1. Introduction

In the following, we provide information about the collection of personal data when using

●       our applications https://numastays.com (hereinafter "applications")

●       and our mobile app (hereinafter "app", applications and app together "applications")

●       our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Numa Group SE, Potsdamer Str. 68a, 10785 Berlin, Germany, email: privacy@numastays.com. We are legally represented by Christian Gaiser, Lukas Zyla, Dimitri Chandogin, Gerhard Maringer.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

More specific information on the delimitation of responsibilities between Numa Group SE and the national numa companies can be found below 4.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

●       Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.

●       Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.

●       Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.

●       Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our applications.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

●       Right of access,

●       Right to correction or deletion,

●       Right to limit processing,

●       Right to object to the processing,

●       Right to data transferability,

●       Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

1.10. Customer account

Guests can open a customer account on our applications. We process the data requested in this context based on the consent of the site visitor. Legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR.

The consent may be revoked at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. If the consent is revoked we will delete the data insofar as we are not obliged or have a right to retain it further.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

We send newsletters with the tools

●       SendGrid of the provider Twilio, Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA (privacy policy: https://www.twilio.com/legal/privacy). The provider processes content, usage, meta/communication data and contact data in the process in the USA.

●       HubSpot of the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: https://legal.hubspot.com/privacy-policy). The provider processes content, usage, meta/communication data and contact data in the process in the USA.

●       Revinate Inc, 1 Letterman Drive Building C, Suite CM 100, San Francisco, California 94129, USA (privacy policy: https://www.revinate.com/privacy). The provider processes content, usage, meta/communication data and contact data in the USA.

●       WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland (privacy policy: https://www.whatsapp.com/legal/updates/privacy-policy-eea?lang=en). The provider processes content, usage, meta/communication data and contact data in the USA.

3. Data processing on our applications

3.1. Informative use of our applications

During the informative use of the applications, i.e. when visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our applications. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

●       IP address

●       Date and time of the request

●       Time zone difference to Greenwich Mean Time (GMT)

●       Content of the request (specific page)

●       Access status/HTTP status code

●       Amount of data transferred in each case

●       Website from which the request comes

●       Browser

●       Operating system and its interface

●       Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2. Web hosting and provision of the applications

Our applications are hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sàrl, Avenue John F. Kennedy 38, 1855 Luxemburg, Luxemburg. In doing so, the provider processes the personal data transmitted via the applications, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/.

It is our legitimate interest to provide our applications, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Our applications are hosted by Vercel. The provider is Vercel Inc., 340 S Lemon Ave Unit 4133 Walnut, CA, USA. In doing so, the provider processes the personal data transmitted via the applications, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at https://vercel.com/legal/privacy-policy.

It is our legitimate interest to provide a applications, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

The legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We use the content delivery network Cloudfront (Amazon AWS) for our applications. The provider is Amazon Web Services, Inc., P.O. Box 81226 Seattle, WA 98108-1226 USA. The provider thereby processes the personal data transmitted via the applications, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/?nc1=f_pr.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We use the content delivery network Vercel for our applications. The provider is Vercel Inc., 340 S Lemon Ave Unit 4133 Walnut, CA, USA. The provider thereby processes the personal data transmitted via the applications, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at https://vercel.com/legal/privacy-policy.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

3.3. Vacant positions

We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.

The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.

3.4. Bookings via the applications

Users can make bookings via our applications. In doing so, we process the following personal data as part of the booking process:

●       IP-address

●       Name

●       E-mail address

●       Phone number (optional)

●       Address

●       Company name (if applicable)

●       Date of arrival and expected departure

●       Number of accompanying persons

The data is processed to fulfill the contract concluded with the respective guest (Art. 6 para. 1 p. 1 lit. b GDPR).

3.4.1. Check-In process on the applications

We offer a facilitated check-in process over our applications. For this purpose, we offer guests two options:

●       Option 1: The check-in is carried out by verifying the ID document and reading the information from the document on the basis of a data protection consent given before the start of the check-in (Art. 6 para. 1 sentence 1 lit. a) GDPR). For this purpose, we use the service provider Incode (​Incode Technologies, Inc., 221 Main Street, Suite 520, San Francisco, CA 94105, USA​). The provider processes First and last name, E-Mail address, information about the guest's stay, all information included in the ID document and a copy of the ID document. The processing takes place exclusively in the European Union. The purpose of the processing is, on the one hand, to offer guests a quick and convenient way to carry out self-check-in, namely to complete it directly via the Numa applications. On the other hand, the purpose of the processing is also to prevent crime, protect property and ensure the accountability of guests.

●       Option 2: Alternatively, guests can choose to check in via video call (similar to a physical reception desk in a hotel). The purpose of the processing is the operation of a digital operation of our business. In this case, the following personal data is processed: First and last name, E-Mail address, date of birth, and information about the guest's stay. The legal basis for this processing is Art. 6 para. 1 s. 1 lit. f as well as Art. 6 para. 1 s. 1 lit. b GDPR. We have a legitimate interest to maintain a digital operation of our accommodation and we process your date of birth to verify your legal age and capacity to contract.         

Germany: If the guest is not a German citizen, the ID document is also processed for the purposes of complying with §§ 29 BMG. The legal basis for this processing is therefore Art. 6 para. 1 s. 1 lit. c GDPR. If such cases, we are also obliged to share the data with German authorities, and, in accordance with § 30 para. 4 BMG, to keep the data for one year from the date of departure of the accommodated person and to destroy it within three months after the expiry of the retention period.

Austria: If the guest is not an Austrian citizen, the ID data is processed for the purposes of complying with the Austrian Reporting Act (§ 5 MeldeG). The legal basis for this processing is Art. 6 para. 1 s. 1 lit. c GDPR. In accordance with § 19 para. 4 of the Reporting Regulation (MeldeV-DVO), we are obliged to keep the data for 7 years from the date of the last entry.

Belgium: If the guest is not a Belgian citizen, the ID data is processed for the purposes of complying with the Law of March 1, 2007 (Articles 141 to 147) and the Royal Decree of April 27, 2007. The legal basis for this processing is Art. 6 para. 1 s. 1 lit. c GDPR. In accordance with these regulations, we are obliged to keep the data for 7 years.

Czech Republic: If the guest is not a Czech citizen, the ID data is processed for the purposes of complying with Section 101 of Act No. 326/1999 Coll. on the residence of foreigners. The legal basis for this processing is Art. 6 para. 1 s. 1 lit. c GDPR. We are obliged to keep the data for 6 years from the last entry.

Denmark: If the guest is not a Danish citizen, the ID data is processed for the purposes of complying with Section 52 of Danish Order No. 581 of 10 July 2002 (Aliens Order). The legal basis for this processing is Art. 6 para. 1 s. 1 lit. c GDPR. We are obliged to keep the data for a minimum of 1 year and a maximum of 2 years.

France: If the guest is not a French citizen, the ID data is collected via the "fiche individuelle de police" for the purposes of complying with Article R814-1 et seq. of the Code of Entry and Stay of Foreigners. The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. In accordance with Article R814-3, we are obliged to keep the data for 6 months and must destroy it thereafter.

Italy: If the guest is not an Italian citizen, the ID data is processed for the purposes of complying with Art. 109 of the Consolidated Text of Public Safety Laws (TULPS). The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. Data is transmitted to the State Police ("Alloggiati Web"); we are obliged to keep the data (receipts of transmission) for 5 years.

Netherlands: If the guest is not a Dutch citizen, the ID data is processed as part of the night register for the purposes of complying with Art. 438 of the Criminal Code and local tax ordinances. The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. In accordance with Art. 52 of the General Tax Act (AWR), we are obliged to keep the data for 7 years.

Norway: If the guest is not a Norwegian citizen, the ID data is processed for the purposes of complying with Section 20 (c) of the Immigration Act. The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. The data is deleted once the stay of the guest is over and the transmission/check has occurred, unless a longer retention is required for tax purposes.

Portugal: If the guest is not a Portuguese citizen, the ID data is processed for the purposes of complying with Law n.º 23/2007 and SEF regulations. The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. We are obliged to keep the data for 1 year after the guest's departure.

Spain: If the guest is not a Spanish citizen, the ID data is processed for the purposes of complying with Royal Decree 933/2021. The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. In accordance with Art. 3 of the Royal Decree, we are obliged to keep the data for 3 years.

Switzerland: If the guest is not a Swiss citizen, the ID data is processed for the purposes of complying with Cantonal Police Acts (e.g., § 21 PolG Zurich). The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. We are generally obliged to keep the data for 3 years (depending on the specific Canton).

United Kingdom: If the guest is not a UK citizen, the ID data is processed for the purposes of complying with The Immigration (Hotel Records) Order 1972. The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR. We are obliged to keep the data for at least 12 months.

The copy of the ID document is kept for 7 days after the upload by the guest for the purposes of ensuring the correctness of the information collected and subsequently deleted.

3.5. Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

●       American Express Europe S.A.

●       Apple Inc., USA (for Apple Pay)

●       Google Ireland Limited, Ireland (for Google Pay)

●       Klarna Bank AB (publ), Sweden (for "Klarna auf Rechnung")

●       Mastercard Europe SA, Belgium

●       PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxemburg

●       Visa Europe Services Inc., Great Britain

●       Stripe Payments Europe, Ltd., Ireland (“Stripe”)

●       Checkout Ltd (Checkout.com), UK

3.6. Technically necessary cookies

Our applications set cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our applications or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with  functional applications.
Specifically, we set technically necessary cookies for the following purpose or purposes:

●       Cookies that store language settings

●       Cookies that store the shopping cart

●       Cookies that store log-in data

●       Cookies that payment providers set for payment processing and do not analyse user behaviour

●       Flash cookies that are set to play media content

3.7. Third parties

3.7.1. ​LinkedIn Insight Tag​

We use LinkedIn Insight Tag for conversion tracking. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.linkedin.com/legal/privacy-policy?.

3.7.2. ​Usercentrics​

We use Usercentrics to manage consents. The provider is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in easily managing consents from our customers and prospects.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://usercentrics.com/privacy-policy/.

3.7.3 Consentmanager

We use Consentmanager to manage user consents for cookies and tracking technologies. The providers is consentmanager GmbH, Eppendorfer Weg 251, 20251 Hamburg, Germany.

 

The provider process meta/communication data (e.g., device information, IP addresses, consent history) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in easily managing user consents in compliance with legal requirements.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the providers' privacy policies at https://www.consentmanager.net/privacy.php.

 

3.7.4. ​Google Webfonts​

We use Google Webfonts for fonts on the applications. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. However, the processing only takes place on our servers. We process meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.7.5. ​HubSpot​

We use HubSpot for customer relationship management. The provider is HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), content data (e.g. entries in online forms), and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in managing data in a simple and inexpensive way.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://legal.hubspot.com/de/privacy-policy.

3.7.6. ​Dato

We use Dato as a content management system to display images on the applications and host other content. The provider is Dato Srl, Via Giuseppe Garibaldi 15, 50123 Firenze (FI), Italy. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest to display photos on our applications in a simple way.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.datocms.com/legal/privacy-policy.

3.7.7. ​Matterport

We use ​Matterport for displaying 360 degree footage of some properties on the applications. The provider is Matterport, Inc., 352 East Java Drive, Sunnyvale, CA 94089, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://matterport.com/privacy-policy.

3.7.8. ​YouTube Videos​

We use YouTube Videos for videos on the applications. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are consents.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy.

3.7.9. ​Google Tag Manager​

We use Google Tag Manager for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.7.10. ​Segment​

We use Segment for analytics. The provider is Segment.io, Inc., 100 California Street Suite 700 San Francisco, CA 94111, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://segment.com/legal/privacy/.

3.6.11. Aircall

We use Aircall for telephone calls. The provider is Aircall SAS, 11 Rue Saint-Georges, 75009 Paris, France. The provider processes meta/communication data (e.g. contact number, IP addresses if applicable) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in contacting our customers.

The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) GDPR (Article 46(2)(c) GDPR), which we have agreed with the provider.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://aircall.io/privacy/.

3.7.12. ​Facebook Pixel​

We use Facebook Pixel for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times, customer identifiers such as e-mail or telephone number) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.facebook.com/policy.php.

3.7.13. ​imgix​

We use imgix to display images on the applications. The provider is Zebrafish Labs Inc., 423 Tehama St., 94103 San Francisco, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest to display photos on our applications in a simple way.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://imgix.com/privacy.

3.7.14. ​TikTok Pixel​

We use TikTok Pixel for analytics and for advertisement. The provider is TikTok, Inc., 10100 Venice Blvd Suite 401 Culver City, CA 90232, USA. The provider processes meta/communication data (e.g. device information, IP addresses, customer identifiers such as e-mail or telephone number) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://ads.tiktok.com/i18n/official/policy/privacy.

3.7.15. ​Cloudflare​

We use Cloudflare for application security. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in increasing the security of our applications by preventing malicious traffic from reaching our server.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.cloudflare.com/en-gb/privacypolicy/.

3.7.16. ​Google Analytics​

We use Google Analytics for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.7.17. ​Sentry​

We use Sentry to monitor applications and to track errors in applications or on applicationss. The provider is Functional Software, Inc., 132 Hawthorne Street San Francisco, CA 94107, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), content data (e.g. entries in online forms), and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://sentry.io/privacy/.

3.7.18. ​Microsoft Advertising​

We use Microsoft Advertising for conversion tracking and for analytics. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are Missing.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://privacy.microsoft.com/en-gb/privacystatement.

3.7.19. Akiles Key System

We use Akiles Key System to provide electronic locks in some of our properties. The provider is AKILES TECHNOLOGIES S.L, Carrer Moianes 16-18, Entresuelo 4, Barcelona. The provider processes the guest’s name in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing our guests with an easy digital system for the locks.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://akiles.app/en/privacy-policy.

3.7.20. ​Incode​

We use Incode to verify identities. The provider is Incode Technologies, Inc., 221 Main Street, Suite 520, San Francisco, CA 94105, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://incode.com/incode-privacy-policy/.

3.7.21. Apaleo

We use Apaleo for the management of property and guest data. The provider is apaleo GmbH, Dachauerstr. 15 A, 80335 Munich. The provider processes master data (e.g. name, email address, information about the stay) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in managing our house and guest data in order to offer our services.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://apaleo.com/de/privacy-policy.

3.7.22. Looker

We use Looker for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. applicationss visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.23. Chekin.io

We use Chekin.io to automate check-in processes. The provider is Chekin Soluciones Digitales SL, Avenida de Diego Martínez Barrio, 10, 4ª planta, Seville, Andalusia 41013, Spain. The provider processes master data (such as name, email address, address, ID card) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in offering our guests a smooth online check-in as part of our services.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://chekin.com/en/generic-privacy-policy-of-accommodations/.

3.7.24. Hevodata

We use Hevodata for analysis. The provider is Hevo Data, Inc, 1390 Market St, Suite 200, San Francisco, CA 94102, USA. The provider processes usage data (e.g. applicationss visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://hevodata.com/privacy/.

3.7.25. Siteminder Distribution Limited

We use Siteminder Distribution to manage bookings on our applications. The provider is SiteMinder Limited ACN 121 931 744 of Bond Store 3, 30 Windmill Street, Millers Point, NSW 2000, Australia. The provider processes master data (such as name, email address, address, ID card, bookings) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in managing our house and guest data in order to provide our services.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.siteminder.com/legal/privacy/.

3.7.25. Voucherify

We use Voucherify to offer and process vouchers on our applications. The provider is P. Rychlik Spółka Jawna, Porcelanowa 23, 40-246 Katowice, Poland ("Rspective"). The provider processes contact data (e.g. email addresses) and meta/communication data (e.g. device information, IP addresses) and master data (e.g. names, addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in providing our guests with a voucher for discounts on next trips.

The data will be deleted when the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information is available in the provider's privacy policy at https://www.voucherify.io/legal/privacy-policy-v1-5.

3.7.26. Google Optimize

For the optimization of our applications, we use the tool Google Optimize of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, ("Google"). The tool is an integration to Google Analytics, processes the data from Google Analytics and helps to perform simple tests on the design and content of the applications. More information about this can be found under the paragraph for Google Analytics in this Privacy Policy.

The legal basis for data processing is Art. 6 para. 1 p. 1 lit. a GDPR. The consent can be revoked at any time via the data provided on this contact page. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.27. Google Ads (formerly Adwords)

For the placement of advertisements, we use the Google AdWords tool of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, ("Google") on the basis of an order processing agreement. The tool collects and transmits cookies with usage data, especially which pages have been visited, which elements have been clicked on, device and browser information, IP address, customer identifiers such as e-mail or telephone number, operating system, data about the displayed advertisements and data from advertising partners, in particular pseudonymized user IDs to the provider of the tool.

The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. a GDPR. The consent can be revoked at any time via the data provided on this page to contact us. The revocation does not affect the lawfulness of the processing until the revocation. The security of the data when transferred to servers in the USA is ensured, as our contract with the provider includes standard data protection clauses published by the EU Commission (Art. 46 para. 2 lit. c GDPR).

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.28. Google Syndication

We use Google Syndication for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. applicationss visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA. The tool is an integration to Google Analytics, processes the data from Google Analytics and helps to perform simple tests on the design and content of the applications. More information about this can be found under the paragraph for Google Analytics in this Privacy Policy.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.29. Google Cloud

We use Google Cloud for cloud storage. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. applicationss visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

It is our legitimate interest to hire and use a professional cloud hosting provider, so that the legal basis of the described data processing is Art. 6 para. 1 p. 1 lit. f GDPR.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.30. Front App

We use Front App to manage customer service channels. The provider is FrontApp, Inc, 525 Brannan St 300, San Francisco, California, 94107, USA. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://front.com/legal/privacy-notice.

3.7.31. Vonage

We use Vonage as a communications API for, among other things, telephone calls. The provider is NewVoiceMedia Limited, 25 Canada Square Level 37, London, England E14 5LQ. The provider processes meta/communication data (e.g. contact number, IP addresses if applicable) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in contacting our customers.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.vonage.com/legal/privacy-policy/?icmp=footer_legalpolicy_privacy.

3.7.32. ​WhatsApp

We use WhatsApp to communicate with guests. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes communication data (telephon number, name, messages) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.whatsapp.com/legal/updates/privacy-policy-eea?lang=en.

3.7.33. Twilio

We use Twilio to communicate with guests. The provider is Twilio, Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA. The provider processes communication data (telephon number, name, messages) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.twilio.com/legal/privacy. 

3.7.34. Google Meet

We use Google Meet for video calls. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. applicationss visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.35. ​Klaviyo (webforms)​

We use Klaviyo (webforms) for email marketing and for quizzes and forms. The provider is Klaviyo, Inc., 125 Summer St, Floor 6 Boston, MA 02111, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in creating forms in a simple way.

The transfer of personal data to a country outside the EEA takes place on the legal basis standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.klaviyo.com/privacy/policy.

3.7.36. ​Mixpanel​

We use Mixpanel for analytics. The provider is Mixpanel, Inc., One Front Street, Floor 28, San Francisco, CA 94111, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://mixpanel.com/legal/privacy-policy/.

3.7.37. Make

We use Make for automation and messages dispatch on the applications. The provider is Celonis, Inc., One World Trade Center, 87th Floor, New York, NY, 10007, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in automating processes and communication with our clients.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.make.com/en/privacy-notice.

3.7.38. Klaviyo

We use Klaviyo for email marketing and user behavior analysis. The provider is Klaviyo, Inc., 125 Summer St, Boston, MA 02110, USA. The provider processes personal data such as email addresses, usage data (e.g., open rates, click behavior), and technical data (e.g., IP addresses, device information).

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based solely on user consent. Data subjects can revoke their consent at any time by contacting us using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted once the purpose of its processing ceases to apply and no legal retention obligations exist. Further information is available in the provider’s privacy policy at: https://www.klaviyo.com/legal/privacy-policy.

3.7.39. OpenAI

We use the OpenAI API to help our customer support team automate tasks such as the triage of tickets, to summarize customer requests, to automatically analyse the quality of the service provided by our customer support team, and to support the team in drafting responses to our customers. The provider is OpenAI, L.L.C., 3180 18th St 100, San Francisco, CA 94110, USA. The provider processes name, e-mail address and other personal data that might be relevant to the customer request. The personal data is processed in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in optimizing our customer support tasks to provide a more efficient support to our guests.

No automatic decision-making process in the terms of the GDPR takes place. Personal data is not used for any other purposes besides providing an answer to the customer request and improving internal customer support processes.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://openai.com/policies/privacy-policy.

3.7.40. Anthropic

We use Anthropic to help our customer support team automate tasks such as the triage of tickets, to summarize customer requests, to automatically analyse the quality of the service provided by our customer support team, and to support the team in drafting responses to our customers. The provider is Anthropic PBC, 548 Market St, PMB 90375, San Francisco, CA 94104-5401, USA. The provider processes name, e-mail address and other personal data that might be relevant to the customer request. The personal data is processed in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in optimizing our customer support tasks to provide a more efficient support to our guests.

No automatic decision-making process in the terms of the GDPR takes place. Personal data is not used for any other purposes besides providing an answer to the customer request and improving internal customer support processes.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.anthropic.com/legal/privacy.

3.7.41. Sprig

We use Sprig for surveys and analytics. The provider is Sprig Technologies, Inc., 140 2nd Street 4th floor, San Francisco, CA 94105, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://sprig.com/privacy-policy.

3.7.42. ​Nevaya

We use Nevaya to enable guests to interact with and control in-room devices from their smartphone. The provider is Nevaya Ltd., Unit 17 Cirencester Office Park, Tetbury Road, Cirencester, Gloucestershire, GL7 6JJ, United Kingdom. The provider processes the guest's name to display a personalized welcome message on the TV screen. This data is shared with Nevaya's system when the guest first enters the room.

The legal basis for this processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing a modern and convenient service that enhances the guest experience by offering remote control of in-room devices and a personalized welcome message.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://nevaya.co.uk/privacy-policy/.

3.7.43. Cognigy

We use Cognigy for AI-driven customer service automation and chatbot management. The provider is Cognigy GmbH, Speditionstraße 1, 40221 Düsseldorf, Germany. The provider processes contact data, communication content, and meta/communication data (e.g., device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in automating customer support tasks to provide efficient guest assistance.

The data will be deleted when the purpose of its collection has ceased to apply. Further information is available in the provider's privacy policy at https://www.cognigy.com/privacy-policy.

 

3.7.44. dbt Labs

We use dbt Labs for data transformation and analytics pipeline engineering. The provider is dbt Labs, Inc., 915 Montgomery Ave, Suite 205, Narberth, PA 19072, USA. The provider processes usage data and meta/communication data in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in managing and optimizing our internal data infrastructure.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses (Art. 46 para. 2 lit. c GDPR).

The data will be deleted when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://www.getdbt.com/legal/privacy-policy/.

 

3.7.45. Hotjar

We use Hotjar to analyze user behavior on our applications (e.g., heatmaps, session recordings, feedback polls). The provider is Hotjar Limited, Dragonara Business Centre, 5th Floor, Paceville St Julian's STJ 3141, Malta. The provider processes usage data, device information, IP address (anonymized), and feedback entries in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based solely on user consent. Data subjects can revoke their consent at any time.

The data will be deleted once the purpose of its processing ceases to apply. Further information is available in the provider's privacy policy at https://www.hotjar.com/legal/policies/privacy/.

 

3.7.46. Chattermill

We use Chattermill for customer feedback analytics and sentiment analysis. The provider is Chattermill Analytics Limited, 68 Hanbury St, London E1 5JL, United Kingdom. The provider processes customer feedback entries, contact data, and usage data in the United Kingdom / EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in evaluating customer satisfaction to improve our services.

The data will be deleted when the purpose of its collection no longer applies. Further information is available in the provider's privacy policy at https://chattermill.com/privacy/.

 

3.7.47 Detect Language API

We use Detect Language API for automatic text language identification in customer interactions. The provider is Web Cats UAB, Baltupio st. 57, LT-08322 Vilnius, Republic of Lithuania. The provider processes submitted text snippets in the EU to identify the language spoken.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in directing customer requests to support agents with matching language skills.

The data will be deleted immediately after language detection is complete. Further information is available in the provider's privacy policy at https://detectlanguage.com/privacy.

 

3.7.48. TalkJS (Klets B.V.)

We use TalkJS for in-app messaging and user chat infrastructure. The provider is Klets B.V., Bogert 1, 5612 LX Eindhoven, Netherlands. The provider processes master data (e.g., names), contact details, and message communication data in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR (performance of contract) and Art. 6 para. 1 s. 1 lit. f GDPR (legitimate interest in providing real-time digital communication channels).

The data will be deleted when the messaging purpose has ceased to apply and no retention obligations exist. Further information is available in the provider's privacy policy at https://talkjs.com/privacy/.

 

3.7.49. UI Bakery

We use UI Bakery to build internal operational tools and dashboards. The provider is UI Bakery, Inc., 5900 Balcones Drive #23460, Austin, TX 78731, USA. The provider processes meta/communication data and operational system logs in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in creating efficient internal management systems.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses (Art. 46 para. 2 lit. c GDPR).

The data will be deleted when no longer required for operating internal tools. Further information is available in the provider's privacy policy at https://uibakery.io/privacy-policy.

 

3.7.50. n8n

We use n8n for internal workflow automation and data integration. The provider is n8n GmbH, Krausenstraße 9-10, 10117 Berlin, Germany. The provider processes meta/communication data and operational data in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in automating internal business workflows.

The data will be deleted when the execution of the automated task is completed and technical logs are no longer required. Further information is available in the provider's privacy policy at https://n8n.io/privacy/.

 

3.6.51. Glutz AG

We use Glutz AG for electronic door locks and access control systems in our properties. The provider is Glutz AG, Segetzstrasse 13, 4502 Solothurn, Switzerland. The provider processes guest names and booking validity timeframes necessary for digital key issuance in Switzerland (guaranteed adequate level of data protection pursuant to Art. 45 GDPR).

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR (contract performance) and Art. 6 para. 1 s. 1 lit. f GDPR (legitimate interest in digital access management).

The data will be deleted once the stay has concluded and legal retention periods expire. Further information is available in the provider's privacy policy at https://glutz.com/datenschutz/.

 

3.7.52. Hikvision (HikCentral)

We use Hikvision / HikCentral for security management and video surveillance of physical property areas. The provider is Hikvision Europe B.V., Dirk Storklaan 3, 2132 PX Hoofddorp, Netherlands. The provider processes video recordings and physical access logs in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in premises security, crime prevention, and protecting guest safety and property.

Video recordings are automatically overwritten and deleted after short statutory retention windows, unless needed to investigate legal claims. Further information is available in the provider's privacy policy at https://www.hikvision.com/en/policies/privacy-policy/.

 

3.7.53 Grafana Labs

We use Grafana Labs for performance monitoring and metric visualization. The provider is Grafana Labs Ltd., 165 Broadway, 23rd Floor, New York, NY 10006, USA. The provider processes usage data and technical meta/communication data (e.g., system metrics, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in maintaining technical infrastructure reliability.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses (Art. 46 para. 2 lit. c GDPR).

The data will be deleted when the monitoring purpose no longer applies. Further information is available in the provider's privacy policy at https://grafana.com/legal/privacy-policy/.

4. Numa subsidiaries

Numa Group SE is the controller for the operation of the applications within the meaning of Art. 4 GDPR. When booking accommodation, Numa Group SE acts as a service provider (processor within the meaning of the GDPR) on behalf of the respective national company of the country in which the accommodation is located.

The personal data of our guests collected during the booking process is therefore transmitted to the respective local Numa company in the country in which the accommodation booked by the guest is located. 

A list of all relevant Numa subsidiaries can be found here. All subsidiaries have concluded an order processing agreement with us for the use of the booking platform operated by Numa Group SE in accordance with Art. 28 GDPR.

5. Data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

5.1. Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

5.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

5.3. YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.

5.4. Twitter

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization.

5.5. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5.6. Xing

We maintain a profile on Xing. The operator is XING AG, Dammtorstraße 29-32, 20354 Hamburg. The privacy policy is available here: https://privacy.xing.com/de/datenschutzerklaerung.

6. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

7. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.