This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services by the brands of Rhein Kultour & Touristik and the websites, functions and content associated with it, as well as external online presences, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Rhein Kultour & Touristik UG
Richard Müller Str. 3d
79206 Breisach
Email: office@freiburg-kultour.com
Managing Director/ Owner: Markus Brall / Susanne Brall
Visitors and users of the above-mentioned websites (hereinafter we also refer to the data subjects collectively as “users”) and users of the Gom-Sys software application (hereinafter we also refer to the data subjects collectively as “users”)
Purpose of the processing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “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 (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
“Pseudonymization” means the processing of personal data in such a manner 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 to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. For users from the area of application of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the data protection declaration:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for the processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6(1)(e) GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which it was collected is governed by the provisions of Art. 6 (4) GDPR.
The processing of special categories of data (in accordance with Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If Rhein-Kultour & Touristik UG discloses data to other persons and companies (processors, joint controllers or third parties) in the course of processing, transmits it to them or otherwise grants them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary to fulfill the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
Data from the websites and applications of Rhein-Kultour & Touristik UG are not disclosed within Rhein-Kultour & Touristik UG; all employees with access to these data have signed a confidentiality clause.
No data is transferred to third countries.
Right to information: Users and customers have the right to request confirmation as to whether the data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: In accordance with legal requirements, users and customers have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that the data in question be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
Complaint to the supervisory authority: You also have the right to lodge a complaint with the competent supervisory authority in accordance with the statutory provisions.
You have the right to withdraw your consent with effect for the future.
Right of objection
Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR.
Cookies and right to object to direct advertising
Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping cart in an online store or a login status, for example, can be stored in such a cookie. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if the user visits the website after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).
Websites
No direct advertising is carried out via the websites. Only analytical cookies are used.
Gom-Sys application
*.gom-sys.com only uses functional cookies:
We may use temporary and permanent cookies and provide information about this in our privacy policy.
If we ask users for their consent to the use of cookies (e.g. as part of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal cookies of the users are processed in accordance with the following explanations in the context of this data protection declaration on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR). GDPR) or if the use of cookies is necessary for the provision of our contract-related services, pursuant to Art. 6 para. 1 lit. b. GDPR, or if the use of cookies is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us pursuant to Art. 6 para. 1 lit. e. GDPR, processed.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.
If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted. 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.
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
We process user data as part of our contractual service, which includes the provision of the booking software.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., as part of the evaluation and performance measurement of marketing measures).
We process customer data on behalf of the user.
We only process data that is entered by the user and that is necessary for the proper processing of a customer booking.
In principle, we do not process special categories of personal data, unless these are part of commissioned processing. The data subjects include our customers, interested parties and their customers, users, website visitors or employees and third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that is required to justify and fulfill the contractual services and point out the necessity of their disclosure. Disclosure to external parties does not take place. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements of order processing in accordance with Art. 28 GDPR and do not process the data for any purposes other than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (6 years, pursuant to Section 257 (1) HGB, 10 years, pursuant to Section 147 (1) AO). In the case of data disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.
We process the data of our users and customers (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
In principle, we do not process special categories of personal data unless these are part of commissioned or contractual processing.
We process data that is required to justify and fulfill the contractual services and point out the necessity of its disclosure, unless this is evident to the contractual partners. Disclosure to external persons or companies only takes place if it is necessary within the framework of a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements.
As part of the use of our online service xxx.gom-sys.com, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. GDPR.
The data is deleted when it is no longer required for the fulfillment of contractual or statutory duties of care and for dealing with any warranty and comparable obligations, whereby the necessity of retaining the data is reviewed every three years; otherwise, the statutory retention obligations apply.
We process data in the context of administrative tasks and the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting and archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee agencies.
In order to operate our business economically and to identify market trends and user requirements, we analyze the data we have on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR. GDPR, whereby the data subjects include users of our online offer Gom-Sys.
The analyses are carried out for the purpose of business evaluations and product development. In doing so, we can take into account the profiles of registered users with information, e.g. on the services they have used. We use the analyses to increase user-friendliness, optimize our offering and improve business efficiency. The analyses serve us alone and are not disclosed externally.
We do not use Google Cloud services.
We do not use Mircosoft cloud services
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the contact details will be used to process the contact request and its processing in accordance with Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other inquiries) GDPR. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete the requests if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply.
There is no communication via WhatsApp Manager.
There is no communication via WhatsApp Manager.
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract). Art. 28 GDPR (conclusion of order processing contract).
We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Google Tag Manager is only used on our websites, but not on the booking software xxx.gom-sys.com and is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users’ personal data, please refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.
We only use Google Analytics on our websites, but not on the booking software xxx.gom-sys.com. Google Analytics is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.
No data is transferred to a Google server in the USA.
If we ask users for their consent (e.g. as part of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR) are processed.
We use Google Analytics to display the ads placed by Google and its partners within advertising services only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users.
We use the online marketing process Google “AdWords” to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products that they have shown an interest in on other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google advertising network is active are accessed, a code from Google is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user has visited, which content they are interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, time of visit and other information about the use of the online offer.
We do not use individual “conversion cookies”.
If we ask users for their consent (e.g. as part of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal data of users are processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR) are processed.
We do not use Facebook Pixels
We maintain online presences within social networks and platforms in order to communicate with the users and interested parties active there and to inform them about our services.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data is generally processed for market research and advertising purposes. For example, usage profiles can be created from the usage 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 platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is based on our legitimate interests in effective user information and communication with users in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR. If the users are asked by the respective providers of the platforms for consent to the data processing described above, the legal basis for the processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.
For a detailed description of the respective processing and the opt-out options, we refer to the following linked information from the providers.
In the case of requests for information and the assertion of user 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 user’s data and can take appropriate measures and provide information directly. If you still need help, you can contact us:
We integrate the fonts (“Google Fonts”) of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. According to Google, user data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and consideration of possible licensing restrictions for their integration. Privacy policy: https://www.google.com/policies/privacy/.