Privacy Policy EN

Page 1

PRIVACY POLICY

Last updated: July 2022

A. CONTACTS

1. CONTROLLER

We, the following companies:

Katara Hospitality Switzerland AG, Bahnhofplatz, 6300 Zug, Switzerland (CHE-114.959.229), operator of the website www.buergenstock-selection.ch

Bürgenstock Hotels AG, Bürgenstock, 6363 Obbürgen, Switzerland (CHE-105.841.711), operator of the website www.buergenstock.ch

Hotel Schweizerhof Bern AG, Bahnhofplatz 11, 3001 Bern, Switzerland (CHE-101.277.243), operator of the website www.schweizerhof-bern.ch

Société Anonyme de l’Hôtel Royal, Avenue d’Ouchy 40, 1000 Lausanne, Switzerland (CHE101.464.526), operator of the website www.royalsavoy.ch

Bürgenstock Kunst & Kulturstiftung, Bürgenstock, 6363 Obbürgen, Switzerland (CHE115.263.885), operator of the website www.kks-buergenstock.ch

Bürgenstock Bahn AG, c/o Bürgenstock Obbürgen, 6362 Stansstad, Switzerland (CHE108.107.719), operator of the website www.buergenstock.ch/en/leisure/buergenstock-funicular

Hammetschwand Lift AG, Bürgenstock Obbürgen, 6363 Obbürgen, Switzerland (CHE106.643.533), operator of the website Explore | Bürgenstock Resort (burgenstockresort.com)

are responsible for collecting, processing and using your personal data and for the compliance of this data processing with the data protection legislation which applies to the relevant website.

Your trust is important to us, which is why we take data protection seriously and ensure the appropriate level of security. We observe the statutory provisions of the Swiss Federal Act on Data Protection (FADP), the Ordinance to the Federal Act on Data Protection (DPO), the Swiss Telecommunications Act (TCA) and any other data protection provisions which may apply under Swiss or EU law, in particular the General Data Protection Regulation (GDPR), if applicable.

Please take note of the following information so that you are aware of the personal data we collect from you and the purposes for which we use it.

2. DATA PROTECTION OFFICER

For questions in connection with data protection and for information regarding your rights as well as for the assertion thereof, you can contact our data protection officer:

DATA-PROTECTION-OFFICER@BURGENSTOCKSELECTION.COM

3. NAME AND ADDRESS OF THE EU REPRESENTATIVE

Our below-mentioned data protection representation in the European Economic Area (EEA) including the European Union (EU) and the Principality of Liechtenstein serves as an additional point of contact for supervisory authorities and data subjects on all issues related to the GDPR:

VGS Datenschutzpartner UG, Am Kaiserkai 69, 20457 Hamburg, Germany, INFO@DATENSCHUTZPARTNER.EU

B. DATAPROCESSING INCONNECTION WITHOUR WEBSITES

1. ACCESSING OUR WEBSITES

When you visit our websites, our servers temporarily store each access in a log file. The following technical data is recorded automatically, as is the case with every connection to a web server, and is stored by us until the automatic erasure after 12 months at the latest:

 The IP address of the computer sending the query

 The name of the owner of the IP address range (usually your Internet access provider)

 The date and the time of access

 The website from which the access was made (referrer URL), with the search term used, if applicable

 The name and URL of the file accessed

 Country from which the access is made

 The status code (e.g. error message)

 Time zone difference to Greenwich Mean Time (GMT)

 The operating system of your computer

 The browser used by you (type, version and language)

 The transfer protocol used (e.g. HTTP/1.1)

 If applicable, your user name used in a registration/authentication

This data is collected and processed to allow users to use our websites (to establish a connection), to ensure permanent system security and stability, to enable us to optimise our online offering and for internal statistical purposes. This is our legitimate interest in processing the data.

The IP address is also analysed together with the other data to investigate and prevent possible attacks on our network infrastructure or other unauthorised use or abuse of the websites and, if applicable, during criminal proceedings for identifying and prosecuting the respective users under civil and criminal law. This is our legitimate interest in processing the data.

2. USING OUR CONTACT FORM

Where on our websites you have the option to use a contact form to get in touch with us, we usually require the following information:

 Form of address

 First and last name

 E-mail address

 Telephone number

 Message

The information that is required to process your request smoothly is marked as a mandatory entry. Entering further information is optional. We will only use this data, as well as an address provided by you voluntarily, to be able to reply to your contact request as effectively as possible and in a personalised manner. The processing of this data is therefore necessary to take steps prior to entering into a contract and is in our legitimate interest.

3. REQUESTS FOR MEETINGS, CONFERENCES AND EVENTS

On our websites, you have the option to submit an enquiry in order to book a meeting, a conference or an event. For this purpose, we usually need the following information:

 For which hotel is the request

 Type of event

 Event data

 Form of address

 First and last name

 Company name

 Postal address

 E-mail address

 Telephone number

 Language of correspondence

Event details (participation of VIP, catering requirements, conference equipment requirements, additional services (flowers, photographer, music, tablecloths, transportation, spa time and activities, budget))

The information that is required to process your request smoothly is marked as a mandatory entry. Entering further information is optional. We will only use this data, as well as an address provided by you voluntarily, to be able to reply to your request as effectively as possible and in a personalised manner. The processing of this data is in our legitimate interest.

Please note that we may pass on your data to third parties as far as this is necessary within the framework of the use of the websites and the execution of the contract (see section 20).

4. MICROSOFT TEAMS

We use the tool “Microsoft Teams" to conduct telephone conferences, online meetings, video conferences and/or online seminars (hereinafter: "Online Meetings"). "Microsoft Teams" is a product of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

When using "Microsoft Teams", various types of data are processed. The scope of the data also depends on what information is provided before or during participation in an online meeting. This may be for example:

 User details: e.g. display name, e-mail address, if applicable, profile picture (optional), preferred language

 Meeting metadata: e.g. date, time, meeting ID, phone numbers, location

 Text, audio and video data: It is possible to use the chat function in an online meeting. In this respect, the text entries made by the respective user are processed in order to display them in the online meeting. In order to enable the display of video and playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device are processed accordingly for the duration of the meeting. The camera or microphone can be switched off or muted by the user at any time via the "Microsoft Teams" applications.

If online meetings are to be recorded, this will be communicated transparently in advance and, where necessary, consent will be requested.

Chat content is logged when using Microsoft Teams. If it is necessary for the purposes of logging the results of an online meeting, we will log the chat content. Usually, however, this will not be the case.

The processing of this data is in our legitimate interest. In these cases, our interest is in the effective conduct of online meetings. In all other respects, the legal basis for data processing when conducting online meetings is the contract, insofar as the meetings are conducted within the framework of contractual relationships.

5. SIGNING UP FOR OUR NEWSLETTER

Where on our websites you have the option to subscribe to our newsletter, you need to register. During the registration process the following data must be submitted:  Title

First and last name

The data above is required for data processing. We only process this data to personalise the information and offers sent to you and to better match them to your interests.

When you register, you give us your consent to process the data provided in order to regularly send the newsletter to the address you have provided, to statistically analyse your usage behaviour and to optimise the newsletter. This consent constitutes our legal basis for processing your e-mail address. We are entitled to commission third parties with the technical implementation of the newsletter and to pass on your data for this purpose (see section 20 below).

The registration for the newsletter takes place in a so-called double opt-in procedure. This means that after registering and clicking the corresponding checkbox, you will receive an e-mail in which you must click on a link to confirm your registration.

The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, first technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval are collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked on. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor that of the dispatch service provider to observe individual users. The analyses rather serve us to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

At the end of every newsletter, there is a link that allows you to unsubscribe from the newsletter at any time. As part of the “Unsubscribe” process, you can voluntarily give us a reason for unsubscribing. After you have unsubscribed from the newsletter, your personal data will be deleted. Further processing only takes place in an anonymised form to optimise our newsletter.

In addition, you have the option to send your revocation to the following e-mail address:

data-privacy@burgenstockresort.com

data-privacy@schweizerhofbern.com

data-privacy@royalsavoylausanne.com

6. ORDERING VOUCHERS

 E-mail address

On our websites you have the option to order vouchers. For this, we usually need the following information:

 Form of address

 Title

 Company name

 First and last name

 E-mail address

 Number of persons

 Telephone number

 Voucher type

 Dedication, personal greeting and form of address for voucher recipient

 Payment method

The information that is required to process your request smoothly is marked as a mandatory entry. Entering further information is optional. We will only use this data, as well as an address provided by you voluntarily, to be able to reply to your enquiry as effectively as possible and in a personalised manner. The processing of this data is in our legitimate interest.

Please note that we may pass on your data to third parties as far as this is necessary within the framework of the use of the websites and the execution of the contract (see section 20).

7. OPENING A CUSTOMER ACCOUNT

Where on our websites you have the option to make bookings, you can place an order as a guest or open a customer account. When you register for a customer account, we usually collect the following data:

 Title

 First and last name

 Postal address

 Telephone number

 E-mail address

 Password and security question

The information that is required to process the opening of your customer account smoothly is marked as a mandatory entry. Entering further information is optional. We will only collect this data, as well as other information provided by you voluntarily (e.g. company name), to provide you with direct, password-protected access to your basic data stored with us. In your account, you can view your previous and current bookings or manage and/or change your personal data.

The legal basis for processing the data for this purpose is the consent given by you.

8. BOOKING ON THE WEBSITES, BY CORRESPONDENCE OR BY TELEPHONE CALL

When you book overnight stays and/or make reservations for restaurants, leisure activities, spa services or medical services via our websites, by corresponding with us (by e-mail or letter) or by calling us, we usually require the following data to process the contract:

 Form of address

 First and last name

 Postal address

 Telephone number

 Credit card information

 E-mail address

We will process the data by name to record your booking/reservation as requested, to provide the booked services, to contact you in case of problems or if anything is unclear, and to ensure the correct payment.

The information that is required to process your booking smoothly is marked as a mandatory entry or – if you book by telephone – requested from you in person. Entering further information is optional. We will only use other information provided by you voluntarily (e.g. date of birth, expected arrival time, vehicle number plate, preferences, comments) to process the contract unless otherwise specified in this privacy statement or unless you have given separate consent.

Please note that we may pass on your data to third parties as far as this is required for the use of the websites and for processing the contract (see section 20).

The legal basis for processing the data for this purpose is the execution of a contract.

9. ORDERS FROM OUR ONLINE SHOP

To order from our online shop, you must register once and set a user name and personal password. On future visits to our website, you can log in with your user name and password and do not have to re-enter your address and payment information each time you place an order. Your password is stored in encrypted form and cannot be viewed by us.

When registering, you must provide the following data:

 Form of address

 First and last name

 Language

 Invoice address

 Delivery address

 E-mail address

 Payment method

The information that is required to process the opening of your customer account smoothly is marked as a mandatory entry. The entry of other information is optional.

The data of your orders is also stored in your customer account.

We use the personal data collected during registration and ordering exclusively for the proper processing of your order. The legal basis for processing the data for this purpose is the fulfilment of a contract.

You can view and change the information in your customer account, such as your chosen payment method and delivery address, at any time. In case you update any information, we keep a copy of your original details on file so that we can clarify any issues that may arise between you and us.

You have the option to delete your customer account at any time, as soon as there are no more open orders. You can also send your deletion request to the following e-mail address:

data-privacy@burgenstockresort.com

data-privacy@schweizerhofbern.com

data-privacy@royalsavoylausanne.com

To verify your identity, please send the request directly via e-mail from your user account.

10. APPLYING FOR A JOB

Where on our websites you have the option to apply for jobs, you must submit a complete application. Usually the following data must be submitted:

 Form of address

 First and last name

 Language

 Postal address

 Date of birth

 E-mail address

 Application documents (CV, covering letter, etc.)

The information that is required to process your application smoothly is marked as a mandatory entry. This data, as well as other information provided by you voluntarily (e.g. telephone number), will be used in the application process. Unless you give your explicit consent to further processing (e.g. to use your details for further application processes with us), the data will be erased 6 months after the relevant application procedure.

The legal basis for processing the data is therefore to take steps prior to entering into a contract and is as such in our legitimate interest. The legal basis for further data processing is the consent given by you.

We may use the talent management software "Recruiting App" by Haufe-umantis AG based in Freiburg. The Recruiting App is integrated into the websites via iFrame and shows vacancies and the possibility to apply via form.

If you apply to us, your personal data will be stored and processed on the systems of Haufeumantis AG.

Together with Haufe-umantis AG we have taken the necessary organisational and technical measures to ensure the confidentiality of your application. All employees of the HR department as well as of our software partner are obliged to maintain secrecy regarding personal data within the scope of their employment contracts.

Thanks to an automatically activated 128-bit encryption, the secure transmission of your data is ensured. When processing data, the general standards for data security are taken into account in accordance with the current state of the art.

For further information, please refer to the privacy policy: PRIVACY POLICY | JOB SERVICE MALTECH AG (UMANTIS.COM)

You may object to this data processing at any time. If you object, we will no longer process your personal data for this purpose. Send your objection to the following e-mail address:

data-privacy@burgenstockresort.com

data-privacy@schweizerhofbern.com

data-privacy@royalsavoylausanne.com

C. C OOKIES

Cookies help to make your visit to our websites easier, more pleasant and more useful in many ways. Cookies are information files that your web browser automatically places on your computer’s hard drive when you visit our website.

For example, we use cookies to temporarily store your selected services and entries when you fill in a form on the websites so that you do not need to enter them again when you access another subpage. Cookies may also be used to identify you as a registered user once you have

registered on the websites so that you do not need to log in again when you access another subpage.

For your understanding, the most common types of cookies are explained below:

Session cookies:

While you are active on a website, a session cookie is temporarily stored in the memory of your computer. In the cookie a session identifier is stored to, e.g. prevent you from having to log in again each time you change pages. Session cookies are deleted when you log out or lose their validity as soon as your session has automatically expired.

Persistent or stored cookies:

Persistent cookies store a file on your computer for the period of time specified in the expiry date. These cookies enable websites to remember your information and settings the next time you visit. This results in faster and more convenient access; for example, you don’t have to set your language preferences for our portal again. Once the expiry date has elapsed, the cookie is automatically deleted when you visit the website that generated it.

Third-party cookies:

Third-party cookies come from providers other than the website operator. They may be used, for example, to collect information for advertising, custom content and web statistics.

Most Internet browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears when you receive a new cookie. Please visit the following webpages to find out how to configure the processing of cookies in the most common browsers:

Microsoft Windows Internet Explorer

Microsoft Windows Internet Explorer Mobile

Mozilla Firefox

Google Chrome for Desktop

Google Chrome for Mobile

Apple Safari for Desktop

Apple Safari for Mobile

Deactivating cookies may mean that you are not able to use all the functions on our website.

D. T RACKING TOOLS 1. GOOGLE ANALYTICS

Based on your consent, we use the web analytics service of Google Analytics in its function of Universal Analytics to design our websites to meet users’ needs and to optimise them continuously. For this purpose, pseudonymised user profiles are created and cookies stored on your computer are used. The information generated by the cookie is transmitted to the Google Analytics server where it is stored and processed for us. In some cases, we may thus receive the following information:

 Navigation path taken by a visitor on the site

 Time spent on the websites or a subpage

 The subpage from which the webpage is left

 The country, region or city from which a website is accessed

 Device (type, version, colour depth, resolution, width and height of the browser window) and

 Returning or new visitor

The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services relating to website activity and Internet use for market research and demand-oriented design of our websites. This information may also be transmitted to third parties if required by law or if third parties process this data on our behalf (see also section 17 ff.).

Provider of Google Analytics is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, or, if you are a resident of the European Economic Area (EEA) or Switzerland, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

Before the data is transmitted to the provider, the IP address is truncated by activating the IP anonymisation (“anonymizeIP”) on our websites within the Member States of the European Union or other parties to the Agreement on the European Economic Area. The anonymised IP address transmitted by your browser for Google Analytics will not be amalgamated with any other data held by Google. Only in exceptional cases will the full IP address be transmitted to Google servers in the USA and truncated there. In such cases, we ensure by means of contractual guarantees that Google Inc. maintains an adequate level of data protection. According to Google Inc. the IP address will under no circumstances be associated with other data concerning the user.

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 (including your IP address), as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: DOWNLOAD PAGE FOR THE BROWSER ADD-ON TO DISABLE GOOGLE ANALYTICSInstructions on how to prevent the processing of your data by the web analytics service can be found HERE.

For further information on terms of use and data protection, please see Privacy Policy - Privacy & Terms - Google or Privacy Policy - Privacy Policy & Terms of Use - Google.

2. GOOGLE TAG MANAGER

We also use Google Tag Manager to integrate and manage Google's analytics and marketing services on our websites. Google Tag Manager is a solution that allows us to manage website tags through one interface. The Google Tag Manager tool itself, which implements the tags, is a cookie-less domain and does not collect any personal data. However, the tool triggers other tags, which in turn may collect data. Google Tag Manager itself, however, does not access this data. If a deactivation has been made at domain or cookie level, this remains in place for all tracking tags that are implemented with Google Tag Manager.

Provider of Google Tag Manager is Google LCC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, or, if you are a resident of the European Economic Area (EEA) or Switzerland, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

For further information related to Google Tag Manager, see the GOOGLE TAG MANAGER USAGE GUIDELINES.

3. GOOGLE MAPS

Based on your consent, we integrate Google Maps in our location page in order to display our locations.

Provider of Google Maps is Google LCC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, or, if you are a resident of the European Economic Area (EEA) or Switzerland, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

When you visit our websites, data (such as your IP address) is transmitted to a Google server in the USA and stored there. Google stores this data as usage profiles for the purpose of tailoring services, advertising and market research. If you are logged in to Google, this data will be directly assigned to your account. If you do not wish this, you must log out beforehand.

You can prevent the use of Google Maps by deactivating Javascript in your browser settings. This may lead to functional restrictions in the use of the website in individual cases.

For further information on data processing and notes on data protection by Google Maps see: ADDITIONAL TERMS OF USE FOR GOOGLE MAPS/EARTH - GOOGLE

4. USE OF USER-GENERATED CONTENT / SQUARELOVIN

Based on your consent, we use the services of Squarelovin, Anchor Media GmbH, Budapester Strasse 45, 20359 Hamburg, Germany, on our websites to display user-generated content

The content for this is collected by the social network "Instagram" (www.instagram.com) and made available for use in galleries on our websites. Personal data is not analysed in the process. Within the scope of the analysis, it is not possible for us to analyse you and your behaviour on our website. Rather, we only access statistically evaluated data, which is not used by Anchor Media for other marketing purposes either.

For further information, see https://squarelovin.com/privacy/

5. MOUSEFLOW

Mouseflow is a web analytics tool that can be used by our websites to analyse user behaviour on our websites and make appropriate optimisations. Mouseflow procures and processes the following data:

 Clicks, mouse movements, hovering, scrolling

 Browser and device (desktop/tablet/mobile)

 Language

 Operating system and screen resolution

 Duration of visit

 Navigation (URLs) and page content (HTML), referrer URL

 IP and location (city, country)

 Visitor type (first-time visitor/returning visitor)

 Individual tags or variables

The information is used to evaluate the use of the websites, to compile reports and heat maps on website activity and to provide other services relating to website activity and Internet use for market research and demand-oriented design of our websites. This information may also be transmitted to third parties if required by law and if third parties process this data on our behalf (see also section 17 ff.).

Provider of Mouseflow is Mouseflow ApS, which is based at Flaesketorvet 68, 1711 Copenhagen, Denmark. For further information about this web analytics service we use, visit the Mouseflow websites. Instructions on how to prevent your data from being processed by the web analytics service can be found here

6. MYFONTS COUNTER

MyFonts Counter is a web analytics service which enables page view tracking by counting the number of visits to our websites for statistical purposes and transmitting it to MyFonts. In doing so, MyFonts collects anonymised data. This data is passed on when JavaScript is activated in your browser. To prevent the execution of JavaScript, you can install a JavaScript blocker (e.g. www.noscript.net).

MyFonts Counter is a service provided by MyFonts Inc., 600 Unicorn Park Drive, Woburn, MA 01801, USA. For further information about this web analytics service we use, visit the MyFonts Counter websites. Information about privacy at MyFonts can be found here

E. R E - TARGETING

So-called “re-targeting” technologies may be used on the websites. These technologies analyse your user behaviour on our websites in order to be able to offer you customised advertising on later visits, including on partner websites. Your user behaviour is recorded in pseudonymised form. Most re-targeting technologies operate using cookies (see section 7). You can prevent retargeting at any time by refusing or deactivating the relevant cookies in your web browser’s menu bar.

1. DOUBLECLICKGOOGLE MARKETING PLATFORM

We may use Google Marketing Platform to display advertising based on the use of previously visited websites. Google uses the so-called “DoubleClick” cookie for this purpose, which makes it possible to recognise your browser when you visit other websites. The information generated by the cookie about your visit to our websites (including your IP address) is transmitted to Google servers in the USA and stored there.

Google will use this information for analysing your use of the websites in view of the advertisements to be displayed, compiling reports on website activity and advertisements for website operators and providing other services relating to website activity and Internet usage. Google may also transmit this information to third parties if required by law or if third parties process this data on its behalf. Google will, however, under no circumstances associate your IP address with other data held by Google.

2. MICROSOFT CLARITY

We use Microsoft Clarity, provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, to better understand the needs of our users and optimise the experience on this website. Clarity's technology helps us to better understand our users' experiences (e.g. how much time users spend on which pages, which links they click on, what they like and dislike, etc.) and to tailor our offerings based on user feedback. Clarity uses cookies and other technologies to collect information about the behaviour of our users and their devices (in particular, device IP address (collected and stored only in anonymised form), screen size, device type (unique device identifiers), information about the browser used, location (country only), preferred language for viewing our website). Clarity stores this information in a pseudonymised user profile. The information is neither used by Clarity nor by us to identify individual users nor is it amalgamated with other data about individual users. For further information, see the Microsoft Clarity privacy policy.

For further information about Microsoft Clarity or how Microsoft might use your data, see: Microsoft Privacy Policy - Microsoft Privacy.

3. APPNEXUS

We may use AppNexus. AppNexus consists of a technical platform that can be used for buying, selling and offering interest-based online advertising (usually via so-called real-time bidding). Thus, AppNexus does not buy, sell or offer advertising itself, but provides us with the technology. To collect and store platform data concerning browsers and end devices via websites and apps

for a longer period of time, the platform uses technologies such as cookies and also non-cookie technologies. AppNexus does not share the data collected on the platform with others.

AppNexus is a service provided by AppNexus Inc., 28 W. 23rd Street, 10010 New York, USA. For further information about the re-targeting tool we use, visit the AppNexus websites. For further information about privacy at AppNexus, see here

4. FACEBOOK CONNECT

Our websites may use Facebook Connect. Facebook Connect is a function offered by Facebook that allows Facebook users to log in to other websites, apps and services using their Facebook identity. Thus, the other service gains access to certain preferences and links stored in Facebook on which it can base its own offers. Facebook may use data concerning the steps users take while using these other services to recognise visitors to our websites when they use Facebook services and to provide them with personalised offers based on their interests and preferences.

Facebook Connect is a service provided by Facebook Inc., 1601 S California Ave., Palo Alto, CA 94304, USA, or, if you are an EU resident, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For further information about the re-targeting tool we use, visit the Facebook websites. You can refuse this form of advertising by adjusting your browser settings here

5. FACEBOOK CUSTOM AUDIENCE

We may use Custom Audience, which is a communication tool. Basically, when Custom Audience is used, a non-reversible and non-personal checksum (hash value) is generated from your usage data and may be transmitted to Facebook for analysis and marketing purposes. The Facebook cookie is accessed to do this.

Custom Audience is a service provided by Facebook Inc., 1601 S California Ave., Palo Alto, CA 94304, USA or, if you are an EU resident, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For further information about the re-targeting tool we use, visit the Facebook websites. You can object to the use of Facebook Custom Audience here

6. FACEBOOK PIXEL

Based on your consent, we use so-called "Facebook Pixel". Facebook Pixel is a service of Facebook Inc., 1601 S California Ave., Palo Alto, CA 94304, USA or, if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With the help of the Facebook Pixel, the behaviour of site visitors can be tracked after they have been redirected to our website by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimised.

The data collected in this way is anonymous for us, so it does not allow us to draw any conclusions about your identity. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can, in accordance with the Facebook data policy [Facebook], use the data for its own advertising purposes. This enables Facebook to display advertisements on Facebook pages as well as outside of Facebook. We have no influence on this use of the data.

Through the use of cookies, i.e. text files that are stored on your terminal device, Facebook can subsequently recognise you in the Facebook member area and can, in accordance with Facebook's data usage policy, optimise the efficiency of advertisements, e.g. offer advertisements targeted to specific groups.

You can opt out of the collection of your data by the Facebook Pixel and its use for the display of Facebook ads. For this purpose, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising. To this end, you must be logged in to Facebook. If you don’t have a Facebook account, you can opt out of the use of cookies that are used for reach measurement and advertising purposes via the Network Advertising Initiative opt-out page (http://optout.networkadvertising.org/) and, additionally, via the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

For general information on Facebook’s use of data, your rights in this regard and ways to protect your privacy, see Facebook's data policy at https://www.facebook.com/policy. For specific information and details about the Facebook Pixel and how it works, see Facebook’s help section.

F. L INKS ON OUR SOCIAL MEDIA PAGES

We have included links to our social media profiles on our websites. The links may lead to the following networks:

 Facebook Inc., 1601 S California Ave., Palo Alto, CA 94304, USA

 Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA

 Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA

 YouTube, a service operated by Google Inc.

 Tripadvisor Inc., 400 1st Avenue, Needham, MA 02494, USA

 Pinterest Inc., 635 High Street, Palo Alto, CA 94301, USA

 LinkedIn Ireland Unlimited Company, Dublin 2, Ireland

 Xing SE, Dammtorstrasse 30, 20354 Hamburg, Germany

 Kununu GmbH, Neutorgasse 4-8, 1010 Vienna, Austria

When you click on the relevant social network icons, you will automatically be redirected to our profiles on the respective networks. You may have to log in to your user account to use the relevant network’s functions. If you open a link to one of our social media profiles, a direct connection will be established between your browser and the server of the respective social network. This provides the network with the information that you are visiting our websites with your IP address and have opened the link. If you open a link to a network while you are logged into your account with the relevant network, the content of our site may be linked to your profile on the network, which means that the network can assign your visit to our websites directly to your user account. If you want to prevent this, you should log out before clicking on the corresponding links. An assignment will be made in any case if you log in to the relevant network after clicking on the link.

G. PROCESSING DATA IN CONNECTION WITH YOUR STAY

1. PROCESSING DATA TO COMPLY WITH STATUTORY REGISTRATION OBLIGATIONS

When you arrive at our hotels, we require the following information from you and the persons accompanying you:

 First and last name

 Sex

 Postal address and canton

 Date of birth

 Nationality

 Official identification card and number

 Arrival and departure day

 Number of persons, incl. children

We collect this information to comply with statutory notification obligations arising from hotel and catering industry and police legislation in particular. As far as we are obliged to do so by the applicable provisions, we will forward this information to the competent police authority.

Entering further information is optional. We will only use this data to be able to arrange your stay the best possible and in a personalised manner.

2. PROCESSING DATA TO PROVIDE THE BOOKED SERVICE IN GENERAL

When you arrive at our hotels, we require the following information from you and the persons accompanying you:

 First and last name

 Postal address and canton

 Date of birth

 Nationality

 Official identification card and number

 Arrival and departure day

 Room number and type

 Telephone number

 E-mail address

 Comment (background note)

We collect this information to comply with our contractual and post-contractual obligations towards you.

The processing of this data is necessary for executing the contract with us.The further data processing is based on our legitimate interest in providing the service and/or on the consent given by you.

3. PROCESSING DATA IN ORDER TO PROVIDE SERVICES IN THE SPA AND WELLNESS AREA

If you receive services offered in our spa and wellness area during your stay at our hotels, the service (e.g. single entrance) and the time it was received will be recorded and processed by us for billing purposes and in order to provide the booked service. Usually, we require the following information for this purpose:

 First and last name

 Postal address

 E-mail address

 Telephone number

 Room number (if available)

 You also have the option to join our Alpine Spa Member’s Club. To process your request to become a member and in particular to contact you, the following information is mandatory:

 First and last name

 E-mail address

 Telephone number

The processing of this data is necessary for executing the contract with us. The further data processing is based on our legitimate interest in providing the service and/or on the consent given by you

4. PROCESSING DATA IN ORDER TO PROVIDE LEISURE SERVICES AND ACTIVITIES BOOKED

If you receive leisure services or book activities during your stay at our hotels, the service (e.g. fitness analysis or cinema visit) and the time it was received will be recorded and processed by us for billing purposes and in order to provide the booked service. Usually, we require the following information for this purpose:

 Form of address

 First and last name

 Sex

 Date of birth

 Nationality

 Postal address

 E-Mail address

 Telephone number

 Room number (if available)

 Language

 Contact person

 Referring doctor

For patients/guests from Switzerland: additionally the insurance incl. policy, VEKA and AHV no., and the address.

The processing of this data is necessary for executing the contract with us. The further data processing is based on our legitimate interest in providing the service and/or on the consent given by you.

5. PROCESSING DATA IN ORDER TO PROVIDE MEDICAL SERVICES

If you receive medical services during your stay at our hotels, the service (e.g. diagnosis, treatment) and the time it was received will be recorded and processed by us for billing purposes, and in order to provide the booked service and to draw up the treatment plans. Usually, we require the following information for this purpose:

 Form of address

 Last name

 First name

 Sex

 Date of birth

 Nationality

 For patients/guests from Switzerland:

 additionally the insurance incl. policy, VEKA and AHV no.

 Complete address (incl. street, postal code, town, country/canton)

 Optionally, the following may be filled in:

 Telephone

 E-mail address

 Civil status

 Denomination

 Language

 Contact person

 Referring doctor / general practitioner, First and last name

 Postal address

 Date of birth

 Health insurance information

 Information on the health state

 E-mail address

 Telephone number

 Room number (if available)

The processing of this data is necessary for executing the contract with us. The further data processing is based on our legitimate interest and on the consent given by you

6. PROCESSING DATA IN THE CONTEXT OF SURVEYS

If you participate in surveys (on-site or online) to evaluate your stay at our hotel, the following personal data will usually be processed:

 First and last name

 Postal address

 E-mail address

 Telephone number

 Room number (if available)

Processing this data enables us to improve our services and customer relations. For this purpose, we use the software from Qualtrics, 2250 N. University Pkwy, 48-C, Provo, Utah 84604, USA. For information about privacy at Qualtrics, see HTTPS://WWW.QUALTRICS.COM/PRIVACYSTATEMENT/. In addition, we use Revinate by Revinate Inc., One Letterman Drive, Bldg. C, Suite CM100, San Francisco, CA 94129, USA. For information about privacy at Revinate , see:

HOTEL CRM & E-MAIL MARKETING SOFTWARE | REVINATE The legal basis for processing the data is the consent given by you.

The personal data processed as part of the customer survey will be kept in pseudonymised form for five years after completion of the customer survey and then deleted.

7. PROCESSING DATA IN ORDER TO PROVIDE FURTHER SERVICES

If you receive further services during your stay at our hotels (e.g. from the mini-bar or W-LAN), the service and the time it was received will be recorded and processed by us for billing purposes. The processing of this data is necessary for executing the contract with us.

H. EXPRESSION OF INTEREST IN THE PURCHASE OF A BÜRGENSTOCK RESIDENCE AND/OR LAKEVIEW VILLA

1. EXPRESSION OF INTEREST

If you are interested in our Bürgenstock Residences and/or Lakeview Villas, you can express your interest in conversation with us, by telephone, by e-mail, via the link we provide or via the website. This way, you let us know your preferences regarding the property you are looking for.

For this purpose, we collect the following personal data:

 Details of the object

 Kind of interest (purchase, rent)

 Form of address

 First and last name

 Company name

 Postal address

 Nationality

 Telephone number

 E-mail address

 Preferred form of contact (e-mail, telephone)

If you express your interest via our website, the following data will also be stored at the time of sending the message:

 IP address

 Date and time of submission from the page on which the form was filled in

We only use this data to provide you with tailored advice regarding the purchase of a Bürgenstock Residence and/or Lakeview Villa and the resort offers available on site. The legal basis for processing the data is the consent given by you and our legitimate interests.

In addition, the contacting aims at the conclusion of a contract. Thus, the data processing is also necessary for the purpose of carrying out pre-contractual measures and for the fulfilment and processing of the contract.

You can revoke your consent to the processing of personal data or object to the processing of personal data at any time. In the event of revocation or objection, your data will be deleted immediately, unless legal regulations only provide for a blocking of the data.

2. ANALYSIS OF CUSTOMER NEEDS

If you express your interest in our Bürgenstock Residences and/or Lakeview Villas, we will contact you and have a personal conversation with you to analyse your needs.

For this purpose, we collect the following categories of personal data in addition to the information mentioned above:

 Personal data (language, nationality, employer, pets, hobbies (if relevant), health data, intolerances etc.)

 Kind of housing you are seeking (floor space (m2), number of rooms, view, location (within the resort), outdoor area, furnishing, parking facilities, etc.).

 Financial motivation (e.g. advice on financing, taxes and legal issues);

 The price you have in mind;

 Special categories of personal data / data requiring specific protection, such as health data in the context of a consultation on on-site medical services.

You can decide yourself which personal data you provide. The provision of this personal data is voluntary. We only collect the personal data that you disclose to us. Consequently, you yourself are responsible for the content of your message to us and it is up to you which information you provide to us.

The personal data collected during the analysis will be exclusively used for personal information regarding suitable real estate offers.

If there are any real estate offers matching your search criteria, we can inform you by e-mail, letter or telephone.

The legal basis for processing the data is the consent given by you and our legitimate interests.

In addition, the needs analysis aims at the conclusion of a contract. Thus the data processing is also necessary for the purpose of carrying out pre-contractual measures and for the fulfilment and processing of the contract.

You can revoke your consent to the processing of personal data or object to the processing of personal data at any time. In the event of revocation or objection, your data will be deleted immediately, unless legal regulations only provide for a blocking of the data.

3. TRANSMISSION TO THIRD PARTIES

The personal data collected from you will be shared with Bader Immobilien Luzern AG.

The legal basis for the disclosure to Bader Immobilien Luzern AG is the consent given by you.

Beyond that, your personal data will not be passed on.

I. STORAGE OF DATA AND EXCHANGE WITH THIRD PARTIES

1. CENTRAL STORAGE AND LINKING OF DATA

The personal data collected from you is stored centrally in our CRM system. The data in the central CRM system is processed by us for the management of the customer relationships and for advertising purposes, in particular to be able to offer you personalised services and products.

The legal basis for processing the data in the context of customer management is the execution of the contract. With regard to data processing in the context of advertising activities, the legal basis is, on the one hand, also the execution of the contract (the existing customer relationship justifies data processing for the purpose of advertising activities) and, on the other hand, the consent given by you (see section 3).

2. RETENTION PERIOD

We store personal data only as long as it is necessary to use the tracking services mentioned above and to make use of the further processing within the scope of our legitimate interest. Contract data will be retained by us for a longer period of time since this is required by statutory retention obligations. Retention obligations that require us to retain data result from provisions regarding registration law, on accounting and from tax legislation. In accordance with these provisions, business communication, contracts concluded and booking documents must be retained for up to 10 years. As far as we do not need this data any more to perform services for you, the data will be blocked. This means that the data may then only be used for accounting and tax purposes.

3. TRANSMISSION OF THE DATA TO THIRD PARTIES

We only pass on your personal data if you have expressly consented to this, if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship. Furthermore, we pass on your data to third parties as far as this is necessary or expedient within the framework of the use of the website and the processing of contracts (also outside the website), namely the processing of your bookings, e.g. when purchasing vouchers.

We transmit your personal data to the following categories of recipients:

Group companies

 IT service providers

 Third parties to whom we have outsourced services such as sending newsletters, translation work or document checks

 Third parties that we engage to provide further services that we provide to our guests,

 Third parties involved in the implementation or organisation of events and seminars

 Consultants, trust companies, law firms

 Authorities and courts, if applicable

If the level of data protection in a country in which the data is processed does not comply with the applicable data protection regulations, we will contractually ensure that the protection of your personal data will at all times correspond to that in Switzerland or the EU/EEA.

Finally, when you pay by credit card on the website, we forward your credit card information to your credit card issuer and to the credit card acquirer. If you decide to pay by credit card, you will be asked to enter all mandatory information. The legal basis for the transmission of the data is the fulfilment of a contract. Regarding the processing of your credit card information by these third parties, we ask you to also read the general terms and conditions as well as the privacy policy of your credit card issuer.

In the case of transmission to third parties, the legal provisions on the transmission of personal data to third parties are, of course, complied with. If we employ processors to provide our services, we take appropriate legal precautions as well as corresponding technical and organisational measures to ensure the protection of your personal data in accordance with the relevant legal regulations.

4. COLLECTING DATA VIA BOOKING PLATFORMS

If you make bookings via a third-party platform, we receive various personal information from the respective platform operator (e.g. in the case of table reservations via the external platforms "Bookatable" and "La Fourchette"). Usually, this is the data listed in section 5 of these Privacy Policy. In addition, enquiries about your booking may be forwarded to us. We will process this data by name in order to record your booking as requested and to provide the booked services. The legal basis for processing the data for this purpose is the fulfilment of a contract.

Finally, we may be informed by the platform operators of disputes in connection with a booking. In the process, we may also receive data on the booking process, which may include a copy of the booking confirmation as proof of the actual booking completion. We process this data to maintain and enforce our claims. This is our legitimate interest.

Please also note the privacy policy of the respective provider.

5. TRANSFER OF PERSONAL DATA ABROAD

If we also transfer your personal data to third parties abroad (i.e. outside Switzerland or the European Economic Area (EEA)), these are obliged to comply with data protection to the same extent as we are. If the level of data protection in the country concerned is not adequate, we will ensure that the protection of your personal data has such a level.

We ensure this in particular by concluding so-called standard data protection clauses of the EU Commission with the companies concerned, and/or by the existence of Binding Corporate Rules (BCR) recognised by a European data protection authority at the companies concerned and/or by the existence of further guarantees that comply with the applicable law. Where this is not possible, we base the transfer of data on your express consent or the necessity of the transfer for the performance of a contract. J.

FURTHER INFORMATION

1. RIGHT TO ACCESS, RECTIFICATION, ERASURE AND RESTRICTION OF PROCESSING; RIGHT TO DATA PORTABILITY

You have the right to gain access to the personal data that we store about you upon request. You also have the right to rectification of incorrect data and the right to erasure of your personal data provided that this is not precluded by any statutory retention obligation or permission which allows us to process the data.

In addition, you have the right to ask us to return the data you have provided to us (right to data portability). Upon request, we will also pass on the data to a third party of your choice. You have the right to receive the data in a commonly used file format.

For the purposes specified above, you can contact us via the e-mail address:

data-privacy@burgenstockresort.com

data-privacy@schweizerhofbern.com

data-privacy@royalsavoylausanne.com

For the processing of your requests, we may reserve the right to ask for a proof of your identity.

2. DATA SECURITY

We use appropriate technical and organisational security measures to protect your personal data stored with us against manipulation, partial or total loss and unauthorised access by third parties. Our security measures are improved on an ongoing basis and in line with technological developments.

You should always keep your login details confidential and close the browser window when you have finished communicating with us, especially if you share your computer with others.

We also take internal data protection very seriously. We have bound our employees and the service providers commissioned by us to secrecy and to comply with data protection provisions.

3. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY DATA PROTECTION AUTHORITY.

You have the right to lodge a complaint with a supervisory data protection authority at any time. In Switzerland, this is the Federal Data Protection and Information Commissioner.

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