With this Privacy Policy, we provide information about the processing of personal data in connection with our activities and operations, including our website under the domain name visitgraubunden.com. In particular, we explain for what purposes, how, and where we process which personal data. We also inform individuals whose data we process about their rights.
For individual or additional activities and operations, we may publish further privacy policies or other information relating to data protection.
We are subject to Swiss law and, where applicable, foreign law, in particular that of the European Union (EU), including the European General Data Protection Regulation (GDPR).
By Decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures an adequate level of data protection. With its Report of 15 January 2024, the European Commission confirmed this adequacy decision.
The controller within the meaning of data protection law is:
Graubünden Ferien
Alexanderstrasse 24
7001 Chur
Switzerland
In individual cases, third parties may be responsible for the processing of personal data, or there may be joint controllership with third parties. Upon request, we will be happy to provide data subjects with information about the respective responsibility.
We have appointed the following data protection officer or data protection advisor as a point of contact for data subjects and authorities for enquiries related to data protection:
Manuela Ruinatscha
Graubünden Ferien
Alexanderstrasse 24
7001 Chur
Switzerland
We have the following data protection representative pursuant to Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The data protection representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries related to the GDPR.
Data subject: A natural person whose personal data we process.
Personal data: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data relating to trade union, political, religious or philosophical views and activities; data concerning health, intimate life, or membership of an ethnicity or race; genetic data; biometric data that uniquely identifies a natural person; data relating to criminal and administrative sanctions or prosecutions; and data relating to measures of social assistance.
Processing: Any handling of personal data, regardless of the means and procedures used, for example: querying, comparing, adapting, archiving, retaining, reading, disclosing, obtaining, recording, collecting, deleting, revealing, sorting, organising, storing, altering, disseminating, linking, destroying, and using personal data.
European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
We process personal data – insofar as and to the extent that the European General Data Protection Regulation (GDPR) applies – on the basis of at least one of the following legal bases:
The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and to the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
We process the personal data that is necessary to perform our activities and operations on a long-term basis in a user-friendly, secure, and reliable manner. The personal data processed may fall, in particular, into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also include particularly sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of carrying out our activities and operations, insofar as such processing is permissible.
Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example to fulfil legal obligations or to safeguard overriding interests. We may also ask data subjects for their consent even when consent is not required.
We process personal data for the duration required for the respective purpose. In particular, we anonymise and/or delete personal data depending on statutory retention and limitation periods.
We may disclose personal data to third parties, have personal data processed by third parties, or process personal data jointly with third parties. Such third parties may include, for example, specialised service providers whose services we use.
In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurers, and payment service providers.
We process personal data in order to be able to communicate with individuals as well as with authorities, organisations, and companies. In doing so, we process in particular data that a data subject provides to us when making contact, for example by post or email. We may store such data in an address book or by using comparable tools.
Third parties who provide us with data about other individuals are obliged to ensure the data protection of those data subjects independently. In particular, they must ensure that such data is accurate and may be transmitted.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. With such services, we may also manage the data of data subjects beyond direct communication and process it for other purposes.
In particular, we use:
We process personal data about applicants insofar as it is required to assess suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data arises in particular from the information requested, for example as part of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and print media or on job portals and job platforms.
We also process the personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs, and other application documents as well as online profiles.
We process – insofar as and to the extent that the General Data Protection Regulation (GDPR) applies – personal data about applicants in particular pursuant to Art. 9(2)(b) GDPR.
We take appropriate technical and organisational measures to ensure data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the personal data processed, without, however, being able to guarantee absolute data security.
Access to our website and our other digital presence is secured by transport encryption (SSL / TLS, in particular using Hypertext Transfer Protocol Secure (HTTPS)). Most browsers warn against visiting a website without transport encryption.
Our digital communication is subject – like basically any digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities, and other security authorities. We also cannot rule out that a data subject is specifically monitored.
We process personal data primarily in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it there or have it processed there.
We may export personal data to all countries on Earth and elsewhere in the Universe, provided that the law there ensures adequate data protection in accordance with the decision of the Swiss Federal Council and – insofar as and to the extent that the General Data Protection Regulation (GDPR) applies – also in accordance with the decision of the European Commission.
We may transfer personal data to countries whose laws do not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific data-protection requirements are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we will be happy to provide data subjects with information about any safeguards or provide a copy of any safeguards.
We grant data subjects all rights under applicable law. In particular, data subjects have the following rights:
We may postpone, restrict, or refuse the exercise of data subjects’ rights within the legally permissible scope. We may inform data subjects of any requirements that must be met for the exercise of their data protection rights. For example, we may refuse access in whole or in part by referring to confidentiality obligations, overriding interests, or the protection of other persons. For example, we may also refuse the deletion of personal data, in particular by referring to statutory retention obligations, in whole or in part.
We may, in exceptional cases, provide for costs for exercising rights. We will inform data subjects in advance about any costs.
We are obliged to identify data subjects who request access or assert other rights by taking appropriate measures. Data subjects are obliged to cooperate.
Data subjects have the right to enforce their data protection rights in court or to file a report and/or complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC / EDÖB).
European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are structured federally, particularly in Germany.
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.
Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called persistent cookies. “Session cookies” are automatically deleted when the browser is closed. Persistent cookies have a specific storage period. Cookies make it possible, in particular, to recognise a browser on the next visit to our website and thus, for example, to measure the reach of our website. Persistent cookies may also be used, for example, for online marketing.
Cookies can be disabled, restricted, or deleted at any time in whole or in part in the browser settings. Browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least insofar as and to the extent required under applicable law – express consent to the use of cookies.
For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via 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).
For each access to our website and our other digital presence, we may log at least the following information, provided that such information is determined or transmitted to our digital infrastructure as standard during such access: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, the individual subpage of our website accessed including the amount of data transmitted, the last website accessed in the same browser window (referer/referrer).
We log such information, which may also constitute personal data, in log files. The information is required to provide our digital presence on a long-term basis in a user-friendly and reliable manner. The information is also required to ensure data security – including through third parties or with the assistance of third parties.
We may integrate tracking pixels into our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when accessing our digital presence. Tracking pixels can collect at least the same information as logging in log files.
Notifications and communications may contain web links or tracking pixels that record whether an individual communication was opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner, and on a long-term, secure, and reliable basis, based on the needs and reading habits of recipients.
You must generally consent to the use of your email address and your other contact addresses, unless the use is permissible for other legal reasons. To obtain any double-confirmed consent, we may use the “double opt-in” procedure. In this case, you will receive a notification with instructions for double confirmation. We may log obtained consents, including IP address and timestamp, for evidentiary and security reasons.
You may generally object to receiving notifications and communications, such as newsletters, at any time. By doing so, you can also object to the statistical recording of usage for performance and reach measurement. This does not affect any necessary notifications and communications in connection with our activities and operations.
We send notifications and communications with the help of specialised service providers.
In particular, we use:
We maintain a presence on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use, as well as privacy policies and other provisions of the respective operators of such platforms, also apply in each case. These provisions provide, in particular, information about the rights of data subjects vis-à-vis the respective platform, including, for example, the right of access.
For our Facebook social media presence, including so-called Page Insights, we are – insofar as and to the extent that the General Data Protection Regulation (GDPR) applies – jointly responsible 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 in order to be able to provide our social media presence on Facebook effectively and in a user-friendly manner.
Further information about the nature, scope, and purpose of data processing, information about the rights of data subjects, as well as Facebook’s contact details and those of Facebook’s data protection officer can be found in the Facebook Privacy Policy. We have entered into the so-called “Controller Addendum” with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. The relevant information for so-called Page Insights can be found on the “Information About Page Insights” page, including “Information About Page Insights Data”.
We use services from specialised third parties in order to perform our activities and operations on a long-term basis in a user-friendly, secure, and reliable manner. With such services, we can, among other things, embed functions and content into our website. In the context of such embedding, the services used collect, for technically necessary reasons, at least temporarily the IP addresses of users.
For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised, or pseudonymised form. This may include, for example, performance or usage data in order to be able to provide the respective service.
In particular, we use:
We use services from specialised third parties in order to use the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
In particular, we use:
We use specialised platforms to integrate and connect existing third-party apps and services. Using such “no-code” platforms, we may also automate workflows and operations with third-party apps and services.
We use specialised services for audio and video conferences in order to communicate online. For example, we may hold virtual meetings or conduct online training and webinars. The legal texts of the respective services, such as privacy policies and terms of use, apply in addition for participation in audio and video conferences.
Depending on your circumstances, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or using a virtual background.
In particular, we use:
We use third-party services to enable online collaboration. In addition to this privacy policy, any terms directly displayed by the services used, such as terms of use or privacy policies, may also apply.
In particular, we use:
We use third-party services to embed maps into our website.
We use the option to display targeted advertising with third parties such as social media platforms and search engines for our activities and operations.
With such advertising, we aim in particular to reach people who are already interested in our activities and operations or who may be interested in them (remarketing and targeting). For this purpose, we may transmit relevant information – potentially including personal data – to third parties that enable such advertising. We may also determine whether our advertising is successful, meaning in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may potentially associate your use of our website with your profile there.
In particular, we use:
We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or operate such extensions on our own digital infrastructure.
In particular, we use:
We seek to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party references or check how different parts or versions of our digital presence are used (“A/B testing” method). Based on the results of performance and reach measurement, we may in particular fix errors, strengthen popular content, or make improvements.
For performance and reach measurement, in most cases the IP addresses of individual users are recorded. In this case, IP addresses are generally shortened (“IP masking”) in order to follow the principle of data minimisation through the corresponding pseudonymisation.
Cookies may be used and user profiles created for performance and reach measurement. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are registered may potentially associate the use of our online offering with the user account or user profile with the respective service.
In particular, we use:
We prepared this privacy policy using the data protection generator by Datenschutzpartner . The present privacy policy is an unofficial translation from the original German version.
We may update this privacy policy at any time. We will inform you about updates in an appropriate manner, in particular by publishing the current version of the privacy policy on our website.