services to users' needs and for advertising purposes.
a. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, which are text files stored on your computer that enable an analysis of your use of the website. The information generated by the cookie about your use of this website is generally transmitted to and stored on a Google server in the USA.
IP Anonymisation
We have activated the IP anonymisation feature on this website. As a result, your IP address is shortened by Google within Member States of the European Union or other signatory states to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity and provide the website operator with other services relating to website and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data held by Google.
You can prevent cookies from being stored by adjusting your browser software settings accordingly. However, please note that in this case you may not be able to use all the functions of this website to their full extent.
You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address), as well as from processing this data, by downloading and installing the browser plugin available at the following link:
tools.google.com/dlpage/gaoptout
Alternatively, particularly when using browsers on mobile devices, you can prevent Google Analytics from collecting your data by clicking on the following link. An opt-out cookie will be set, preventing the collection of your data during future visits to this website.
Disable Google Analytics
The opt-out cookie is valid only in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will need to set the opt-out cookie again.
Data Processing Agreement
We have concluded a data processing agreement with Google and comply with the strict requirements imposed by the German data protection authorities when using Google Analytics.
We use Google Analytics to analyse and regularly improve the use of our website. The statistics obtained enable us to improve our services and make them more interesting and user-friendly for you.
In exceptional cases where personal data is transferred to the USA, Google has committed to the EU-US Privacy Shield Framework:
https://www.privacyshield.gov/EU-US-Framework
The legal basis for the use of Google Analytics is Art. 6(1)(f) GDPR. Our legitimate interest arises from the purposes outlined above.
Third-party provider information:
Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland
Fax: +353 (1) 436 1001
Terms of Service:http://www.google.com/analytics/terms/de.html
Privacy Overview:http://www.google.com/intl/de/analytics/learn/privacy.html
Privacy Policy:www.google.de/intl/de/policies/privacy
VII. Google Maps
Auf dieser Webseite nutzen wir das Angebot von Google Maps. Dadurch können wir Ihnen interaktive Karten direkt in der Website anzeigen und ermöglichen Ihnen die komfortable Nutzung der Karten-Funktion.
Durch den Besuch auf der Website erhält Google die Information, dass Sie die entsprechende Unterseite unserer Website aufgerufen haben. Zudem werden die unter § 3 dieser Erklärung genannten Daten übermittelt. Dies erfolgt unabhängig davon, ob Google ein Nutzerkonto bereitstellt, über das Sie eingeloggt sind, oder ob kein Nutzerkonto besteht. Wenn Sie bei Google eingeloggt sind, werden Ihre Daten direkt Ihrem Konto zugeordnet. Wenn Sie die Zuordnung mit Ihrem Profil bei Google nicht wünschen, müssen Sie sich vor Aktivierung des Buttons ausloggen. Google speichert Ihre Daten als Nutzungsprofile und nutzt sie für Zwecke der Werbung, Marktforschung und/oder bedarfsgerechten Gestaltung seiner Website. Eine solche Auswertung erfolgt insbesondere (selbst für nicht eingeloggte Nutzer) zur Erbringung von bedarfsgerechter Werbung und um andere Nutzer des sozialen Netzwerks über Ihre Aktivitäten auf unserer Website zu informieren. Ihnen steht ein Widerspruchsrecht zu gegen die Bildung dieser Nutzerprofile, wobei Sie sich zur Ausübung dessen an Google richten müssen.
Weitere Informationen zu Zweck und Umfang der Datenerhebung und ihrer Verarbeitung durch den Plug-in-Anbieter erhalten Sie in den Datenschutzerklärungen des Anbieters. Dort erhalten Sie auch weitere Informationen zu Ihren diesbezüglichen Rechten und Einstellungsmöglichkeiten zum Schutze Ihrer Privatsphäre: http://www.google.de/intl/de/policies/privacy. Google verarbeitet Ihre personenbezogenen Daten auch in den USA und hat sich dem EU-US Privacy Shield unterworfen, https://www.privacyshield.gov/EU-US-Framework. Informationen zum Drittanbieter: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;
VIII. Enquiries, Online Bookings and Gift Voucher Sales via Vioma
We use the booking system provided by vioma GmbH, Offenburg (vioma BOOKING / Clearing Station) for enquiries and online bookings of our rooms and services, as well as for the sale of gift vouchers.
As part of the booking process and the sale of gift vouchers, the personal data required for these purposes is processed. This includes, in particular, your name, address, contact details, arrival and departure dates, where applicable, the services booked, the booking or gift voucher amount, and any additional information you may provide.
The processing of this data is carried out for the purpose of initiating and fulfilling the accommodation contract in accordance with Art. 6(1)(b) GDPR. vioma GmbH processes the data on our behalf on the basis of a Data Processing Agreement pursuant to Art. 28 GDPR.
The data will be deleted as soon as it is no longer required for the fulfilment of the contract, provided that no statutory retention obligations require its continued storage.
IX. ADDITIVE+ LANDINGPAGE - Online Marketing and Landing Pages
Beside our website we do also operate optimized landing pages for means of hotel online marketing. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”), our partner in the field of hotel digital marketing. The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
You can prevent the data collection connected to your use of our online services through cookies and the processing of this data by Google, by installing the browser-plugin available at the following link:
https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence. Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. Only by clicking on the corresponding button you consent to the use of these cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.
X. ADDITIVE+ MARKETING AUTOMATION - Direct Marketing
In order to increase customer loyalty and to sell our services and additional services we use hotel online marketing software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”) within the field of hotel marketing automation.
Therefore your data, which we gather and process in connection with your request, reservation, order, activation, registration or the transmission of other contact forms on our website, will be analysed and used to provide you with automatically generated offers for our services and additional services. Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.
You can deny the use of your data for this purpose anytime by clicking on the “unsubscribe” link in the respective message.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the prevention of competitive disadvantages, the increase in brand awareness and the maximisation of our economic success through an optimal use of the acquired contacts.
XI. Your Rights
If we process your personal data, you are entitled to the following rights with regard to your personal data:
Right of Access, Art. 15 GDPR
You have the right to obtain confirmation from the data controller as to whether or not personal data concerning you is being processed. If this is the case, you have the right to request access to the following information:
- The purposes for which the personal data is being processed;
- The categories of personal data being processed;
- The recipients or categories of recipients to whom your personal data has been or will be disclosed, in particular recipients in third countries or international organisations. In such cases, you may request information about the appropriate safeguards pursuant to Art. 46 GDPR relating to the transfer;
- The envisaged period for which your personal data will be stored or, if specific information is not available, the criteria used to determine that period;
- The existence of your right to request the rectification or erasure of your personal data, the restriction of processing by the data controller, or to object to such processing;
- The existence of your right to lodge a complaint with a supervisory authority;
- Any available information about the source of the data, where the personal data was not collected directly from you;
- The existence of automated decision-making, including profiling, pursuant to Art. 22(1) and (4) GDPR and, at least in these cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.
Right to Rectification, Art. 16 GDPR
You have the right to obtain from the data controller, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed.
The data controller must carry out the rectification without undue delay.
Right to Erasure, Art. 17 GDPR
a) Obligation to Erase
You have the right to request that the data controller erase personal data concerning you without undue delay. The data controller is obliged to erase such data without undue delay where one of the following grounds applies:
- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- You withdraw your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
- You object to the processing pursuant to Art. 21(1) GDPR (see Section X) and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) GDPR.
- The personal data has been processed unlawfully.
- The personal data must be erased to comply with a legal obligation under Union law or the law of a Member State to which the data controller is subject.
- The personal data was collected in relation to the offer of information society services pursuant to Art. 8(1) GDPR.
b) Notification to Third Parties
Where the data controller has made personal data concerning you public and is obliged pursuant to Art. 17(1) GDPR to erase it, the controller shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other data controllers processing the personal data that you, as the data subject, have requested the erasure of all links to, copies of or reproductions of that personal data.
c) Exceptions
The right to erasure does not apply insofar as processing is necessary:
- For exercising the right of freedom of expression and information;
- For compliance with a legal obligation requiring processing under Union or Member State law to which the data 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;
- For reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
- For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Art. 89(1) GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- For the establishment, exercise or defence of legal claims.
Right to Restriction of Processing, Art. 18 GDPR
You have the right to request the restriction of processing of your personal data under the following conditions:
- If you contest the accuracy of your personal data, for a period enabling the data controller to verify the accuracy of the personal data;
- If the processing is unlawful and you oppose the erasure of the personal data and instead request the restriction of its use;
- If the data controller no longer needs the personal data for the purposes of processing, but you require it for the establishment, exercise or defence of legal claims; or
- If you have objected to processing pursuant to Art. 21(1) GDPR (see Section X) and it has not yet been established whether the legitimate grounds of the data controller override your interests.
Where the processing of your personal data has been restricted, such data may, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims, 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 you have obtained a restriction of processing under the conditions outlined above, you will be informed by the data controller before the restriction is lifted.
Right to Notification, Art. 19 GDPR
If you have exercised your right to rectification, erasure or restriction of processing with regard to the data controller, the controller is obliged to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom your personal data has been disclosed, unless this proves impossible or involves disproportionate effort.
You also have the right to be informed by the data controller about these recipients.
Right to Data Portability, Art. 20 GDPR
You have the right to receive the personal data concerning you, which you have provided to the data controller, in a structured, commonly used and machine-readable format.
You also have the right to transmit this data to another data controller without hindrance from the data controller to whom the personal data was originally provided, provided that:
- The processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, or on a contract pursuant to Art. 6(1)(b) GDPR; and
- The processing is carried out by automated means.
In exercising this right, you also have the right to request that your personal data be transmitted directly from one data controller to another, where technically feasible. This must not adversely affect the rights and freedoms of others.
Your right to erasure remains unaffected.
The right to data portability does 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 data controller.
Right to Object, Art. 21 GDPR
You have the right to object to the processing of your personal data on grounds relating to your particular situation, as well as the right to object to the processing of your data for advertising purposes.
Further information can be found in Section X of this Privacy Policy.
Right to Withdraw Consent under Data Protection Law
You may withdraw any consent you have given to the processing of your personal data at any time by contacting the data controller.
Please note that the withdrawal of consent only takes effect for the future. The lawfulness of any processing carried out on the basis of your consent before its withdrawal remains unaffected.
Automated Individual Decision-Making, Including Profiling, Art. 22 GDPR
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
This does not apply if the decision:
- Is necessary for entering into, or the performance of, a contract between you and the data controller;
- Is authorised by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
- Is based on your explicit consent.
In cases (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests. These measures must include, at a minimum, the right to obtain human intervention on the part of the data controller, to express your point of view and to contest the decision.
Furthermore, decisions based solely on automated processing must not be based on special categories of personal data referred to in Art. 9(1) GDPR, unless Art. 9(2)(a) or (g) GDPR applies and suitable measures have been taken to safeguard your rights and freedoms and legitimate interests.
Right to Lodge a Complaint with a Supervisory Authority, Art. 77 GDPR
You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data.
You may submit your complaint to the supervisory authority in the Member State where you reside, where you work, or where the alleged infringement took place.
The supervisory authority with which the complaint has been lodged will inform you, as the complainant, about the progress and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.
Exercising Your Rights
You may exercise any of the above rights by sending us an informal notification. Please address your request to:
Hotel Ludinmühle GmbH & Co. KG
Brettental 31
79348 Freiamt
Germany
Telephone: +49 7645 9119-0
Email: info@ludinmuehle.de
XII. Right to Object pursuant to Art. 21 DSGVO
Einzelfallbezogenes Widerspruchsrecht:
You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data which is based on Art. 6(1)(e) GDPR (processing of data in the public interest) and Art. 6(1)(f) GDPR (processing of data for the purposes of the legitimate interests pursued by the data controller or a third party). This also applies to profiling based on these provisions.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
Right to Object to the Processing of Data for Advertising Purposes
In certain cases, we process your personal data for the purpose of direct marketing.
You have the right to object at any time to the processing of your personal data for the purposes of such advertising. This also applies to profiling insofar as it is related to such direct marketing.
If you object to the processing of your personal data for direct marketing purposes, we will no longer process your personal data for these purposes.
In the above cases, you may submit your objection informally. It should preferably be sent by email with the subject line “Objection” to:
Hotel Ludinmühle GmbH & Co. KG
Brettental 31
79349 Freiamt
Germany
Email: info@ludinmuehle.de
XIII. Data Security
We make every effort to protect your personal data by implementing all available technical and organisational measures to ensure that it cannot be accessed by third parties.
However, complete data security cannot be guaranteed when communicating by email. We therefore recommend that you use postal mail when sending confidential information.