English

Privacy policy

I. Name and address of the responsible person

The responsible person within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:

HRG Hotels GmbH
Hauptstraße 66
12159 Berlin
Germany
+49 (0)30 / 773 27 80 – 0
Email: info@hrg-hotels.de
Website: www.hrg-hotels.de

Managing directors: Ruslan Husry, Jörg Beginen, Björn Weidner, Johanna Weichselbaumer, Martin Ykema

I. Name and address of the data protection officer

The data protection officer of the responsible party is: 

DataCo GmbH
Dachauer Straße 65
80335 Munich
Germany
+49 89 7400 45840
datenschutz@dataguard.de
www.dataguard.de

I. General information on data processing

1. Scope of the processing of personal data

As a matter of principle, we process personal data of our users only insofar as this is necessary to provide a functional website as well as our contents and services. The processing of personal data of our users is regularly only carried out with the consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by legal regulations.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) lit. a of the EU General Data Protection Regulation (DSGVO) serves as the legal basis. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Art. 6 (1) c DSGVO serves as the legal basis. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO serves as the legal basis. If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) lit. f DSGVO serves as the legal basis for the processing.

3. Data deletion and storage period

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may take place beyond this if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned norms expires, unless there is a need to continue storing the data for the conclusion or fulfilment of a contract.

II. Provision of the website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:

  • Information about the browser type and the version used.
  • The user's operating system
  • The user's internet service provider
  • The IP address of the user
  • Date and time of access
  • Websites from which the user's system accesses our website
  • Websites that are accessed by the user's system via our website

This data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Legal basis for data processing

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f DSGVO.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session. The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. These purposes are also our legitimate interest in data processing according to Art. 6 Para. 1 lit. f DSGVO.

4. Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

5. Possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for the user to object.

III. Use of cookies

a) Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user calls up a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

b) Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 (1) lit. f DSGVO.

c) Purpose of data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change. These purposes are also our legitimate interest in processing the personal data according to Art. 6 para. 1 lit. f DSGVO.

d) Duration of storage, possibility of objection and removal
Cookies are stored on the user's computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.

IV. Newsletter

1. Description and scope of data processing

On our website, you have the option of subscribing to a free newsletter. When registering for the newsletter, the data from the input mask is transmitted to us.

  • IP address of the calling computer
  • Date and time of registration

For the processing of the data, your consent is obtained during the registration process and reference is made to this data protection declaration. No data will be passed on to third parties in connection with the processing of data for the dispatch of newsletters. The data is used exclusively for sending the newsletter.

2. Legal basis for data processing

The legal basis for the processing of data after registration for the newsletter by the user is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.

3. Purpose of data processing

The collection of the user's e-mail address serves to deliver the newsletter. The collection of other personal data during the registration process serves to prevent misuse of the services or the e-mail address used.

4. Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. The user's e-mail address is therefore stored for as long as the subscription to the newsletter is active.

5. Possibility of objection and cancellation

The subscription to the newsletter can be cancelled by the user concerned at any time. For this purpose, there is a corresponding link in each newsletter. This also enables revocation of the consent to the storage of the personal data collected during the registration process.

V. Contact form and e-mail contact

1. Description and scope of data processing

Our website contains a contact form which can be used for electronic contact. If a user makes use of this option, the data entered in the input mask is transmitted to us and stored. For the processing of the data, your consent is obtained during the sending process and reference is made to this data protection declaration. Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored. In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation.

2. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f DSGVO. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO. 3.

3. Purpose of the data processing

The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified. The additional personal data collected during the sending process will be deleted at the latest after a period of seven days.

5. Possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. All personal data stored in the course of contacting us will be deleted in this case.

VI. Analysis tools

a) Tracking-Tools

The tracking measures listed below and used by us are carried out on the basis of Art. 6 para. 1 p. 1 lit. f DSGVO. With the tracking measures used, we want to ensure a needs-based design and the ongoing optimisation of our website. On the other hand, we use the tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision. The respective data processing purposes and data categories can be found in the corresponding tracking tools.

i) Google Analytics

For the purpose of demand-oriented design and continuous optimisation of our pages, we use Google Analytics, a web analysis service of Google Inc (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google"). In this context, pseudonymised usage profiles are created and cookies (see under point 4) are used. The information generated by the cookie about your use of this website such as

  • Browser type/version,
  • operating system used,
  • Referrer URL (the previously visited page),
  • host name of the accessing computer (IP address),
  • time of the server request,

are transmitted to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services associated with the use of the website and the Internet for the purposes of market research and the design of these Internet pages in line with requirements. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymised so that an allocation is not possible (IP masking). You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (incl. your IP address) as well as the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de). Further information on data protection in connection with Google Analytics can be found, for example, in the Google Analytics help (https://support.google.com/analytics/answer/6004245?hl=de).

By clicking on the following link, your visit and future visits will not be recorded by Google Analytics as long as your browser saves this setting:

ii) Google Adwords Conversion Tracking

In order to statistically record the use of our website and to evaluate it for the purpose of optimising our website for you, we also use Google Conversion Tracking. In this process, Google Adwords sets a cookie (see section 4) on your computer if you have accessed our website via a Google ad. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer's website and the cookie has not yet expired, Google and the customer can recognise that the user clicked on the ad and was redirected to this page. Each Adwords customer receives a different cookie. Cookies can therefore not be tracked via the websites of Adwords customers. The information obtained using the conversion cookie is used to create conversion statistics for Adwords customers who have opted for conversion tracking. The Adwords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in the tracking procedure, you can also refuse the setting of a cookie required for this - for example, via a browser setting that generally deactivates the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting your browser so that cookies from the domain "www.googleadservices.com" are blocked. Google's privacy policy on conversion tracking can be found here (https://services.google.com/sitestats/de.html).

b) Google Maps
On our website, we use Google Maps from Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information. By using this service, our location is shown to you and a possible journey is made easier. When you call up those sub-pages in which the Google Maps map is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there. This happens regardless of whether you are logged in to Google via a user account or do not have such a user account. If you are logged in to Google via a user account, your data will be directly assigned to your account. If you do not wish to have your data associated with your Google profile, you must log out of your Google account before accessing the subpages on which the Google Maps map is integrated. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation is carried out in particular in accordance with Art. 6 Para. 1 lit.f DSGVO on the basis of Google's legitimate interests in the display of personalised advertising, market research and/or the needs-based design of its website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right. Google LLC, based in the USA, is certified for the us-European data protection agreement "Privacy Shield", which guarantees compliance with the level of data protection applicable in the EU. If you do not agree to the future transmission of your data to Google in the context of the use of Google Maps, you also have the option of completely deactivating the Google Maps web service by switching off the JavaScript application in your browser. Google Maps and thus also the map display on this website can then not be used. You can view Google's terms of use at http://www.google.de/intl/de/policies/terms/regional.html, the additional terms of use for Google Maps can be found at https://www.google.com/intl/de_US/help/terms_maps.html. Detailed information on data protection in connection with the use of Google Maps can be found on Google's website ("Google Privacy Policy"): http://www.google.de/intl/de/policies/privacy/.

c) Google Web Fonts
This site uses so-called web fonts (script libraries and font libraries) for the uniform display of fonts, which are provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). When you call up a page, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly. For this purpose, the web browser you are using must connect to Google's servers. This enables Google to know that our website has been accessed via your IP address. Google Web Fonts are used in the interest of a uniform and appealing presentation of our online offer. This represents a legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO. If your browser does not support web fonts, a standard font will be used by your computer. Google LLC, based in the USA, is certified for the us-European data protection agreement "Privacy Shield", which ensures compliance with the level of data protection applicable in the EU. Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://www.google.com/policies/privacy/

VIII. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights vis-à-vis the controller:

1. Right of access

You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If there is such processing, you may request information from the controller about the following:

  1. The purposes for which the personal data are processed;
  2. the categories of personal data which are processed;
  3. the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  4. the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period;
  5. the existence of a right to rectify or erase the personal data concerning you, a right to restrict processing by the controller or a right to object to such processing;
  6. the existence of a right of appeal to a supervisory authority;
  7. any available information on the origin of the data, if the personal data are not collected from the data subject;
  8. the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope
    and intended effects of such processing for the data subject.

You have the right to request information on whether personal data concerning you are transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.

2. Right of rectification

You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller must make the rectification without undue delay.

3. Right to restriction of processing

You may request the restriction of the processing of personal data concerning you under the following conditions:

  1. if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
  2. the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
  3. the controller no longer needs the personal data for the purposes of the processing but you need them for the establishment, exercise or defence of legal claims; or
  4. if you have objected to the processing pursuant to Article 21(1) DSGVO and it has not yet been determined whether the controller's legitimate grounds override your grounds.

Where the processing of personal data relating to you has been restricted, such data may - apart from being stored - only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or a Member State. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right to erasure

a) Obligation to delete

You may request the controller to erase the personal data concerning you without undue delay and the controller is obliged to erase such data without undue delay if one of the following reasons applies:

  1. The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
  2. You withdraw your consent on which the processing was based pursuant to Art. 6 (1) (a) or Art. 9 (2) (a) DSGVO and there is no other legal basis for the processing.
  3. You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
  4. The personal data concerning you have been processed unlawfully.
  5. The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  6. The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

b) Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as the data subject, have requested them to erase all links to, or copies or replications of, that personal data.

c) Exceptions

The right to erasure does not apply to the extent that the processing is necessary

  1. for the exercise of the right to freedom of expression and information;
  2. for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in
    the exercise of official authority vested in the controller;
  3. for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) DSGVO;
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) DSGVO, insofar as the right referred to in section a) is likely to render
  5. impossible or seriously prejudice the achievement of the purposes of such processing; or
  6. for the assertion, exercise or defence of legal claims.

5. Right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed of these recipients by the controller.

6. Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that

  1. the processing is based on consent pursuant to Art. 6 (1) a DSGVO or Art. 9 (2) a DSGVO or on a contract pursuant to Art. 6 (1) b DSGVO and
  2. the processing is carried out with the aid of automated procedures.

In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. This must not affect the freedoms and rights of other persons. The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes. You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications. Your right to object may be limited to the extent that it is likely to render impossible or seriously impair the achievement of the research or statistical purposes and the limitation is necessary for the fulfilment of the research or statistical purposes.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

9. Automated decision-making in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

  1. is necessary for the conclusion or performance of a contract between you and the controller,
  2. is permitted under Union or Member State legislation to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
  3. is done with your explicit consent.

However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests. With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

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