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Privacy Policy
This Privacy Policy provides information on the processing of personal data in connection with our activities and operations, including our website under the domain name berguen-filisur.graubuenden.ch. We inform you in particular about which personal data we process, for what purpose, in what manner, and where. We also inform you about the rights of persons whose data we process.
We have drafted this Privacy Policy in the German language. In the event of publication in another language, the German-language Privacy Policy shall prevail.
For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.
We are subject to Swiss law as well as any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
The European Commission recognised, by decision of 26 July 2000, that Swiss data protection law ensures an adequate level of data protection. By report of 15 January 2024, the European Commission confirmed this adequacy decision.
Table of Contents
- 1. Contact Details
- 2. Definitions and Legal Bases
- 3. Nature, Scope and Purpose of the Processing of Personal Data
- 4. Disclosure of Personal Data
- 5. Communication
- 6. Job Applications
- 7. Data Security
- 8. Personal Data Abroad
- 9. Rights of Data Subjects
- 10. Use of the Website
- 11. Notifications and Communications
- 12. Social Media
- 13. Third-Party Services
- 14. Success and Reach Measurement
- 15. Video Surveillance
- 16. Final Notes on the Privacy Policy
1. Contact Details
The controller within the meaning of data protection law is:
Bergün Filisur Tourismus AG
Veja Alvra 99
7482 Bergün
In individual cases, third parties may be responsible for the processing of personal data, or joint responsibility with third parties may exist. We are happy to provide data subjects with information about the respective responsibility upon request.
1.1 Data Protection Officer or Data Protection Adviser
We have appointed the following data protection officer or data protection adviser as a point of contact for data subjects and authorities for enquiries relating to data protection:
Niculin Josty
Bergün Filisur Tourismus AG
Veja Alvra 99
7482 Bergün
1.2 Data Protection Representative in the European Economic Area (EEA)
We have appointed the following data protection representative pursuant to Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The data protection representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries relating to the GDPR.
2. Definitions and Legal Bases
2.1 Definitions
Data subject: Natural person about whom we process personal data.
Personal data: All information relating to an identified or identifiable natural person.
Sensitive personal data: Data on trade union, political, religious or philosophical views and activities, data on health, the private sphere or membership of an ethnic group or race, genetic data, biometric data that uniquely identify a natural person, data on criminal and administrative sanctions or proceedings, and data on social welfare measures.
Processing: Any handling of personal data, regardless of the means and procedures applied, for example querying, matching, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, revealing, organising, structuring, saving, modifying, disseminating, linking, destroying and using personal data.
European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.
2.2 Legal Bases
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (FADP) and the Ordinance on Data Protection (ODP).
Where and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process personal data on the basis of at least one of the following legal bases:
- Art. 6(1)(b) GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6(1)(f) GDPR for the necessary processing of personal data in order to protect legitimate interests – including the legitimate interests of third parties – unless the fundamental freedoms and fundamental rights and interests of the data subject prevail. Such interests include in particular the permanent, user-friendly, secure and reliable conduct of our activities and operations, ensuring information security, protection against misuse, enforcement of our own legal claims and compliance with Swiss law.
- Art. 6(1)(c) GDPR for the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
- Art. 6(1)(e) GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6(1)(a) GDPR for the processing of personal data with the consent of the data subject.
- Art. 6(1)(d) GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
- Art. 9(2) et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. Nature, Scope and Purpose of the Processing of Personal Data
We process the personal data that is necessary to conduct our activities and operations in a permanent, user-friendly, secure and reliable manner. The personal data processed may fall in particular into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contractual data and payment data. The personal data may furthermore constitute sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, to the extent that such processing is permissible.
We process personal data, where necessary, with the consent of the data subjects. We may process personal data without consent in many cases, for example to fulfil legal obligations or to protect overriding interests. We may also request the consent of data subjects where their consent is not required.
We process personal data for the duration required for the respective purpose. We anonymise or delete personal data in particular depending on statutory retention and limitation periods.
4. Disclosure of Personal Data
We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties may be, for example, specialised providers whose services we use. Such third parties may in turn disclose personal data to further third parties.
In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, accounting and fiduciary service providers, debt collection companies, interest groups, IT service providers, cooperation partners, credit and commercial information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.
5. Communication
We process personal data in order to communicate with individuals as well as with authorities, organisations and companies. In doing so, we process in particular data that a data subject transmits to us when making contact, for example by post or e-mail. We may store such data in an address book or using comparable tools.
Third parties who transmit data about other persons to us are legally obliged to ensure data protection for those data subjects independently. They must in particular ensure that they are authorised to transmit such data, and also guarantee the accuracy of the data transmitted.
6. Job Applications
We process personal data about applicants to the extent necessary for assessing their suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job posting. We may publish job postings with the assistance of suitable third parties, for example in electronic and printed media or on job portals and recruitment platforms.
We also process personal data that applicants voluntarily communicate or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.
Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular pursuant to Art. 9(2)(b) GDPR.
7. Data Security
We take appropriate technical and organisational measures to ensure a level of data security appropriate to the respective risk. Our measures ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without however being able to guarantee absolute data security.
Access to our website and our other digital presence is provided by means of transport encryption (SSL / TLS, in particular using the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn before visiting a website without transport encryption.
Our digital communications are subject – as is in principle all digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot exert any direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities. We also cannot exclude the possibility that a data subject is specifically monitored.
8. Personal Data Abroad
We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular to process it or have it processed there.
We may export personal data to all countries on earth and elsewhere in the universe, provided that the law of the country in question ensures an adequate level of data protection pursuant to a decision of the Swiss Federal Council and – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – also pursuant to a decision of the European Commission.
We may transfer personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard contractual clauses or other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special data protection law requirements are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. We are happy to provide data subjects with information about any safeguards upon request or to provide a copy of any safeguards.
9. Rights of Data Subjects
9.1 Data Protection Rights
We grant data subjects all rights under applicable law. Data subjects have in particular the following rights:
- Access: Data subjects may request whether we process personal data about them and, if so, what personal data is concerned. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of retention, any disclosure or export of data to other countries and the origin of the personal data.
- Rectification and restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed and the processing of their data restricted.
- Right to express one's own view and to human review: In the case of decisions based solely on automated processing of personal data that have a legal consequence for them or significantly affect them (automated individual decisions), data subjects may express their own view and request review by a human being.
- Erasure and objection: Data subjects may request the erasure of personal data ("right to be forgotten") and object to the processing of their data with effect for the future.
- Data portability and data transfer: Data subjects may request the release of personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of data subjects' rights within the legally permissible scope. We may inform data subjects of any conditions that must be met for the exercise of their data protection rights. We may, for example, refuse access in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. We may also, for example, refuse the erasure of personal data in whole or in part, in particular with reference to statutory retention obligations.
We may exceptionally charge fees for the exercise of rights. We inform data subjects in advance of any fees.
We are obliged to identify data subjects who request access or assert other rights by appropriate measures. Data subjects are obliged to cooperate.
9.2 Legal Remedies
Data subjects have the right to enforce their data protection rights through the courts or to lodge a complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), the data protection supervisory authorities are structured on a federal basis, in particular in Germany.
10. Use of the Website
10.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies may be stored in the browser temporarily as "session cookies" or for a specific period as so-called permanent cookies. Session cookies are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies enable in particular a browser to be recognised on the next visit to our website and thereby, for example, to measure the reach of our website. Permanent cookies may also be used, for example, for online marketing.
Cookies may be deactivated, restricted or deleted in whole or in part at any time in the browser settings. Browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least where and to the extent required under applicable law – explicit consent to the use of cookies.
For cookies used for success and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
10.2 Log Files
For each access to our website and our other digital presence, we may log at least the following information, to the extent that it is determined or transmitted by default to our digital infrastructure during such accesses: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpage of our website accessed including the volume of data transferred, last webpage accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. The information is necessary to be able to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also necessary to be able to ensure data security – including by third parties or with the assistance of third parties.
10.3 Tracking Pixels
We may integrate tracking pixels into our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are typically small, invisible images or scripts formulated in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can capture at least the same information as logging in log files.
11. Notifications and Communications
11.1 Success and Reach Measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner as well as permanently, securely and reliably, based on the needs and reading habits of recipients.
11.2 Consent and Objection
You must in principle consent to the use of your e-mail address and your other contact details, unless the use is permitted for other legal reasons. For the possible obtaining of a doubly confirmed consent, we may use the "double opt-in" procedure. In this case, you will receive a communication with instructions for the double confirmation. We may log consents obtained, including IP address and timestamp, for evidentiary and security reasons.
You may in principle object at any time to the receipt of notifications and communications such as newsletters. By such an objection, you may simultaneously object to the statistical recording of usage for success and reach measurement. Reserved are necessary notifications and communications in connection with our activities and operations.
11.3 Service Providers for Notifications and Communications
We send notifications and communications with the assistance of specialised service providers.
We use in particular:
- MAILINGWORK: E-mail marketing platform; provider: Mailingwork GmbH (Germany); privacy information: Privacy Policy, "Privacy Policy and Newsletter Delivery – What Should Be Considered?".
12. Social Media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as the privacy policies and other provisions of the individual operators of such platforms also apply. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which include for example the right of access.
For our social media presence on Facebook, including the so-called Page Insights, we are – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights in order to be able to provide our social media presence on Facebook effectively and in a user-friendly manner.
Further information on the nature, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in Facebook's Privacy Policy. We have concluded with Facebook the so-called "Controller Addendum" and have thereby agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information about Page Insights" including "Information about Page Insights Data".
13. Third-Party Services
We use services from specialised third parties in order to be able to conduct our activities and operations in a permanent, user-friendly, secure and reliable manner. With such services we can, among other things, embed functions and content in our website. When embedding such services, the services used collect, for technically mandatory reasons, at least temporarily the IP addresses of users.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to provide the respective service.
We use in particular:
- Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland), in part for users in the European Economic Area (EEA) and in Switzerland; general privacy information: "Our approach to privacy", Privacy Policy, "How Google uses personal data", "Google's commitment to complying with applicable data protection laws", "Privacy guide for Google products", "How we use data from websites or apps that use our services", Cookie Policy, "Ads that include your choices" (personalised advertising settings).
- Microsoft services: Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; general privacy information: "Microsoft Privacy", "Privacy and data protection", Privacy Statement, "Data and privacy settings".
13.1 Digital Infrastructure
We use services from specialised third parties in order to be able to use the required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
13.2 Appointment Scheduling
We use services from specialised third parties in order to be able to arrange appointments online, for example for meetings. In addition to this Privacy Policy, any conditions of the services used that may be directly visible, such as terms of use or privacy policies, also apply.
We use in particular:
- Doodle: Online appointment scheduling; provider: Doodle AG (Switzerland) as a subsidiary of TX Group AG (Switzerland); privacy information: Privacy Policy, "General Terms and Conditions of the Processing of Personal Data".
- Google Calendar: Online appointment scheduling; provider: Google; Google Calendar-specific information: "Appointment scheduling with Google Calendar", "Privacy in Google Calendar".
13.3 Online Collaboration
We use services from third parties to enable online collaboration. In addition to this Privacy Policy, any conditions of the services used that may be directly visible, such as terms of use or privacy policies, also apply.
We use in particular:
- Microsoft Teams: Platform for productive collaboration, in particular with audio and video conferencing; provider: Microsoft; Teams-specific information: "Security and compliance in Microsoft Teams", in particular "Privacy".
13.4 Maps
We use services from third parties in order to be able to embed maps in our website.
We use in particular:
- Google Maps including the Google Maps Platform: Map service; provider: Google; Google Maps-specific information: "How does Google use location information?".
- map.geo.admin.ch: Map service; provider: Federal Office of Topography swisstopo / Federal Spatial Data Infrastructure (FSDI); privacy information: Privacy Policy, "Legal Bases".
- OpenStreetMap (OSM): Map service; provider: OpenStreetMap Foundation (United Kingdom); privacy information: Privacy Policy.
- Outdooractive: Map service; provider: Outdooractive AG (Germany); privacy information: Privacy Policy.
13.5 E-Commerce
We operate e-commerce and use services from third parties in order to be able to successfully offer services, content or goods.
We use in particular:
- Holidu Smart Destination: Booking platform; provider: Holidu GmbH (Germany); privacy information: Privacy Policy.
13.6 Payments
We use specialised service providers in order to be able to process payments securely and reliably. For the processing of payments, the legal texts of the individual service providers, for example general terms and conditions (GTC) or privacy policies, also apply in addition.
We use in particular:
- Datatrans: Payment processing; provider: Datatrans AG (Switzerland); privacy information: Privacy Policy, "Security & Compliance".
- PostFinance: Payment processing; provider: PostFinance AG (Switzerland); privacy information: "Legal information and accessibility", "Data protection" (including privacy policies).
- TWINT: Payment processing in Switzerland; provider: TWINT AG (Switzerland); privacy information: Privacy Policy, "Security according to Swiss standards".
- Worldline: Payment processing, in particular with mobile payment solutions; providers: Worldline SA (France), Worldline Switzerland AG (Switzerland) and other Worldline companies worldwide (including in the USA); privacy information: Privacy Policy, "Responsible Disclosure Programme", Cookie Policy.
13.7 Advertising
We use the possibility of displaying targeted advertising with third parties such as social media platforms and search engines for our activities and operations.
With such advertising, we wish in particular to reach persons who are already interested or may be interested in our activities and operations (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties who enable such advertising. We may also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may possibly associate the use of our website with your profile on that platform.
We use in particular:
- Google Ads: Search engine advertising; provider: Google; Google Ads-specific information: advertising based inter alia on search queries, where various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – are used for Google Ads, Privacy Policy for advertising, "Manage ads shown directly via ads".
- Meta Ads: Social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); privacy information: targeting, including retargeting, in particular with the Meta Pixel and with Custom Audiences including Lookalike Audiences, Privacy Policy, "Ad Preferences" (registration as a user required).
14. Success and Reach Measurement
We endeavour to measure the success and reach of our activities and operations. In this context, we may also measure the effect of references from third parties or examine how different parts or versions of our digital presence are used ("A/B test" method). Based on the results of success and reach measurement, we may in particular fix errors, strengthen popular content or make improvements.
For success and reach measurement, the IP addresses of individual users are collected in most cases. In this case, IP addresses are in principle truncated ("IP masking") in order to follow the principle of data minimisation through the corresponding pseudonymisation.
In the course of success and reach measurement, cookies may be used and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are registered may possibly associate the use of our online offering with the user account or user profile at the respective service.
We use in particular:
- Google Marketing Platform: Success and reach measurement, in particular with Google Analytics; provider: Google; Google Marketing Platform-specific information: measurement also across different browsers and devices (cross-device tracking) with pseudonymised IP addresses, which are only exceptionally transmitted in full to Google in the USA, Privacy Policy for Google Analytics, "Browser add-on to deactivate Google Analytics".
- Google Tag Manager: Integration and management of Google and third-party services, in particular for success and reach measurement; provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further privacy information can be found at the individual integrated and managed services.
15. Video Surveillance
We use video surveillance for the prevention of criminal offences, for the preservation of evidence in the event of criminal offences, for the exercise and enforcement of our own legal claims, for the defence against third-party legal claims and for the exercise of our right of domicile. This constitutes – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – overriding legitimate interests pursuant to Art. 6(1)(f) GDPR, for sensitive personal data with reference to Art. 9(2)(f) GDPR.
We store recordings from our video surveillance for as long as they are required for the preservation of evidence or another stated purpose. As a rule, recordings are deleted or overwritten after 96 hours.
We may secure recordings from our video surveillance and transmit them to competent authorities, in particular judicial or law enforcement authorities, if the transmission is required for a stated purpose, in our other legitimate overriding interest or due to legal obligations.
16. Final Notes on the Privacy Policy
The present privacy policy is an unofficial translation from the original German version. The present privacy policy was created with the Privacy Policy Generator by Datenschutzpartner. The present privacy policy is an unofficial translation from the original German version.
We may update this Privacy Policy at any time. We inform about updates by publishing the current version of the Privacy Policy on our website.