We are very pleased that you are interested in our company. Data protection is a top priority for the management of Eckelmann Hotels KG. In general, you can use the Eckelmann Hotels KG website without providing any personal data. However, if a data subject wishes to use specific services offered by our company via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data—such as a data subject’s name, address, email address, or phone number—is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Eckelmann Hotels KG. Through this Privacy Policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this Privacy Policy informs data subjects of their rights.

As the data controller, Eckelmann Hotels KG has implemented numerous technical and organizational measures to ensure the most comprehensive protection possible for the personal data processed through this website. However, Internet-based data transmissions may generally involve security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, any data subject is free to provide personal data to us through alternative means, such as by telephone.

The Eckelmann Hotels KG Privacy Policy is based on the terminology used by European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
In this Privacy Policy, we use the following terms, among others:

a) Personal Data
Personal data refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier, or one or more specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b) Processing
Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution, or any other form of disclosure, the comparison or linking, the restriction, erasure, or destruction.

c) Restriction of Processing
Restriction of processing refers to the marking of stored personal data with the aim of limiting its future processing.

d) Data Subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

e) Profiling
Profiling is any form of automated processing of personal data that involves using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

f) Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures that ensure the personal data is not attributed to an identified or identifiable natural person.

g) Data Controller or Controller
The controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for by Union law or the law of the Member States.

h) Data Processor
A data processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller.

i) Recipient
A recipient is a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, regardless of whether or not that entity is a third party. However, public authorities that may receive personal data in the course of a specific investigative mandate under Union law or the law of the Member States are not considered recipients.

j) Third
A “third party” is a natural or legal person, public authority, agency, or other entity other than the data subject, the controller, the processor, and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

k) Consent
Consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, expressed in the form of a statement or other unambiguous affirmative action, by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

The Eckelmann Hotels KG website uses cookies. Cookies are text files that are placed and stored on a computer system via a web browser.

Numerous websites and servers use cookies. Many cookies contain what is known as a 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 associate the cookie with the specific web browser in which it was stored. This enables the visited websites and servers to distinguish the data subject’s individual browser from other web browsers that contain different cookies. A specific web browser can be recognized and identified via the unique cookie ID.

By using cookies, Eckelmann Hotels KG can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

Cookies allow us to optimize the information and content on our website to better serve our users. As mentioned earlier, cookies enable us to recognize users of our website. The purpose of this recognition is to make it easier for users to navigate our website. For example, a user of a website that uses cookies does not have to re-enter their login credentials every time they visit the site, as this information is handled by the website and the cookie stored on the user’s computer system. Another example is the shopping cart cookie in an online store. The online store uses a cookie to remember the items a customer has placed in the virtual shopping cart.

The data subject can prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via a web browser or other software programs. This is possible in all common web browsers. If the data subject disables the setting of cookies in the web browser they are using, not all features of our website may be fully usable under certain circumstances.

The Eckelmann Hotels KG website collects a range of general data and information each time a data subject or an automated system accesses the website. This general data and information is stored in the server’s 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 (known as the referrer), (4) the subpages on our website accessed via an accessing system, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information used to prevent threats in the event of attacks on our information technology systems.

When using this general data and information, Eckelmann Hotels KG does not draw any conclusions about the data subject. Rather, this information is needed to (1) correctly deliver the content of our website, (2) optimize the content of our website and the advertising on it, (3) ensure the ongoing functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. Eckelmann Hotels KG therefore evaluates this anonymously collected data and information both for statistical purposes and with the aim of enhancing data protection and data security within our company, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

The data subject has the option to register on the data controller’s website by providing personal data. The specific personal data transmitted to the data controller in this process is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the data controller and for its own purposes. The data controller may arrange for the transfer of such data to one or more processors, such as a package delivery service, which will also use the personal data exclusively for internal purposes attributable to the data controller.

When a user registers on the data controller’s website, the IP address assigned by the data subject’s Internet service provider (ISP), as well as the date and time of registration, are also stored. This data is stored because it is the only way to prevent misuse of our services, and, if necessary, this data enables us to investigate criminal offenses that have been committed. In this respect, the storage of this data is necessary to protect the data controller. This data is generally not disclosed to third parties, unless there is a legal obligation to do so or the disclosure serves the purposes of criminal prosecution.

The registration of the data subject, who voluntarily provides personal data, enables the data controller to offer the data subject content or services that, by their very nature, can only be made available to registered users. Registered users are free to modify the personal data provided during registration at any time or to have it completely deleted from the data controller’s database.

The data controller will, upon request, provide any data subject with information at any time regarding which personal data about the data subject has been stored. Furthermore, the data controller will correct or delete personal data at the request or upon notification by the data subject, provided that no statutory retention obligations prevent this. All employees of the data controller are available to the data subject as points of contact in this regard.

On the Eckelmann Hotels KG website, users are given the opportunity to subscribe to our company’s newsletter. The personal data transmitted to the data controller when subscribing to the newsletter is determined by the input form used for this purpose.

Eckelmann Hotels KG regularly informs its customers and business partners about the company’s offers via a newsletter. In general, a data subject can only receive our company’s newsletter if (1) the data subject has a valid email address and (2) the data subject registers to receive the newsletter. For legal reasons, a confirmation email is sent via the double-opt-in procedure to the email address initially provided by a data subject for the newsletter. This confirmation email serves to verify whether the owner of the email address, as the data subject, has authorized receipt of the newsletter.

When you subscribe to the newsletter, we also store the IP address assigned by the Internet service provider (ISP) to 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 to be able to trace any (potential) misuse of a data subject’s email address at a later date and therefore serves to provide legal protection for the data controller.

The personal data collected when subscribing to the newsletter is used exclusively for sending our newsletter. In addition, newsletter subscribers may be notified by email if this is necessary for the operation of the newsletter service or for registration purposes, such as in the event of changes to the newsletter content or technical changes. Personal data collected in connection with the newsletter service is not disclosed to third parties. The data subject may cancel their subscription to our newsletter at any time. Consent to the storage of personal data that the data subject has provided to us for the purpose of sending the newsletter may be revoked at any time. A link for revoking consent is included in every newsletter. Furthermore, you may unsubscribe from the newsletter at any time directly on the data controller’s website or notify the data controller of your wish to unsubscribe by other means.

The Eckelmann Hotels KG newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Using the embedded web beacon, Eckelmann Hotels KG can determine whether and when an email was opened by a data subject and which links contained in the email were clicked by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters is stored and analyzed by the data controller in order to optimize newsletter distribution and to tailor the content of future newsletters even better to the interests of the data subject. This personal data is not disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent provided via the double opt-in procedure. Following revocation, this personal data will be deleted by the data controller. Eckelmann Hotels KG automatically interprets unsubscribing from the newsletter as a revocation of consent.

In accordance with legal requirements, the Eckelmann Hotels KG website contains information that enables users to quickly contact our company electronically and communicate directly with us, including a general electronic mail (email) address. If a data subject contacts the data controller via email or through a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data, voluntarily provided by a data subject to the data controller, is stored for the purpose of processing the request or contacting the data subject. This personal data is not disclosed to third parties.

The data controller processes and stores the data subject’s personal data only for the period necessary to achieve the purpose of storage, or to the extent provided for by the European legislative bodies or another legislative authority in laws or regulations to which the data controller is subject.

If the purpose of storage no longer applies or if a retention period prescribed by the European legislative and regulatory authorities or another competent legislative authority expires, the personal data will be routinely blocked or deleted in accordance with legal requirements.

a) Right to Confirmation
Every data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to exercise this right of confirmation, they may contact any employee of the controller at any time.

b) Right of Access
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain free information at any time from the controller regarding the personal data stored about them and to receive a copy of such information.

Furthermore, the data subject has the right to obtain information about:

• the purposes of the processing;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly recipients in third countries or international organizations;
• where possible, the planned period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period;
• the existence of the right to request rectification or erasure of personal data, restriction of processing, or objection to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling pursuant to Article 22(1) and (4) GDPR and meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing.

If personal data are transferred to a third country or an international organization, the data subject has the right to be informed about the appropriate safeguards relating to such transfer.

c) Right to Rectification
Every data subject has the right to obtain without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

d) Right to Erasure (“Right to be Forgotten”)
Every data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies:

• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent on which the processing is based and there is no other legal ground for processing.
• The data subject objects to the processing and there are no overriding legitimate grounds for the processing.
• The personal data have been processed unlawfully.
• The personal data must be erased for compliance with a legal obligation under Union or Member State law.
• The personal data have been collected in relation to information society services offered pursuant to Article 8(1) GDPR.

If Eckelmann Hotels KG has made personal data public and is obliged to erase it under Article 17 GDPR, it will take reasonable steps, including technical measures, to inform other controllers processing the data that the data subject has requested the erasure of links, copies, or replications of such data.

e) Right to Restriction of Processing
Every data subject has the right to obtain restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject.
• The processing is unlawful and the data subject opposes the erasure of the data.
• The controller no longer needs the personal data, but the data subject requires it for legal claims.
• The data subject has objected to processing and verification of overriding legitimate grounds is pending.

f) Right to Data Portability
Every data subject has the right to receive their personal data in a structured, commonly used, and machine-readable format and to transmit those data to another controller without hindrance, where processing is based on consent or contract and is carried out by automated means.

Where technically feasible, the data subject also has the right to have personal data transmitted directly from one controller to another.

g) Right to Object
Every data subject has the right, on grounds relating to their particular situation, to object at any time to processing of personal data concerning them carried out pursuant to Article 6(1)(e) or (f) GDPR, including profiling based on those provisions.

Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing for such marketing, including profiling related to direct marketing.

h) Automated Individual Decision-Making, Including Profiling
Every data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless permitted under Article 22 GDPR.

In such cases, Eckelmann Hotels KG shall implement suitable measures to safeguard the rights, freedoms, and legitimate interests of the data subject, including the right to obtain human intervention, express their point of view, and contest the decision.

i) Right to Withdraw Consent Under Data Protection Law

Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw their consent to the processing of personal data at any time.

If a data subject wishes to exercise this right to withdraw consent, they may contact the controller at any time.

This website contains links to other websites (so-called external links).

As a provider, Eckelmann Hotels KG is responsible for its own content in accordance with applicable European and national legislation. Such own content must be distinguished from links to content provided by other providers. We have no influence over whether operators of other websites comply with applicable European and national legal requirements. Please refer to the privacy policies provided on the respective websites. Eckelmann Hotels KG accepts no responsibility for third-party content made available through links and does not adopt such content as its own. Sole responsibility for illegal, incorrect, or incomplete content, as well as for damages arising from the use or non-use of such information, lies with the provider of the referenced website.

The controller has integrated components of Facebook on this website. Facebook is a social network.

A social network is an online social meeting place and community that generally enables users to communicate and interact with one another in virtual space. A social network may serve as a platform for exchanging opinions and experiences or enable users to share personal or business-related information. Facebook allows users to create private profiles, upload photos, and connect through friend requests.

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

Each time an individual page of this website that contains a Facebook component (Facebook plug-in) is accessed, the web browser on the data subject’s information technology system is automatically prompted by the 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/

As part of this technical process, Facebook receives information regarding 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 recognizes with every visit to our website which specific subpage is being viewed. This information is collected by the Facebook component and assigned to the data subject’s Facebook account.

If the data subject clicks one of the Facebook buttons integrated on our website, such as the “Like” button, or leaves a comment, Facebook assigns this information to the data subject’s personal Facebook account and stores the corresponding personal data.

Facebook receives information that the data subject has visited our website whenever the data subject is logged into Facebook at the time of access, regardless of whether the Facebook component is clicked. If the data subject does not wish such information to be transmitted to Facebook, they can prevent this by logging out of their Facebook account before accessing our website.

Facebook’s Data Policy provides information about the collection, processing, and use of personal data by Facebook and is available at:

https://www.facebook.com/privacy/policy/

It also explains privacy settings available to protect the data subject’s privacy. Various applications are also available that allow users to prevent data transmission to Facebook.

The controller has integrated the Google Analytics component (with anonymization function) into this website. Google Analytics is a web analytics service. Web analytics involves the collection, gathering, and analysis of data regarding the behavior of website visitors.

A web analytics service collects information including the website from which a user arrived (referrer), which subpages were accessed, how often they were viewed, and how long they were viewed. Web analytics is primarily used to optimize websites and conduct cost-benefit analyses of internet advertising.

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

The controller uses the “_gat._anonymizeIp” extension for web analytics through Google Analytics. By means of this extension, Google shortens and anonymizes the IP address of the data subject’s internet connection when access to our website originates from a member state of the European Union or another contracting state of the European Economic Area.

The purpose of Google Analytics is to analyze visitor traffic on our website. Google uses the data and information collected to evaluate website usage, compile reports on website activity, and provide additional services related to website usage.

Google Analytics places a cookie on the data subject’s information technology system. By setting the cookie, Google is enabled to analyze website usage. Every time a page containing a Google Analytics component is accessed, the browser automatically transmits data to Google for online analysis purposes.

As part of this technical process, Google receives personal data such as the IP address of the data subject, which Google uses to trace visitor origins and clicks and subsequently facilitate commission settlements.

The cookie stores personal information such as access times, location of access, and frequency of website visits. With each visit, this personal data, including the IP address used, is transferred to Google in the United States and stored there. Google may share this data with third parties under certain circumstances.

The data subject may prevent the setting of cookies at any time through browser settings and thereby permanently object to cookie storage. Such settings will also prevent Google from placing cookies on the user’s device.

In addition, cookies already set by Google Analytics may be deleted at any time through the web browser or other software programs.

The data subject may also object to the collection and processing of data generated by Google Analytics and relating to the use of this website. To do so, the user must download and install a browser add-on available at:

https://tools.google.com/dlpage/gaoptout

Further information about Google’s privacy practices can be found at:

https://www.google.com/policies/privacy/

and

http://www.google.com/analytics/terms/

This website uses the Google Maps mapping service via an API. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use Google Maps features, it is necessary to store your IP address. This information is generally transmitted to and stored on a Google server in the USA. The provider of this website has no influence on this data transmission.

The use of Google Maps is in the interest of presenting our online services attractively and making the locations indicated on our website easy to find. This constitutes a legitimate interest pursuant to Article 6(1)(f) GDPR.

More information about Google’s handling of user data can be found in Google’s Privacy Policy:

https://www.google.com/policies/privacy/

The controller has integrated the Google+ button on this website. Google+ is a social network.

Google+ allows users to create private profiles, upload photos, and connect with others through friend requests.

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

Whenever a page containing a Google+ button is accessed, the internet browser automatically downloads the corresponding Google+ button from Google. During this process, Google receives information about which specific page of our website has been visited.

Additional information about Google+ is available at:

https://developers.google.com/

If the data subject is logged into Google+ at the same time, Google can identify which pages of our website are visited and associate them with the user’s Google+ account.

If the user activates a Google+1 recommendation, Google stores this information and may make it publicly available according to the settings accepted by the user. Google may also combine this information with other Google services.

Users can prevent the transmission of personal data to Google by logging out of their Google+ account before visiting our website.

The controller has integrated YouTube components into this website.

YouTube is an internet video portal that allows video publishers to upload video content free of charge and allows users to view, rate, and comment on videos free of charge.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, a subsidiary of Google Inc.

Whenever a page containing a YouTube component is accessed, the browser automatically downloads the corresponding YouTube content. During this process, YouTube and Google receive information regarding the specific page visited by the data subject.

If the data subject is simultaneously logged into YouTube, YouTube can associate the visit with the corresponding YouTube account.

Users can prevent such transmission of information by logging out of their YouTube account before visiting our website.

This website uses technologies provided by LiveRate GmbH, Metzstrasse 12, 81667 Munich, Germany (http://www.liverate.chat), to collect and store data from which usage profiles are created using pseudonyms.

Cookies are used for this purpose. These are small text files stored on the visitor’s device that enable recognition of the user during future visits.

The pseudonymized usage profiles are not merged with personal data of the user unless the user has given separate and explicit consent.

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.

Where the processing of personal data is necessary for the performance of a contract to which the data subject is party, processing is based on Article 6(1)(b) GDPR.

Where processing is necessary to comply with a legal obligation, such as tax obligations, processing is based on Article 6(1)(c) GDPR.

In rare cases, processing may be necessary to protect vital interests of the data subject or another natural person. In such cases, processing is based on Article 6(1)(d) GDPR.

Finally, processing operations may be based on Article 6(1)(f) GDPR where processing is necessary for the purposes of legitimate interests pursued by the company or a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

Where processing is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of our employees and shareholders.

The criterion used to determine the storage period of personal data is the respective statutory retention period. After expiration of that period, the corresponding data are routinely deleted, provided they are no longer required for contract performance or contract initiation.

We inform you that the provision of personal data may be partly required by law (for example, tax regulations) or may result from contractual provisions (for example, information on the contractual partner).

In some cases, it may be necessary for a data subject to provide personal data in order to conclude a contract.

Failure to provide the personal data would result in the inability to conclude the contract with the data subject.

As a responsible company, we do not engage in automated decision-making or profiling.

The use of contact details published as part of our legal notice obligations for the transmission of unsolicited advertising and information materials is hereby expressly prohibited.

The operators of this website expressly reserve the right to take legal action in the event of unsolicited promotional information being sent, such as spam emails.

The controller for purposes of the General Data Protection Regulation (GDPR), other applicable data protection laws in the Member States of the European Union, and other provisions related to data protection is:

Eckelmann Hotels KG

Managing Director:
Dipl.-Kfm. Johannes Eckelmann

Häberlstrasse 9
80337 Munich
Germany

Phone: +49 89 59993907

E-Mail: hotel@hotel-cocoon.de
Website: www.hotel-cocoon.de

Cornelius Kalk

Email: info@consulting-trust.de

Phone: +49 40 808058300

contrust – Gesellschaft für betriebliche Prävention mbH

Alsterredder 8
22395 Hamburg
Germany

Website: www.consulting-trust.de

We reserve the right to amend our data protection practices and this Privacy Policy in order to adapt them to changes in relevant laws and regulations or to better meet your needs.

Any changes to our privacy practices will be published here accordingly.

Munich, May 2018