Data protection statement
The following data protection statement applies to the use of our online services www.guy.travel (hereinafter referred to as “website”). We place great importance on data protection. The collection and processing of your personal data is carried out in compliance with the applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).
1. Data controller
The data controller for the collection, processing and use of your personal data within the meaning of Art. 4 (7) GDPR is Zusammen.reisen UG (limited liability), Wintersteinstrasse 1, D-61440 Oberursel, Tel. (+49) 0151-70057775, email@example.com. If you wish to object to the collection, processing or use of your data by us in accordance with these data protection regulations as a whole or for individual measures, you can address your objection to the data controller. You can save and print this data protection statement at any time.
2. General purposes of processing
We use personal data for the purpose of operating the website and for processing the tours that can be booked via the website and the associated intermediary and other services.
3. What data we process and why
The hosting services utilised by us are intended to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating the website. In doing so, we or our hosting provider Wix.com Ltd. process inventory data, contact data, content data, contract data, usage data, meta data and communication data of clients, interested parties and visitors of this website on the basis of our legitimate interests in an efficient and secure provision of our website pursuant to Art. 6 (1)(f) GDPR in conjunction with Art. 28 GDPR.
3.2 Access data
We collect information about you when you use this website. We automatically collect information about your usage patterns and interaction with us and record data about your computer or mobile device. We collect, store and use data about every access to our website (so-called server log files). Access data includes:
Name and URL of the retrieved file
Date and time of retrieval
Amount of data transferred
HTTP response code (message)
Browser type and browser version
Referer URL (i.e., the previously visited website)
Websites accessed by the user’s system through our website
User’s internet service provider
IP address and
We use this log data without assigning it to you personally or otherwise profiling it for statistical evaluations for the purpose of operating, securing and optimising our website, but also to anonymously record the number of visitors to our website (traffic) and the extent and type of use of our website and services, as well as for accounting purposes to measure the number of clicks received from cooperation partners. This information allows us to analyse traffic, troubleshoot and improve our services. This is also our legitimate interest according to Art. 6 (1)(f) GDPR. We reserve the right to check the log data retrospectively if there is a justified suspicion of unlawful use on the basis of concrete evidence. We store IP addresses in the log files for a limited period of time if this is necessary for security purposes – for example, if we have a concrete suspicion of a criminal offence in connection with the use of our website.
A cookie is a small text file that is sent by the respective servers when you visit a website and is temporarily stored on your hard drive. This file as such contains a so-called session ID with which various requests from your browser can be assigned to a joint session as well as identify a user’s computer. Cookies and similar technologies may be used by us for a variety of purposes, such as:
For security and fraud protection and to detect and prevent cyber-attacks
To provide you with the services you have selected, including the contact and booking forms on our website provided by 123FormBuilder SRL – details can be found on this page: https://www.123formbuilder.com/de/cookie-policy/
To monitor and analyse the performance, operation and effectiveness of our services in conjunction with our hosting partner Wix.com Ltd
To improve your user experience
Information about the number of visits to our website and the use of individual functions of our website
3.4 Data for the fulfilment of our contractual obligations
We process personal data that are required for the fulfilment of our contractual obligations, such as name, address, e-mail address, date of birth, travel services booked, billing and payment data. The collection of this data is necessary for the conclusion of the contract. The deletion of the data takes place after the expiry of the guarantee periods and legal retention periods. The legal basis for the processing of this data is Art. 6 (1)(b) GDPR, as this data is required so that our contractual obligations towards you can be fulfilled.
In order to subscribe to our newsletter, it is necessary to store your e-mail address and – if provided voluntarily – your name. Newsletter subscriptions are logged. After subscribing, you will receive an e-mail at the e-mail address provided asking you to confirm your subscription (“double opt-in”). This is necessary to prevent third parties from subscribing using your e-mail address. You may revoke your consent to receive the newsletter at any time and thereby unsubscribe from the newsletter. Our service provider for the distribution of our newsletters is Brevo. The data protection provisions and general terms and conditions of Brevo apply: https://www.brevo.com/legal/termsofuse/
We store login data for as long as it is required for the purpose of distributing the newsletter. The log of subscription activities and mailing addresses are stored for as long as there is an interest in proving that consent was previously given; as a rule, this is the limitation period for civil claims, i.e., a maximum of three years.
The legal basis for distributing the newsletter is your consent as per Art. 6 (1)(a) in conjunction with Art. 7 GDPR in conjunction with Section 7 (2)(3) of the German Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb – UWG). The legal basis for logging subscription activities is our legitimate interest in proving that the distribution was carried out with your consent.
You may cancel your subscription at any time without incurring any costs other than the transmission fees charged in accordance with basic telephone rates. A notification in written form (e.g., e-mail, fax, letter), sent to the appropriate contact mentioned in Point 1, shall suffice for this purpose. You can also find an unsubscribe link in every newsletter, of course.
3.6 E-mail contact
If you contact us (e.g., via the contact form, WhatsApp or e-mail), your details are processed in order to respond to your enquiry and to address any follow-up questions that may arise.
If data processing is carried out for the purpose of executing pre-contractual measures in response to your enquiry or, if you are already our client, for the purpose of executing a contract, the legal basis for this data processing is Art. 6 (1)(b) GDPR.
We only process other personal data if we have your consent (Art. 6 (1)(a) GDPR) or if we have a legitimate interest in processing your data (Art. 6 (1)(f) GDPR). A legitimate interest is, for example, to respond to your e-mail.
3.7 Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc (“Google”), to collect usage statistics about our website. However, we use Analytics in a simplified form that does not use so-called “cookies” and therefore does not store any text files on your computer. We have also activated IP anonymisation such that your IP address is only stored in abbreviated form. This prevents Google from drawing any conclusions about your person. Google has submitted to the Privacy Shield agreement concluded between the European Union and the USA and has certified its compliance. By doing so, Google commits to adhering to the standards and regulations of European data protection law. For further information, please refer to the following link:
3.8 Reviews via eKomi
3.9 WhatsApp Groups
4. Facebook fan page
We maintain a Facebook page (“fan page”) in order to communicate with users there and to draw their attention to our offers.
To our knowledge, Facebook usually processes user data for market research and advertising purposes. Facebook may create use profiles based on user behaviour as well as on interests deriving therefrom. These use profiles allow Facebook to place ads inside and outside of Facebook that target the user’s perceived interests. For this purpose, cookies are usually stored on the users’ computer(s) in order to make information regarding the users’ interests available to websites other than Facebook. A detailed description of the processing activities carried out by Facebook can be found at the following link: https://www.facebook.com/about/privacy/. In addition, the user has the possibility to set their advertising preferences individually under the links https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com.
To the best of our knowledge, user data is also processed outside the European Union, which entails certain risks for the user (enforcement of user rights may be more difficult outside the European Union). However, Facebook Inc., the U.S. parent company of Facebook Ireland Ltd.is certified under the EU-U.S. Privacy Shield and thereby assures to adhere to European data protection guidelines. For more information on Facebook’s Privacy Shield status, please visit https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
In its decision of 5 June 2018, the ECJ classified operators of a fan page and Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter “Facebook”) joint controllers insofar as the so-called “page insights” are concerned. We are therefore jointly responsible with Facebook for analysing the data provided to us by Facebook in anonymised form on how visitors use our fan page. The basis for the processing of personal data on our fan page is an agreement concluded with Facebook on the joint processing of personal data. We recommend that claims for the disclosure of information be submitted directly to Facebook, as the relevant information can be obtained more quickly and effectively by Facebook as opposed to us.
We also collect and process user data when visitors contact us via the fan page, for example with questions about travel offers. We process the personal data provided to us by the respective user in order to answer their questions. The legal basis for this is Art. 6 (1)(b) GDPR, insofar as answering the question is necessary to initiate or fulfil a contract with the respective user. Outside of a contractual relationship of this nature, we have a legitimate interest in answering the respective questions in accordance with Art. 6 (1)(f) GDPR, whereby an assessment of our interest in processing the data and the individual interest of the user is always carried out on a case-by-case basis.
On our fan page, users can also leave posts or comments on the pin board/wall as well as “like” or “share” these posts or comments. These areas/processes are publicly accessible, which means that all personal data that a user posts there can be viewed by other users. The aforementioned community functions are core functions of an online platform, which is why we have a legitimate interest pursuant to Art. 6 (1)(f) GDPR in making the personal data posted by the user on our wall available to the public. In doing so, our interest in data processing is always weighed against the individual interest of the user in each individual case.
5. Storage limitation period
Unless specifically indicated, personal data will only be stored for as long as is necessary to fulfil the purposes pursued. In some cases, the legislator provides for the retention of personal data, for example in tax or commercial law. In these cases, we will only continue to store the data for these legal purposes but will not process it in any other manner and will delete it after the legal retention period has expired.
6. Your rights as a data subject affected by data processing
Under applicable laws, you have various rights regarding your personal data. If you wish to exercise these rights, please send your request by e-mail or by post, clearly identifying yourself, to the address given in Point 1. Below you will find an overview of your rights.
6.1 Right to confirmation and access
You have the right to receive clear information regarding how your personal data is processed. Specifically:
You have the right to obtain confirmation from us at any time as to whether your personal data is being processed. If this is the case, you have the right to request information from us at no charge regarding the personal data stored about you, along with a copy of this data. Furthermore, you have the right to the following information:
The purposes for processing your data
The categories of personal data processed
The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations
If possible, the intended 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 rectification or erasure of personal data concerning you or to restriction of 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 your personal data has not been obtained through you, all available information regarding the source of the data
The existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and – as a minimum in these cases – meaningful information concerning the logic applied as well as the scope and the intended effects of such processing for you
If personal data are transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
6.2 Right of rectification
You have the right to demand that we rectify and, if necessary, complete any personal data relating to you. Specifically:
You have the right to request that we rectify any inaccurate personal data relating to you in a timely manner. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.
6.3 Right to erasure (“right to be forgotten”)
In a number of cases we are obliged to delete personal data relating to you. Specifically:
Pursuant to Article 17 (1) GDPR, you have the right to request that we delete personal data relating to you without delay, and we are obliged to delete personal data without delay, if one of the following reasons applies:
The personal data are no longer necessary for the purposes for which they were collected or processed in any other way.
The personal data have been processed unlawfully.
The deletion of the personal data is necessary for compliance with a legal obligation under EU or Member State law to which we are subject.
The personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
In the event that we have made the personal data public and we are obliged to erase it pursuant to Art. 17 (1) GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and the cost of implementation, to inform data controllers who process the personal data that you have requested that they erase all links to, or copies or replications of, such personal data.
6.4 Right to restrict processing
In a number of cases, you are entitled to request that we restrict the processing of your personal data. Specifically:
You have the right to demand that we restrict processing if one of the following conditions is met:
The accuracy of the personal data is disputed by you for a period of time which enables us to verify the accuracy of the personal data
The processing is unlawful, and you have declined the erasure of the personal data and have instead requested the restriction of the use of the personal data
We no longer require the personal data for the purposes of processing, but you require the data for the assertion, exercise or defence of legal claims
You have objected to the processing pursuant to Art. 21 (1) GDPR, pending the determination of whether the legitimate reasons on the part of our company outweigh your own
6.5 Right to data portability
You have the right to receive personal data concerning you in machine-readable form, to transmit it or to have it transmitted by us. Specifically:
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transfer this data to another controller without any hindrance on our part, provided that
The processing is carried out by means of automated procedures
When exercising your right to data portability in accordance with paragraph 1, you have the right to have personal data transferred directly from us to another controller where this is technically feasible.
6.6 Right of object
You have the right to object to the lawful processing of your personal data by us on grounds relating to your particular situation and where our interests in the processing are not overriding. Specifically:
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6 (1)(e) or (f) GDPR; this also applies to profiling based on these provisions. We no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the purpose of asserting, exercising or defending legal claims.
If personal data is processed by us for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing.
You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, unless the processing is necessary for the performance of a task carried out in the public interest.
6.7 Automated individual decision-making, including profiling
You have the right not to be subject to decision-making based solely on automated processing, including profiling, which has legal effects concerning you or similarly significantly affects you. Automated decision-making based on the personal data collected is not performed.
6.8 Right to revoke consent under data protection law
You have the right to withdraw consent to the processing of personal data at any time.
6.9 Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you are of the opinion that the processing of personal data concerning you is unlawful.
7. Data security
We make every effort to ensure the security of your data within the framework of the applicable data protection laws and technical possibilities. We transmit your personal data in encrypted form. This applies to your bookings/orders as well as other enquiries. Although we use the SSL (Secure Socket Layer) coding system, we would like to point out that data transmission on the Internet (e.g., when communicating via e-mail) may be subject to security risks. Total protection of the data against access by third parties cannot be guaranteed. In order to secure your data, we implement technical and organisational security measures in accordance with Art. 32 GDPR, which we continually adapt to the latest state of technology. We also do not guarantee that our services will be available at any specific times; disruptions, interruptions or failures cannot be ruled out. The servers we utilise are carefully backed up on a regular basis.
8. Disclosure of data to third parties, no data transfer to non-EU countries
In principle, your personal data is only used within our company. If and to the extent that we involve third parties in the performance of contracts (such as logistics service providers), they will only receive personal data to the extent that the transfer is necessary for the corresponding service. In the event that we outsource certain aspects of data processing (“commissioned processing”), we contractually oblige commissioned processors to use personal data only in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject. A data transfer to entities or persons outside the EU apart from in the cases mentioned in this declaration in Points 4, 5 and 6 does not take place and is not planned.
9. Data Protection Officer
If you still have questions or concerns about data protection, please contact our Data Protection Officer: Martin Richter, Wintersteinstr. 1, D-61440 Oberursel, Tel. (+49) 0151-70057775, firstname.lastname@example.org