Privacy Policy

  1. 1. Introduction

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

    •       our website https://numastays.com und https://numastays.com
    •       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 GmbH, Jägerstraße 71, 10117 Berlin, Germany, email: privacy@cosi-group.com. We are legally represented by Christian Gaiser, Torsten Weihrich, 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.

    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 website.

    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.

    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 process.

    3. Data processing on our website

    3.1. Informative use of our website

    During the informative use of the website, i.e. when site 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 website. 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 website

    Our website is 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 website, 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 a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

    Our website is 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 website, 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 website, 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 website. 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 website, 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 website. The provider is Vercel Inc., 340 S Lemon Ave Unit 4133 Walnut, CA, USA. The provider thereby processes the personal data transmitted via the website, 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 website

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

    •       IP-address
    •       Name
    •       E-mail address
    •       Phone number
    •       Address
    •       Company name (if applicable)
    •       Date of birth
    •       Nationality
    •       Gender
    •       Date of arrival and expected departure
    •       Number of accompanying persons and their nationality
    •       Identity document

    The data is processed to fulfill the contract concluded with the respective guest (Art. 6 para. 1 p. 1 lit. b GDPR) as well as to comply with applicable legal requirements (Art. 6 para. 1. p. 1 lit. c GDPR in connection with §29 ff. BMG).

    We are obliged according to § 30 paragraph 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.

    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

    3.6. Technically necessary cookies

    Our website sets 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 website 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 a functional website.

    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. ​Google Webfonts​

    We use Google Webfonts for fonts on the website. 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.

    3.7.4. ​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.

    3.7.5. ​Hotjar​

    We use Hotjar for analytics. The provider is Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's, STJ 3141, Malta. 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.hotjar.com/legal/policies/privacy/.

    3.7.6. ​Mapbox​

    We use Mapbox to localize. The provider is Mapbox, Inc., 50 Beale St floor 9, San Francisco, CA, 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 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.mapbox.com/legal/privacy.

    3.7.7. ​YouTube Videos​

    We use YouTube Videos for videos on the website. 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.

    3.7.8. ​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.

    3.7.9. ​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/.

    3.7.10. ​Zapier​

    We use Zapier to automate between applications. The provider is Zapier, Inc., 548 Market St. #62411, San Francisco, CA 94104-5401, 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. f GDPR. We have a legitimate interest in easily connecting the applications in our company to optimize the way we work.

    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://zapier.com/privacy.

    3.7.11. ​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) 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.

    3.7.12. ​imgix​

    We use imgix to display images on the website. 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 website in a simple way.

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

    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.

    3.7.13. ​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) 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.

    3.7.14. ​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 app 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/.

    3.7.15. ​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.

    3.7.16. ​Sentry​

    We use Sentry to monitor applications and to track errors in applications or on websites. 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/.

    3.7.17. ​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.

    3.7.18. ​Lumigo​

    We use Lumigo to monitor applications. The provider is Lumigo Ltd., Spinoza 41 Tel Aviv Jaffa, 6451617, Israel. 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://lumigo.io/privacy-policy/.

    3.7.19. ​Optimove​

    We use Optimove for personalisation. The provider is Optimove Inc., 2 Hashlosha St., 33rd Floor, Tel Aviv, 6706054 Israel. The provider processes content data (e.g. entries in online forms), 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 Israel.

    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 adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.

    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.optimove.com/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. ​Mapme​

    We use Mapme for maps on our website. The provider is Mapme, Sderot Abba Eban 18, Herzliya, Israel. 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://mapme.com/privacy-policy/.

    3.7.22. 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.

    3.7.23. 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. websites 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.

    3.7.24. 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/.

    3.7.25. 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. websites 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/.

    3.7.26. Siteminder Distribution Limited

    We use Siteminder Distribution to manage bookings on our website. 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/.

    3.7.27. MentionMe

    We use MentionMe to manage referrals on our website. Users can recommend our services to their friends. The provider is Mention Me Limited, 20-22 Wenlock Road, London, N1 7GU, United Kingdom. The provider processes content data (e.g. entries in online forms), contact data (e.g. email addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses) and master data (e.g. names, addresses) in the United Kingdom.

    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://mention-me.com/help/privacy_policy_s.

    3.7.28. Voucherify

    We use Voucherify to offer and process vouchers on our website. 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 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 page to contact us. 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://www.voucherify.io/legal/privacy-policy-v1-5.

    3.7.29. Google Optimize

    For the optimization of our website, 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 website. 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.

    3.7.30. 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, 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.

    3.7.31. 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. websites 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 website. 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.

     

    4. 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.

    4.1. 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.

    4.2. 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.

    4.3. 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.

    4.4. 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.

    4.5. 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.

    4.6. 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.

    5. 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.

    6. 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.