Visit Graubunden
Hamb

Privacy Policy

With this Privacy Policy, we inform you about the personal data we process in connection with our activities and operations, including our visitgraubunden.com website. We provide information about the purposes, methods, and locations of the personal data we process. We also inform you about the rights of individuals whose data we process.

Additional privacy policies and other legal documents such as Terms and Conditions (T&C), Terms of Use, or Participation Terms may apply to individual or additional activities and operations.

We are subject to Swiss data protection law as well as, if applicable, foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission acknowledges that Swiss data protection law provides adequate data protection.

1. Contact Information

Responsible for the processing of personal data:

Graubünden Ferien
Alexanderstrasse 24
7001 Chur
Switzerland

[email protected]

We would like to point out that there may be other data controllers in individual cases.

1.1 Data Protection Officer

We have the following data protection officer as a point of contact for data subjects and as a contact person for supervisory authorities regarding data protection inquiries:

Manuela Ruinatscha
Graubünden Ferien
Alexanderstrasse 24
7001 Chur
Switzerland

[email protected]

1.2 Data Protection Representative in the European Economic Area (EEA)

We have the following data protection representative in accordance with Article 27 of the GDPR. The data protection representative serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the European Economic Area (EEA) regarding inquiries related to the General Data Protection Regulation (GDPR):

VGS Datenschutzpartner UG
Am Kaiserkai 69
20457 Hamburg
Germany

[email protected]

2.1 Terms

Personal data refers to any information relating to an identified or identifiable individual. An data subject is a person about whom personal data is processed.

Processing includes any operation or set of operations performed on personal data, regardless of the means and methods used, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, combination, restriction, erasure, or destruction of personal data.

The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (DSG) and the Ordinance to the Federal Act on Data Protection (VDSG).

If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data based on at least one of the following legal bases:

  • Article 6(1)(b) of the GDPR for the necessary processing of personal data for the performance of a contract with the data subject or for the implementation of pre-contractual measures.
  • Article 6(1)(f) of the GDPR for the necessary processing of personal data to protect our legitimate interests or those of third parties, unless the fundamental rights and freedoms of the data subject outweigh those interests. Legitimate interests include, in particular, our interest in exercising our activities and operations on a permanent, user-friendly, secure, and reliable basis, as well as being able to communicate about them, ensuring information security, protecting against misuse, enforcing our own legal claims, and complying with Swiss law.
  • Article 6(1)(c) of the GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
  • Article 6(1)(e) of the GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Article 6(1)(a) of the GDPR for the processing of personal data with the data subject's consent.
  • Article 6(1)(d) of the GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

3. Type, Scope, and Purpose

We process personal data that is necessary to permanently, user-friendly, securely, and reliably carry out our activities and operations. Such personal data may include categories such as inventory and contact information, browser and device data, content data, metadata or marginal data, usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration that is necessary for the respective purpose(s) or as required by law. Personal data that is no longer necessary for processing will be anonymized or deleted.

We may engage third parties to process personal data. We may process personal data jointly with third parties or disclose it to third parties. Such third parties are particularly specialized service providers whose services we utilize. We ensure data protection with regard to these third parties as well.

We process personal data only with the consent of the data subject, unless the processing is permissible for other legal reasons. Processing without consent may, for example, be permissible for the fulfillment of a contract with the data subject and for corresponding pre-contractual measures, to safeguard our overriding legitimate interests when processing is apparent from the circumstances, or after prior notification.

In this context, we process, in particular, information that a data subject voluntarily provides to us when contacting us, for example, by postal mail, email, instant messaging, contact form, social media, or telephone, or when registering for a user account. We may store such information, for example, in an address book or with similar tools. If we receive data about other persons, the transmitting individuals are obliged to ensure data protection for these individuals and to ensure the accuracy of this personal data.

Furthermore, we process personal data that we receive from third parties, obtain from publicly accessible sources, or collect during the course of our activities and operations, to the extent permitted by legal reasons.

4. International Data Transfer

We process personal data primarily in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, particularly for processing purposes.

We may export personal data to any country or territory on Earth and beyond, in the Universe, as long as the local laws in accordance with the assessment of the Federal Data Protection and Information Commissioner (FDPIC) or based on the decision of the Swiss Federal Council provide adequate data protection and, where applicable, according to the European Commission's decision, ensure adequate data protection in accordance with the General Data Protection Regulation (GDPR).

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

5. Rights of Data Subjects

Data subjects, whose personal data we process, have the rights according to Swiss data protection law. These rights include the right to information as well as the right to rectification, erasure, or blocking of the processed personal data.

Data subjects, whose personal data we process, can, if and to the extent that the General Data Protection Regulation (GDPR) is applicable, request confirmation free of charge as to whether we are processing personal data concerning them. In this case, data subjects can request information about the processing of their personal data, restrict the processing of their personal data, exercise their right to data portability, as well as rectify, erase ("right to be forgotten"), block, or complete their personal data.

Data subjects, whose personal data we process, can, if and to the extent that the GDPR is applicable, revoke their consent given at any time with effect for the future and object to the processing of their personal data at any time.

Data subjects, whose personal data we process, have the right to lodge a complaint with a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

6. Data Security

We implement appropriate technical and organizational measures to ensure data security that is appropriate to the respective risks. However, we cannot guarantee absolute data security.

Access to our website is encrypted using transport encryption (SSL/TLS, especially with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock symbol in the address bar.

Our digital communication is subject to mass surveillance without cause or suspicion, as well as other forms of surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries, as is the case with all digital communication. We cannot directly influence the corresponding processing of personal data by intelligence agencies, law enforcement agencies, and other security authorities.

7. Use of the Website

7.1 Cookies

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

Cookies can be stored in the browser temporarily as "session cookies" or for a specific period as so-called persistent cookies. "Session cookies" are automatically deleted when the browser is closed. Persistent cookies have a specific storage duration. Cookies allow, in particular, recognizing a browser on the next visit to our website, enabling us to measure the reach of our website, for example. However, persistent cookies can also be used for online marketing purposes.

Cookies can be disabled or deleted entirely or partially in the browser settings at any time. Without cookies, our website may not be fully available. We request, at least if necessary, explicit consent for the use of cookies.

For cookies used for measurement of success and reach or for advertising purposes, a general objection ("opt-out") is possible for numerous services through the 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).

7.2 Server Log Files

We may collect the following information for each access to our website if it is transmitted by your browser to our server infrastructure or can be determined by our web server: date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, accessed individual sub-page of our website including transferred data volume, and the previously accessed website in the same browser window (referer or referrer).

We store such information, which can also constitute personal data, in server log files. The information is necessary to provide our website permanently, in a user-friendly and reliable manner, and to ensure data security, in particular, the protection of personal data, even by third parties or with the help of third parties.

7.3 Tracking Pixels

We may use tracking pixels, also known as web beacons, on our website. Tracking pixels, including those from third parties whose services we use, are small, usually invisible images that are automatically retrieved when visiting our website. Tracking pixels can capture the same information as server log files.

8. Notifications and Communications

We send notifications and communications via email and other communication channels such as instant messaging or SMS.

8.1 Success and Reach Measurement

Notifications and communications may contain web links or tracking pixels that capture whether an individual notification was opened and which web links were clicked. Such web links and tracking pixels can also capture the personal usage of notifications and communications. We require this statistical measurement of usage for success and reach measurement in order to effectively and user-friendly send notifications and communications based on the needs and reading habits of recipients, as well as to ensure their long-term, secure, and reliable delivery.

In general, you must expressly consent to the use of your email address and other contact information, unless the use is permissible for other legal reasons. If possible, we use the "double opt-in" procedure for obtaining consent, which means you receive an email with a web link that you must click to confirm, ensuring that no unauthorized third parties can abuse it. We may log such consents, including the internet protocol (IP) address, date, and time, for evidentiary and security purposes.

In general, you can object to receiving notifications and communications, such as newsletters, at any time. By objecting, you can also simultaneously object to the statistical measurement of usage for success and reach measurement. Necessary notifications and communications related to our activities and operations remain reserved.

8.3 Service Providers for Notifications and Communications

We send notifications and communications with the help of specialized service providers.

We use the following:

9. Social Media

We have 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 be processed outside Switzerland and the European Economic Area (EEA).

The terms and conditions, usage policies, privacy policies, and other provisions of each operator of such platforms also apply. These provisions provide information, in particular, about the rights of data subjects directly vis-à-vis the respective platform, including the right to information.

For our Facebook social media presence, including so-called page insights, we are jointly responsible – to the extent that the General Data Protection Regulation (GDPR) is applicable – with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including in the USA). Page insights provide information about how visitors interact with our Facebook presence. We use page insights to effectively and user-friendly provide our social media presence on Facebook.

Further information about the nature, scope, and purpose of data processing, information about the rights of data subjects, and the contact details of Facebook, as well as Facebook's data protection officer, can be found in the Facebook Privacy Policy. We have concluded the so-called "Controller Addendum" with Facebook, thereby agreeing, in particular, that Facebook is responsible for ensuring the rights of data subjects. The corresponding information for page insights can be found on the 10. Third-Party Services

We use services from specialized third parties to conduct our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us to embed features and content into our website. For such embedding, the utilized services may temporarily collect users' Internet Protocol (IP) addresses for technical reasons.

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

We specifically use:

10.1 Digital Infrastructure

We utilize services from specialized third parties to access the required digital infrastructure in connection with our activities and operations. This includes hosting and storage services from selected providers.

We specifically use:

10.2 Audio and Video Conferencing

We use specialized services for audio and video conferencing to facilitate online communication. These services allow us to conduct virtual meetings, online classes, and webinars, among other things. The participation in audio and video conferences is subject to the respective service's legal texts, such as privacy policies and terms of use.

We recommend muting the microphone by default and blurring the background or using a virtual background, depending on the individual's circumstances during audio or video conferences.

We specifically use:

10.3 Social Media Features and Social Media Content

We use services and plugins from third parties to embed features and content from social media platforms, as well as to enable content sharing on social media platforms and other channels.

We specifically use:

10.4 Map Material

We use services from third parties to embed maps into our website.

We specifically use:

10.5 Digital Audio and Video Content

We use services from specialized third parties to enable direct playback of digital audio and video content, such as music or podcasts.

We specifically use:

10.6 Advertising

We utilize the opportunity to display targeted advertisements for our activities and operations through third parties, such as social media platforms and search engines.

With such advertising, we aim to reach individuals who are already interested in or may be interested in our activities and operations (remarketing and targeting). For this purpose, we may transmit relevant – possibly personally identifiable – information to third parties that enable such advertising. Additionally, we may determine whether our advertising is successful, particularly in terms of whether it leads to visits to our website (conversion tracking).

Third parties on which we advertise and where you, as a user, are logged in, may associate the use of our online offering with your respective profile.

We specifically use:

11. Extensions for the Website

We use extensions for our website to access additional features.

In particular, we use:

12. Success and Reach Measurement

We use services and programs to determine how our online offering is used. In this context, we can measure the success and reach of our activities and the impact of third-party links to our website. We may also experiment and compare how different versions of our online offering or parts of our online offering are used (A/B testing method). Based on the results of success and reach measurement, we can fix errors, strengthen popular content, or make improvements to our online offering.

When using services and programs for success and reach measurement, the Internet Protocol (IP) addresses of individual users need to be stored. IP addresses are generally truncated ("IP masking") to follow the principle of data minimization through pseudonymization, thus improving the privacy of users.

When using services and programs for success and reach measurement, cookies may be used, and user profiles may be created. User profiles may include visited pages or viewed content on our website, information about screen size or browser window, and at least approximate location. User profiles are generally created in a pseudonymized form and are not used for identifying individual users. Certain third-party services where users are logged in may associate the usage of our online offerings with their user accounts or profiles.

In particular, we use the following:

  • Google Analytics: Success and reach measurement; Provider: Google; Specific information about Google Analytics: Measurement across different browsers and devices (cross-device tracking) and the use of pseudonymized Internet Protocol (IP) addresses that are only exceptionally transmitted to Google in the United States, "Privacy", "Browser add-on for disabling Google Analytics".
  • Google Tag Manager: Integration and management of other services for success and reach measurement, as well as additional services from Google and third parties; Provider: Google; Specific information about Google Tag Manager: "Data collected by Google Tag Manager"; further information on data privacy can be found in the individual integrated and managed services.

13. Concluding Provisions

We have created this privacy policy using the Privacy Policy Generator provided by Datenschutzpartner.

We reserve the right to adjust and supplement this privacy policy at any time. We will inform about such adjustments and supplements in an appropriate manner, in particular by publishing the respective current privacy policy on our website.

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