DATA PROTECTION

1. Contact address

The responsible party in the sense of data protection law is:

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Hotel-Restaurant Alte Brauerei

Via Maistra 60
7505 Celerina

info@alte-brauerei.ch
 

In individual cases, third parties may be responsible for processing personal data, or joint responsibility with third parties may exist. We will gladly provide data subjects with information about the respective responsibility upon request.

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2. Definitions and Legal Basis

 

2.1 Definitions

Data subject: A natural person whose personal data we process.

Personal data: Any information relating to an identified or identifiable natural person.

Sensitive personal data: Data regarding trade union, political, religious, or philosophical views and activities; data regarding health, the private sphere, or membership in an ethnic or racial group; genetic data; biometric data that uniquely identifies a natural person; data regarding criminal or administrative sanctions or proceedings, and data regarding social assistance measures.

Processing: Any handling of personal data, regardless of the means and methods used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, revealing, sorting, organizing, saving, modifying, disseminating, linking, destroying, and using personal data.

 

​2.2 Legal Basis

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

 

3. Nature, Scope, and Purpose of Personal Data Processing

We process the personal data necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The personal data processed may include, in particular, browser and device data, content data, communication data, metadata, usage data, master data (including inventory and contact data), location data, transaction data, contract data, and payment data. The personal data may also constitute special-category personal data.

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We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, to the extent that such processing is permitted.

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We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example to comply with legal obligations or to safeguard legitimate interests. We may also request consent from data subjects even when their consent is not required.

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We process personal data for the period necessary to fulfill the respective purpose. We anonymize or delete personal data, in particular, in accordance with statutory retention and statute of limitations periods.​

 

4. Disclosure of Personal Data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may include, for example, specialized service providers whose services we utilize.

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In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, government agencies, educational and research institutions, consultants and attorneys, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media outlets, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.

 

5. Communication

We process personal data to communicate with individuals as well as with public authorities, organizations, and companies. In doing so, we process, in particular, data that a data subject provides to us when contacting us, for example by mail or email. We may store such data in an address book or using comparable tools.

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Third parties who provide us with data about other individuals are required to independently ensure the data protection of those individuals. In particular, they must ensure that such data is accurate and may be disclosed.

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We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We may also use such services to manage and otherwise process the data of the data subjects beyond the scope of direct communication.

 

6. Data Security

We implement appropriate technical and organizational measures to ensure data security commensurate with the respective risk. Through these measures, we ensure, in particular, the confidentiality, availability, traceability, and integrity of the personal data we process; however, we cannot guarantee absolute data security.

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Access to our website and our other digital presence is secured via transport encryption (SSL/TLS, specifically using the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn users before visiting a website without transport encryption.

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Our digital communications – like all digital communications in general – are subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence over the processing of personal data by intelligence agencies, police departments, and other security authorities. Nor can we rule out the possibility that a data subject may be specifically monitored.

 

7. Personal Data Abroad

We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular to process it there or have it processed there.

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We may disclose personal data to any country on Earth or elsewhere in the universe, provided that the local law ensures adequate data protection in accordance with a decision by the Swiss Federal Council.

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We may disclose personal data to countries whose laws do not guarantee adequate data protection, provided that adequate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific legal requirements for data protection are met, such as the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. Upon request, we are happy to provide data subjects with information about any safeguards or to provide a copy of such safeguards.

 

8. Rights of Data Subjects

 

8.1 Rights Under Data Protection Law

We grant data subjects all rights provided for under applicable law. In particular, data subjects have the following rights:

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• Right of access: Data subjects may request information regarding whether we process personal data about them and, if so, what personal data is involved. Data subjects will also receive the information necessary to exercise their data protection rights and to ensure transparency. This includes the personal data being processed as such, but also, among other things, details regarding the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.

• Correction and restriction: Data subjects may correct inaccurate personal data, complete incomplete data, and have the processing of their data restricted.

• Right to express one’s own point of view and human review: Data subjects may present their own viewpoint and request human review in the case of decisions that are based exclusively on the automated processing of personal data and that have legal consequences for them or significantly affect them (automated individual decisions).

• Erasure and objection: Data subjects may have personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.

• Data Disclosure and Data Portability: Data subjects may request the disclosure of their personal data or the transfer of their data to another controller.
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We may defer, restrict, or deny the exercise of data subjects’ rights to the extent permitted by law. We may inform data subjects of any prerequisites that must be met for them to exercise their data protection rights. For example, we may refuse to provide information in whole or in part, citing confidentiality obligations, overriding interests, or the protection of other individuals. We may also, for example, refuse to delete personal data in whole or in part, particularly citing legal retention obligations.

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In exceptional cases, we may charge a fee for the exercise of these rights. We will inform data subjects in advance of any such costs.

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We are required to identify data subjects who request information or assert other rights by taking appropriate measures. Data subjects are required to cooperate.

 

8.2 Legal Remedies

Data subjects have the right to enforce their data protection rights through legal action or to file a complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

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9. Use of the Website

 

9.1 Cookies

We may use cookies. Cookies – including our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.

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Cookies can be stored temporarily in the browser as “session cookies” or for a specific period of time as so-called persistent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies enable, in particular, the recognition of a browser upon the next visit to our website and thereby, for example, the measurement of our website’s reach. Permanent cookies can also be used, for example, for online marketing.

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Cookies can be completely or partially deactivated, restricted, or deleted at any time in the browser settings. Browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least to the extent required by applicable law – your explicit consent to the use of cookies.

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For cookies used to measure performance and reach or for advertising purposes, many services offer a general opt-out option through AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

 

9.2 Logging

For each visit to our website and other digital platforms, we may log at least the following information, provided that it is transmitted to our digital infrastructure during such visits: Date and time, including time zone; IP address; access status (HTTP status code); operating system, including user interface and version; browser, including language and version; specific subpages of our website accessed, including the amount of data transferred; the last webpage accessed in the same browser window (referrer).

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We record such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence is available on a permanent, user-friendly, and reliable basis. The information is also necessary to ensure data security – including through third parties or with the assistance of third parties.

 

9.3 Web Beacons

We may incorporate web beacons into our digital presence. Web beacons are also known as tracking pixels. Tracking pixels – including those from third parties whose services we use—are typically small, invisible images or JavaScript scripts that are automatically loaded when you access our digital presence. Tracking pixels can collect at least the same information as is recorded in log files.

 

10. Social Media

We maintain a presence on social media platforms and other online platforms to communicate with interested individuals and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland.

The General Terms and Conditions (GTC), Terms of Use, privacy policies, and other provisions of the individual operators of these platforms also apply. These provisions provide information in particular regarding the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.

 

11. Third-Party Services

We use services provided by specialized third parties to ensure that we can carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services enable us, among other things, to embed functions and content into our website. When such embedding occurs, the services used collect users’ IP addresses – at least temporarily – for technical reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data required to provide the respective service.

In particular, we use:

• Google Services: Providers: Google LLC (U.S.) / Google Ireland Limited (Ireland), in part for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and Security Principles,” “More information on how Google uses personal data,” Privacy Policy, “Google is committed to complying with applicable data protection laws,” “Guide to data protection in Google products,” “How we use data from websites or apps where our services are used,” Cookie Policy, “Ads you can control” (personalized ad settings).

11.1 Digital Infrastructure

We use services provided by specialized third parties to access the digital infrastructure required for our activities and operations. These include, for example, hosting and storage services from selected providers.

In particular, we use:

• METANET: Hosting; Provider: METANET AG (Switzerland); Data protection information: Privacy Policy, “Legal” section including “Technical and Organizational Measures.”

11.2 Maps

We use third-party services to embed maps on our website.

In particular, we use:

• Google Maps, including the Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: “How Google uses location information.”

 

11.3 Fonts

We use third-party services to embed selected fonts, icons, logos, and symbols into our website.

12. Website Extensions

We use extensions on our website to provide additional functionality. We may use selected services from appropriate providers or implement such extensions on our own digital infrastructure.

In particular, we use:

• Google reCAPTCHA: Spam protection (distinguishing between desired content from humans and unwanted content from bots and spam); Provider: Google; Google reCAPTCHA-specific information: “What is reCAPTCHA?”.

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13. Measuring Success and Reach

We strive to measure the success and reach of our activities and initiatives. In this context, we may also measure the impact of third-party content or test how different parts or versions of our digital presence are used (using the “A/B testing” method). Based on the results of success and reach measurement, we can, in particular, correct errors, enhance popular content, or make improvements.

For performance and reach measurement, the IP addresses of individual users are typically collected. In this case, IP addresses are generally truncated (“IP masking”) to comply with the principle of data minimization through appropriate pseudonymization.

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Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital platform, information about the size of the screen or browser window, and the user’s location (at least approximately). In principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Certain third-party services with which users are registered may, in some cases, associate the use of our online offering with the user’s account or profile on the respective service.

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In particular, we use:

• Google Marketing Platform: Performance and reach measurement, in particular with Google Analytics; Provider: Google; Google Marketing Platform-specific information: Measurement across different browsers and devices (cross-device tracking) using pseudonymized IP addresses, which are only transmitted in full to Google in the U.S. in exceptional cases; Google Analytics Privacy Policy, “Browser add-on to disable Google Analytics.”

 

14. Video Surveillance

We use video surveillance to prevent crimes, to preserve evidence in the event of crimes, and to enforce our property rights.

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We store video surveillance recordings for as long as they are necessary to preserve evidence or for any other specified purpose.

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We may back up recordings from our video surveillance and transmit them to competent authorities, such as courts or law enforcement agencies, provided that such transmission is necessary for a specified purpose, in our overriding interest, or due to legal obligations.

 

15. Final Notes on the Privacy Policy

We may update this Privacy Policy at any time. We will notify you of any updates in an appropriate manner, in particular by publishing the most current version of the Privacy Policy on our website.