Information on data protection

3. Name and address of the data protection officer

The data protection officer of the controller is:

Arne Söhns

In-house lawyer

Barmer Str. 17

58332 Schwelm

Tel.: +49 (0) 2336 – 40 97 106

Fax: +49 (0) 2336 – 40 97 229

Email: datenschutz@lohbeck-privathotels.de

Any data subject may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

4. Cookies

The websites of Privathotels Dr. Lohbeck GmbH & Co. KG use cookies. Cookies are text files that are stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that allows websites and servers to be assigned to the specific Internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the person concerned from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified via the unique cookie ID.

By using cookies, Privathotels Dr. Lohbeck GmbH & Co. KG can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

Cookies enable the information and offers on our website to be optimised for the user. As already mentioned, cookies enable us to recognise users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, users of a website that uses cookies do not have to re-enter their access data each time they visit the website, as this is stored by the website and the cookie stored on the user’s computer system. Another example is the cookie used in an online shop’s shopping basket. The online shop uses a cookie to remember the items that a customer has placed in the virtual shopping basket.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programmes. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, it may not be possible to use all functions of our website to their full extent.

5. Collection of general data and information

The website of Privathotels Dr. Lohbeck GmbH & Co. KG collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to protect against attacks on our information technology systems.

When using this general data and information, Privathotels Dr. Lohbeck GmbH & Co. KG does not draw any conclusions about the data subject. This information is required in order to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Privathotels Dr. Lohbeck GmbH & Co. KG on the one hand statistically and on the other hand with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

Privacy policy on the use and application of web analytics by Google Analytics

We use the Google Analytics (GA) analysis tracking tool from the American company Google LLC on our website. For the European area, Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. Google Analytics collects data about your actions on our website. For example, if you click on a link, this action is stored in a cookie and sent to Google Analytics. The reports we receive from Google Analytics help us to better tailor our website and our service to your needs. Below, we provide more detailed information about the tracking tool and, in particular, what data is stored and how you can prevent this.

Google Analytics is a tracking tool that is used to analyse traffic on our website. In order for Google Analytics to work, a tracking code is embedded in the code of our website. When you visit our website, this code records various actions that you perform on our website. As soon as you leave our website, this data is sent to the Google Analytics servers and stored there.

Google processes the data and we receive reports on your user behaviour. These reports may include the following:

Target group reports: Target group reports help us to get to know our users better and find out more about who is interested in our services.

Advertising reports: Advertising reports make it easier for us to analyse and improve our online advertising.

Acquisition reports: Acquisition reports provide us with helpful information on how we can get more people interested in our service.

Behavioural reports: These reports tell us how you interact with our website. We can track the path you take on our site and which links you click on.

Conversion reports: A conversion is a process in which you perform a desired action based on a marketing message.

For example, when you go from being a mere website visitor to a buyer or newsletter subscriber. These reports tell us more about how our marketing measures are being received by you. This helps us to increase our conversion rate.

Real-time reports: These reports tell us immediately what is happening on our website. For example, we can see how many users are currently reading this text.

Our goal with this website is clear: we want to offer you the best possible service. The statistics and data from Google Analytics help us achieve this goal.

The statistically evaluated data gives us a clear picture of the strengths and weaknesses of our website. On the one hand, we can optimise our site so that it is easier for interested people to find on Google. On the other hand, the data helps us to better understand you as a visitor.

This means we know exactly what we need to improve on our website in order to offer you the best possible service. We also use the data to tailor our advertising and marketing measures more effectively and cost-efficiently. After all, it only makes sense to show our products and services to people who are interested in them.

Google Analytics uses a tracking code to create a random, unique ID that is linked to your browser cookie. This allows Google Analytics to recognise you as a new user. The next time you visit our site, you will be recognised as a ‘returning’ user. All data collected is stored together with this user ID. This is what makes it possible to evaluate pseudonymous user profiles in the first place.

In order to analyse our website with Google Analytics, a property ID must be inserted into the tracking code. The data is then stored in the corresponding property. For each newly created property, Google Analytics 4 is the default property. Alternatively, you can also create the Universal Analytics property. Depending on the property used, data is stored for different lengths of time.

Your interactions on our website are measured using identifiers such as cookies and app instance IDs. Interactions are all types of actions you perform on our website. If you also use other Google systems (such as a Google account), data generated by Google Analytics may be linked to third-party cookies. Google does not share Google Analytics data unless we, as the website operator, authorise it. Exceptions may apply if required by law.

Google creates so-called heat maps. Heat maps show exactly which areas you click on. This gives us information about where you are ‘navigating’ on our site.

Google defines the session duration as the time you spend on our site without leaving the site. If you have been inactive for 20 minutes, the session ends automatically.

Bounce rate: A bounce occurs when you view only one page on our website and then leave our website.

Account creation: When you create an account or place an order on our website, Google Analytics collects this data.

The IP address is only displayed in abbreviated form so that no unique assignment is possible.

The IP address can be used to determine the country and your approximate location. This process is also known as IP location determination. Technical information includes your browser type, your Internet service provider or your screen resolution.

Source: Google Analytics and we are of course also interested in which website or advertisement brought you to our site.

Other data includes contact details, any reviews, media playback (e.g. if you play a video via our site), sharing content via social media or adding it to your favourites. This list is not exhaustive and is only intended to provide a general overview of the data storage by Google Analytics.

Google has servers all over the world. Most servers are located in America, which means that your data is usually stored on American servers. You can find out exactly where Google’s data centres are located here: https://www.google.com/about/datacenters/locations/?hl=de

Your data is distributed across various physical data carriers. This has the advantage that the data can be retrieved more quickly and is better protected against manipulation. Every Google data centre has appropriate emergency programmes for your data. If, for example, Google’s hardware fails or natural disasters cripple servers, the risk of service interruption at Google remains low.

The retention period for the data depends on the properties used. When using the newer Google Analytics 4 properties, the retention period for your user data is set to 14 months. For other so-called event data, we have the option of choosing a retention period of 2 months or 14 months.

For Universal Analytics properties, Google Analytics has a standard retention period of 26 months for your user data. After that, your user data is deleted. However, we have the option of choosing the retention period for user data ourselves. There are five options available to us.

There is also the option of only deleting data if you do not visit our website within the period we have selected. In this case, the retention period is reset each time you visit our website within the specified period.

Once the specified period has expired, the data will be deleted once a month. This retention period applies to your data linked to cookies, user recognition and advertising IDs (e.g. cookies from the DoubleClick domain). Reporting results are based on aggregated data and are stored independently of user data. Aggregated data is a combination of individual data into a larger unit.

Under European Union data protection law, you have the right to obtain information about your data, to update it, to delete it or to restrict its use. You can prevent Google Analytics from using your data by using the browser add-on to disable Google Analytics JavaScript (ga.js, analytics.js, dc.js). You can download and install the browser add-on at https://tools.google.com/dlpage/gaoptout?hl=de. Please note that this add-on only deactivates data collection by Google Analytics.

If you wish to disable, delete or manage cookies in general, you will find the relevant links to the instructions for the most popular browsers in the ‘Cookies’ section.

The use of Google Analytics requires your consent, which we have obtained via our cookie pop-up. According to Art. 6 para. 1 lit. a GDPR (consent), this consent constitutes the legal basis for the processing of personal data, as may occur during collection by web analytics tools.

In addition to your consent, we have a legitimate interest in analysing the behaviour of website visitors in order to improve our offer both technically and economically. With the help of Google Analytics, we can detect errors on the website, identify attacks and improve economic efficiency. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interest). However, we only use Google Analytics if you have given your consent.

Google also processes your data in the USA. We would like to point out that, in the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This may entail various risks for the legality and security of data processing.

As the basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular in the USA) or for data transfers to such countries, Google uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR). Standard contractual clauses (SCC) are model templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through these clauses, Google undertakes to comply with European data protection standards when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here:

https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

The Google Ads Data Processing Terms, which refer to the standard contractual clauses, can be found at https://business.safety.google/intl/de/adsprocessorterms/

If you would like to learn more about the tracking service, we recommend these two links:

https://marketingplatform.google.com/about/analytics/terms/de/ and https://support.google.com/analytics/answer/6004245?hl=de

6. Registration on our website

The data subject has the option of registering on the website of the controller by providing personal data. The personal data transmitted to the controller is determined by the input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be passed on to one or more processors, for example a parcel service provider, who will also use the personal data exclusively for internal purposes attributable to the controller.

By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) of the data subject, the date and time of registration are also stored. This data is stored for the purpose of preventing misuse of our services and, if necessary, enabling the investigation of criminal offences. In this respect, the storage of this data is necessary for the protection of the controller. This data will not be passed on to third parties unless there is a legal obligation to do so or the disclosure serves the purpose of criminal prosecution.

The registration of the data subject by voluntarily providing personal data serves the purpose of the controller to offer the data subject content or services that, due to their nature, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the data controller’s database.

The controller shall provide any data subject with information about the personal data stored about them at any time upon request. Furthermore, the controller shall correct or delete personal data at the request or on the instruction of the data subject, unless there are legal obligations to retain such data. A data protection officer named in this privacy policy and all employees of the controller are available to the data subject as contact persons in this regard.

7. Subscription to our newsletter

If you purchase goods or services from us and provide your email address, we may use it to send you a newsletter. In such a case, the newsletter will only be used to send direct advertising for our own similar goods or services. The legal basis for sending the newsletter is Art. 7 para. 3 UWG.

To prevent misuse or incorrect email details, we use the double opt-in procedure. This means that we will send you an email to the email address you provided, asking you to confirm that the email address is correct. If you do not confirm your details within [24 hours], your information will be blocked and automatically deleted after one month. In addition, we store your IP addresses and the times of registration and confirmation.

The user’s email address is collected for the purpose of delivering the newsletter. The collection of other personal data during the confirmation process in accordance with paragraph 2 serves to prevent misuse of the services or the email address used.

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user’s email address will therefore be stored for as long as you do not revoke your consent to receive the newsletter.

 

You can unsubscribe from our emails at any time by clicking on the ‘Unsubscribe newsletter’ field in our newsletter footer or by sending us a text message (email, letter or fax) to the contact details provided in the legal notice, stating that you no longer wish to receive our promotional emails.

On the website of Privathotels Dr. Lohbeck GmbH & Co. KG, users are given the opportunity to subscribe to our company’s newsletter. The personal data transmitted to the controller when ordering the newsletter is determined by the input mask used for this purpose.

Privathotels Dr. Lohbeck GmbH & Co. KG informs its customers and business partners at regular intervals about offers from the company by means of a newsletter. The newsletter of our company can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject has registered for the newsletter. For legal reasons, a confirmation email is sent to the email address entered by a data subject for the first time for the newsletter dispatch using the double opt-in procedure. This confirmation email serves to verify that the owner of the email address is the data subject who authorised the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace any (possible) misuse of the email address of a data subject at a later date and therefore serves to provide legal protection for the controller.

The personal data collected when registering for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by email if this is necessary for the operation of the newsletter service or for registration in this regard, as may be the case in the event of changes to the newsletter offer or changes to the technical conditions. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data that the data subject has given us for the purpose of sending the newsletter can be revoked at any time. For the purpose of revoking consent, a corresponding link is provided in every newsletter. Furthermore, it is possible to unsubscribe from the newsletter at any time directly on the website of the controller responsible for processing or to inform the controller responsible for processing in another manner.

Email marketing | Existing customer advertising

We reserve the right to process the email address you provided during the booking process in accordance with the statutory provisions in order to send you the following content by email during or after the contract processing, unless you have already objected to this processing of your email address:

further interesting offers from our portfolio,
events organised by our company and third parties,
technical information,
an overview of possible leisure activities,
information on how to reach us by public transport,
special or limited-time offers,
pre-stay/upselling emails,
post-stay: feedback link,
invitations to events.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR.

We carry out the aforementioned processing for customer care and to improve our services. We will delete your data when you unsubscribe from the newsletter, but no later than two years after the end of the contract.

The provision of your data is necessary for the conclusion of the contract. However, if you do not provide the data, we will not be able to send you the newsletter.

We would like to point out that you can object to receiving direct advertising at any time without incurring any costs other than the transmission costs according to the basic tariffs.

You have a general right to object without giving reasons (Art. 21 (2) GDPR). To do so, click on the unsubscribe link in the newsletter or send your objection to the contact details provided in the ‘Responsible provider’ section.

8. Newsletter tracking

The newsletters of Privathotels Dr. Lohbeck GmbH & Co. KG contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in emails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Using the embedded tracking pixel, Privathotels Dr. Lohbeck GmbH & Co. KG can recognise whether and when an email has been opened by a data subject and which links in the email have been accessed by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters is stored and evaluated by the controller in order to optimise the newsletter dispatch and to tailor the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled to revoke their separate declaration of consent given via the double opt-in procedure at any time. Upon revocation, this personal data will be deleted by the controller. Privathotels Dr. Lohbeck GmbH & Co. KG automatically interprets unsubscribing from the newsletter as revocation.

9. Contact option via the website

Due to legal requirements, the website of Privathotels Dr. Lohbeck GmbH & Co. KG contains information that enables you to contact our company quickly and communicate directly with us, including a general address for electronic mail (e-mail address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject will be stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller will be stored for the purpose of processing or contacting the data subject. This personal data will not be passed on to third parties.

10. Comment function on the blog on the website

Privathotels Dr. Lohbeck GmbH & Co. KG offers users the opportunity to leave individual comments on individual blog posts on a blog located on the website of the controller.

A blog is a portal maintained on a website, usually publicly accessible, where one or more persons, known as bloggers or web bloggers, can post articles or write down their thoughts in so-called blog posts. The blog posts can usually be commented on by third parties.

If a data subject leaves a comment on the blog published on this website, the comments left by the data subject will be stored and published along with information about the time the comment was made and the user name (pseudonym) chosen by the data subject. Furthermore, the IP address assigned by the Internet service provider (ISP) of the data subject is also logged. This IP address is stored for security reasons and in the event that the data subject violates the rights of third parties or posts illegal content through a comment. The storage of this personal data is therefore in the legitimate interest of the controller, so that the latter can exonerate itself in the event of a legal violation. This personal data will not be passed on to third parties unless such disclosure is required by law or serves to defend the legal interests of the controller.

11. Routine deletion and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or if this has been provided for by the European directive and regulation issuer or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies or if a storage period prescribed by the European Directive and Regulation or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

12. Rights of the data subject

a) Right to confirmation Every data subject has the right granted by European Directive and Regulation to obtain confirmation from the controller as to whether personal data concerning them are being processed. If a data subject wishes to exercise this right to confirmation, they may contact our data protection officer or another employee of the controller at any time.
b) Right to information Every person affected by the processing of personal data has the right granted by European directives and regulations to obtain, at any time and free of charge, information from the controller about the personal data stored about them and a copy of this information. Furthermore, the European Directive and Regulation has granted the data subject the right to obtain the following information: Furthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, they may contact our data protection officer or another employee of the controller at any time.
the purposes of the processing
the categories of personal data that are processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored or, if this is not possible, the criteria for determining this period
the existence of a right to rectify or erase personal data concerning them or to restrict processing by the controller or a right to object to such processing
the existence of a right to lodge a complaint with a supervisory authority
if the personal data are not collected from the data subject: All available information on the origin of the data
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved and the significance and the envisaged consequences of such processing for the data subject
c) Right to rectification Every data subject whose personal data has been processed has the right granted by European directives and regulations to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the purposes of the processing. If a data subject wishes to exercise this right to rectification, they may contact our data protection officer or another employee of the controller at any time.
d) Right to erasure (right to be forgotten) Every person affected by the processing of personal data has the right granted by European directives and regulations to request that the controller delete personal data concerning them without delay if one of the following reasons applies and provided that the processing is not necessary:If one of the above reasons applies and a data subject wishes to have personal data stored by Privathotels Dr. Lohbeck GmbH & Co. KG deleted, they may contact our data protection officer or another employee of the controller at any time. The data protection officer of Privathotels Dr. Lohbeck GmbH & Co. KG or another employee will ensure that the request for erasure is complied with immediately.If the personal data has been made public by Privathotels Dr. Lohbeck GmbH & Co. KG and our company is obliged to delete the personal data as the controller in accordance with Art. 17 (1) GDPR, Privathotels Dr. Lohbeck GmbH & Co. KG shall take appropriate measures, taking into account the available technology and implementation costs, including technical measures, to inform other controllers processing the personal data of the erasure of the personal data, including any disclosure of the personal data to third parties, unless processing is required by law. The data protection officer of Privathotels Dr. Lohbeck GmbH & Co. KG or another employee will take the necessary steps in individual cases.
The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
The data subject withdraws their consent on which the processing was based in accordance with Art. 6 (1) letter a GDPR or Art. 9 (2) letter a GDPR, and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data has been processed unlawfully.
The erasure of the personal data is necessary for compliance with a legal obligation to which the controller is subject under Union law or the law of the Member States.
The personal data has been collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.
e) Right to restriction of processing Any person affected by the processing of personal data has the right granted by European directives and regulations to request that the controller restrict processing if one of the following conditions is met:If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Privathotels Dr. Lohbeck GmbH & Co. KG, they may contact our data protection officer or another employee of the controller at any time. The data protection officer of Privathotels Dr. Lohbeck GmbH & Co. KG or another employee will arrange for the processing to be restricted.
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, the data subject refuses to delete the personal data and instead requests the restriction of the use of the personal data.
The controller no longer needs the personal data for the purposes of processing, but the data subject needs it to assert, exercise or defend legal claims.
The data subject has objected to the processing pursuant to Art. 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.
f) Right to data portability Any person affected by the processing of personal data has the right, granted by the European Directive and Regulation, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6 para. 1 letter a of the GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.Furthermore, when exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.To exercise the right to data portability, the data subject may contact the data protection officer appointed by Privathotels Dr. Lohbeck GmbH & Co. KG or another employee at any time.
g) Right to object Any person affected by the processing of personal data has the right, granted by the European Directive and Regulation, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.Privathotels Dr. Lohbeck GmbH & Co. KG will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.If Privathotels Dr. Lohbeck GmbH & Co. KG processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing purposes. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Privathotels Dr. Lohbeck GmbH & Co. KG processing their data for direct marketing purposes, Privathotels Dr. Lohbeck GmbH & Co. KG will no longer process the personal data for these purposes.In addition, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them by Privathotels Dr. Lohbeck GmbH & Co. KG for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR. unless such processing is necessary for the performance of a task carried out in the public interest. To exercise the right to object, the data subject may contact the data protection officer of Privathotels Dr. Lohbeck GmbH & Co. KG or another employee directly. The data subject is also free to exercise their right to object in relation to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
h) Automated individual decision-making, including profiling Every data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and that law provides for appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the data subject’s explicit consent.If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Privathotels Dr. Lohbeck GmbH & Co. KG shall take appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.If the data subject wishes to exercise rights relating to automated decisions, they may contact our data protection officer or another employee of the controller responsible for processing at any time.
i) Right to withdraw consent to data protection Each person affected by the processing of personal data has the right granted by European directives and regulations to withdraw consent to the processing of personal data at any time.If the data subject wishes to exercise their right to withdraw consent, they can contact our data protection officer or another employee of the controller responsible for processing at any time.
13. Data protection in applications and in the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits relevant application documents to the controller by electronic means, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, unless other legitimate interests of the controller prevent deletion. Other legitimate interests in this sense include, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

14. Data protection provisions on the use and application of Facebook

The controller has integrated components of the Facebook company into this website. Facebook is a social network.

A social network is a social meeting place operated on the Internet, an online community that generally enables users to communicate with each other and interact in a virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enables the Internet community to provide personal or company-related information. Facebook allows users of the social network to create private profiles, upload photos and network via friend requests, among other things.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the USA or Canada, the controller responsible for the processing of personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website, which is operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=de_DE. As part of this technical process, Facebook is informed of which specific subpage of our website is visited by the data subject.

If the data subject is logged into Facebook at the same time, Facebook recognises which specific subpage of our website the data subject is visiting each time the data subject accesses our website and for the entire duration of the data subject’s visit to our website. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the person clicks on one of the Facebook buttons integrated into our website, such as the ‘Like’ button, or if they leave a comment, Facebook will assign this information to the person’s personal Facebook account and store this personal data.

Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is logged into Facebook at the same time as visiting our website; this occurs regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want this information to be transferred to Facebook, they can prevent this by logging out of their Facebook account before visiting our website.

The data policy published by Facebook, which can be found at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains the settings options Facebook offers to protect the privacy of the person concerned. In addition, various applications are available that allow data transmission to Facebook to be suppressed. Such applications can be used by the person concerned to suppress data transmission to Facebook.

15. Data protection provisions for the use and application of Google Analytics (with anonymisation function)

The controller has integrated the Google Analytics component (with anonymisation function) into this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites. A web analytics service collects, among other things, data about which website a data subject came from (so-called referrers), which subpages of the website were accessed or how often and for how long a subpage was viewed. Web analytics is mainly used to optimise a website and to analyse the cost-benefit ratio of internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the addition ‘_gat._anonymizeIp’ for web analysis via Google Analytics. This addition shortens and anonymises the IP address of the internet connection of the person concerned by Google if access to our website is made from a member state of the European Union or from another contracting state of the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse visitor traffic on our website. Google uses the data and information obtained to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By placing the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website operated by the controller and on which a Google Analytics component has been integrated is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

The cookie stores personal information, such as the access time, the location from which access originated and the frequency of visits to our website by the data subject. Each time you visit our website, this personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical process to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programmes.

Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information relating to visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the information technology system of the data subject is deleted, formatted or reinstalled at a later point in time, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of influence, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable data protection provisions can be found at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

16. Data protection provisions for the use and application of Google Remarketing

The controller has integrated Google Remarketing services into this website. Google Remarketing is a function of Google AdWords that enables a company to display advertisements to Internet users who have previously visited the company’s website. The integration of Google Remarketing therefore allows a company to create user-specific advertising and thus display advertisements that are relevant to the interests of the Internet user.

The operator of Google Remarketing services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google Remarketing is to display interest-based advertising. Google Remarketing enables us to display advertisements via the Google advertising network or on other websites that are tailored to the individual needs and interests of Internet users.

Google Remarketing places a cookie on the information technology system of the data subject. Cookies have been explained above. The cookie enables Google to recognise visitors to our website when they subsequently visit websites that are also members of the Google advertising network. Each time a website is accessed on which the Google Remarketing service has been integrated, the Internet browser of the data subject is automatically identified by Google. As part of this technical process, Google obtains knowledge of personal data, such as the IP address or the surfing behaviour of the user, which Google uses, among other things, to display interest-based advertising.

The cookie stores personal information, such as the websites visited by the data subject. Each time you visit our website, personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical process to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programmes.

Furthermore, the data subject has the option of objecting to interest-based advertising by Google. To do this, the data subject must access the link www.google.de/settings/ads from each of the Internet browsers they use and make the desired settings there.

Further information and Google’s applicable data protection provisions can be found at https://www.google.de/intl/de/policies/privacy/.

17. Data protection provisions on the use and application of Google

The controller has integrated the Google+ button as a component on this website. Google+ is a so-called social network. A social network is an Internet-based social meeting place, an online community that generally allows users to communicate with each other and interact in a virtual space. A social network can serve as a platform for exchanging opinions and experiences or enable the Internet community to provide personal or company-related information. Google+ allows users of the social network to create private profiles, upload photos and connect with each other via friend requests, among other things.

The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Each time one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google+ button to download a representation of the corresponding Google+ button from Google. As part of this technical process, Google obtains knowledge of which specific subpage of our website is visited by the data subject. More detailed information about Google+ is available at https://developers.google.com/+.

If the person is logged into Google+ at the same time, Google recognises which specific subpage of our website the person is visiting each time they visit our website and for the entire duration of their visit to our website. This information is collected by the Google+ button and assigned by Google to the person’s Google+ account.

If the data subject clicks on one of the Google+ buttons integrated into our website and thereby submits a Google+1 recommendation, Google will assign this information to the personal Google+ user account of the data subject and store this personal data. Google stores the Google+1 recommendation of the data subject and makes it publicly available in accordance with the terms and conditions accepted by the data subject in this regard. A Google+1 recommendation made by the data subject on this website is subsequently stored and processed together with other personal data, such as the name of the Google+1 account used by the data subject and the photo stored in it, in other Google services, for example in the search engine results of the Google search engine, the Google account of the data subject or in other places, such as on websites or in connection with advertisements. Furthermore, Google is able to link the visit to this website with other personal data stored by Google. Google also records this personal information for the purpose of improving or optimising the various Google services.

Google always receives information that the data subject has visited our website via the Google+ button if the data subject is logged into Google+ at the time of accessing our website; this occurs regardless of whether the data subject clicks on the Google+ button or not.

If the data subject does not want personal data to be transferred to Google, they can prevent this by logging out of their Google+ account before visiting our website.

Further information and Google’s applicable data protection provisions can be found at https://www.google.de/intl/de/policies/privacy/.

Further information from Google on the Google+1 button can be found at https://developers.google.com/+/web/buttons-policy.

18. Data protection provisions for the use and application of Google Maps

We use Google Maps on our website as a route planner and to display map sections. The terms of use for Google Maps can be found here.

19. Data protection provisions for the use and application of Google AdWords

The controller has integrated Google AdWords into this website. Google AdWords is an internet advertising service that allows advertisers to place ads in Google’s search engine results and in the Google advertising network. Google AdWords allows an advertiser to specify certain keywords in advance, which are then used to display an ad in Google’s search engine results only when the user enters a keyword-relevant search query in the search engine. In the Google advertising network, the ads are distributed to relevant websites using an automatic algorithm and in accordance with the previously specified keywords.

The operating company of Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to promote our website by displaying interest-based advertising on the websites of third-party companies and in the search results of the Google search engine, and to display third-party advertising on our website.

If a data subject accesses our website via a Google advertisement, Google places a so-called conversion cookie on the data subject’s information technology system. Cookies have already been explained above. A conversion cookie expires after thirty days and is not used to identify the data subject. The conversion cookie is used to track whether certain subpages, such as the shopping cart of an online shop system, have been accessed on our website, provided that the cookie has not yet expired. The conversion cookie enables both us and Google to determine whether a data subject who has reached our website via an AdWords advertisement has generated a sale, i.e. whether they have completed or cancelled a purchase.

The data and information collected through the use of the conversion cookie is used by Google to compile visit statistics for our website. We in turn use these visit statistics to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimise our AdWords ads for the future. Neither our company nor other Google AdWords advertising customers receive information from Google that could be used to identify the data subject.

The conversion cookie stores personal information, such as the websites visited by the data subject. Each time you visit our website, personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected using technical means to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by adjusting the settings of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a conversion cookie on the information technology system of the data subject. In addition, a cookie already set by Google AdWords can be deleted at any time via the Internet browser or other software programmes.

Furthermore, the data subject has the option of objecting to interest-based advertising by Google. To do this, the data subject must access the link www.google.de/settings/ads from each of the Internet browsers they use and make the desired settings there.

Further information and Google’s applicable data protection provisions can be found at https://www.google.de/intl/de/policies/privacy/.

20. Data protection provisions for the use and application of Instagram

The controller has integrated components of the Instagram service into this website. Instagram is a service that qualifies as an audiovisual platform and allows users to share photos and videos and also to redistribute such data on other social networks.

The operating company of Instagram’s services is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, USA.

Each time one of the individual pages of this website operated by the controller and on which an Instagram component (Insta button) has been integrated is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Instagram component to download a representation of the corresponding component of Instagram. As part of this technical process, Instagram becomes aware of which specific subpage of our website is being visited by the data subject.

If the data subject is logged into Instagram at the same time, Instagram recognises which specific subpage the data subject is visiting each time the data subject accesses our website and for the entire duration of the data subject’s stay on our website. This information is collected by the Instagram component and assigned by Instagram to the respective Instagram account of the person concerned. If the person concerned clicks on one of the Instagram buttons integrated on our website, the data and information transmitted will be assigned to the personal Instagram user account of the person concerned and stored and processed by Instagram.

Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is logged into Instagram at the same time as visiting our website; this occurs regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want this information to be transmitted to Instagram, they can prevent this by logging out of their Instagram account before visiting our website.

Further information and the applicable data protection provisions of Instagram can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

21. Data protection provisions for the use of Twitter

The controller has integrated components from Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and distribute so-called tweets, i.e. short messages limited to 140 characters. These short messages are accessible to everyone, including persons not registered with Twitter. However, the tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Twitter also allows a broad audience to be addressed via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Each time one of the individual pages of this website, which is operated by the controller and on which a Twitter component (Twitter button) has been integrated, is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information about Twitter buttons is available at https://about.twitter.com/de/resources/buttons. As part of this technical process, Twitter is informed about which specific subpage of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to disseminate the content of this website, to make this website known in the digital world and to increase our visitor numbers.

If the data subject is logged into Twitter at the same time, Twitter recognises which specific subpage of our website the data subject is visiting each time they access our website and for the entire duration of their visit to our website. This information is collected by the Twitter component and assigned by Twitter to the data subject’s Twitter account. If the data subject clicks on one of the Twitter buttons integrated into our website, the data and information transmitted will be assigned to the personal Twitter user account of the data subject and stored and processed by Twitter.

Twitter always receives information via the Twitter component that the data subject has visited our website if the data subject is logged into Twitter at the same time as visiting our website; This happens regardless of whether the person clicks on the Twitter component or not. If the person doesn’t want this info to be sent to Twitter, they can stop it by logging out of their Twitter account before visiting our website.

The applicable data protection provisions of Twitter are available at https://twitter.com/privacy?lang=de.

22. Data protection provisions for the use of YouTube

The controller has integrated components from YouTube on this website. YouTube is an Internet video portal that allows video publishers to post video clips free of charge and other users to view, rate and comment on them free of charge. YouTube allows the publication of all types of videos, which is why complete films and television programmes, as well as music videos, trailers or videos created by users themselves, can be accessed via the Internet portal.

YouTube is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Each time one of the individual pages of this website, which is operated by the controller and on which a YouTube component (YouTube video) has been integrated, is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information about YouTube can be found at https://www.youtube.com/yt/about/de/. As part of this technical process, YouTube and Google become aware of which specific subpage of our website is visited by the data subject.

If the data subject is logged in to YouTube at the same time, YouTube recognises which specific subpage of our website the data subject is visiting when a subpage containing a YouTube video is accessed.

This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject. YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is logged into YouTube at the time of accessing our website; this occurs regardless of whether the data subject clicks on a YouTube video or not.

If the data subject does not want this information to be transferred to YouTube and Google, they can prevent this by logging out of their YouTube account before visiting our website.

The privacy policy published by YouTube, which can be found at https://www.google.de/intl/de/policies/privacy/, provides information about the collection, processing and use of personal data by YouTube and Google.

23. Legal basis for processing

Art. 6 I lit. a GDPR serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance details or other vital information had to be passed on to a doctor, hospital or other third parties. In this case, the processing would be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the above legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2 of the GDPR).

24. Legitimate interests in processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of all our employees and our shareholders.

25. Duration for which the personal data will be stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data will be routinely deleted, provided that it is no longer necessary for the fulfilment of the contract or for the initiation of a contract.

26. Legal or contractual requirements for the provision of personal data; Necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We hereby inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we will then have to process. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what consequences the non-provision of personal data would have.

27. Existence of automated decision-making

As a responsible company, we refrain from automatic decision-making or profiling.

28. Information on joint responsibility pursuant to Article 26(2) sentence 2 of the General Data Protection Regulation (GDPR)

What is the reason for joint responsibility?

Privathotels Dr. Lohbeck GmbH CO. KG, Barmer Straße 17, 58332 Schwelm and Hotel Oversum GmbH -Am Kurpark 6 – 59955 Winterberg (hereinafter also referred to as the parties) work together to send information media. This also applies to the processing of your personal data. This data is processed in various stages of the process. Within the process stages described below, the parties are jointly responsible for the protection of your personal data (Art. 26 GDPR). The parties have concluded a corresponding agreement to this effect.

For which process stages is there joint responsibility?

The legal basis for the processing of your personal data under joint responsibility is the consent you have given. Processing takes place in the following process stages: Sending information in digital and print form.

What have the parties agreed? Within the scope of their joint responsibility for data protection, both parties have agreed which of them will fulfil which obligations under the GDPR. This applies in particular to the rights of data subjects (Articles 15 et seq. GDPR) and the fulfilment of the information obligations under Articles 13 and 14 GDPR. The parties shall inform each other immediately of any legal positions asserted by data subjects. They shall provide each other with all information necessary to respond to requests for information.

What does this mean for data subjects?

Data protection rights can be asserted against both parties. Data subjects shall, as a matter of principle, receive the information from the body to which the rights have been asserted. Both parties shall make the information required under Articles 13 and 14 GDPR available to the data subjects free of charge in a precise, transparent, understandable and easily accessible form in clear and simple language. In doing so, each party shall provide the other party with all the necessary information from its sphere of activity. To exercise their rights to lodge a complaint, data subjects may contact the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (LDI-NRW), Postfach 20 04 44, 40102 Düsseldorf, Germany, on behalf of both parties.

Where can I find further information? Further information on data protection:

https://www.oversum-vitalresort.de/de/datenschutz

https://www1.d10145.imv.de/gruppenseite/datenschutz

This privacy policy was created by the privacy policy generator of the Karlsruhe external data protection officer in cooperation with RC GmbH, which recycles used notebooks, and the file sharing lawyers at WBS-LAW.