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Privacy Policy.

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PRIVACY STATEMENT

Mr. David Delgado
Compagnie Hôtelière des Alpes Vaudoises  (CHAV)
route du Belvédère 20
CH-1854 Leysin
Switzerland

Phone: +41 24 493 0707

manages the hotels: Central Résidence and Alpine Classic Hotel and operates the websites: https://www.hotelcr.ch and https://www.classic-hotel.ch and is thus responsible for the collection, processing, and use of your personal data as well as compliance with applicable data protection laws. We attach great importance to your trust, which is why we take data protection very seriously and ensure appropriate security. We naturally comply with the legal provisions of the Swiss Federal Data Protection Act (DPA), the Ordinance to the Federal Data Protection Act (ODPA), the Federal Telecommunications Act (TCA), and other data protection provisions from Swiss or possibly applicable EU legislation, in particular the General Data Protection Regulation (GDPR). To know what personal data about you we collect and for what purposes we use it, please read the information below carefully. Our representative in the EU for data protection law is: [David Delgado, route du Belvédère 20, 1854 Leysin, Switzerland, info@hotelcr.ch].

Website
Visiting our website

When you visit our site, our server temporarily records each access in a log file. The following technical data is then recorded, in principle as with any connection to a web server, without any action on your part and stored by us until it is automatically deleted no later than [12] months:

the IP address of the computer accessing the site,
the name of the owner of the IP space (usually your internet service provider),
the date and time of access,
the website from which you accessed our site (original URL) and possibly the search keywords used,
the name and URL of the file accessed,
the status code (e.g., error message),
your computer's operating system,
the browser you are using (type, version, and language),
the communication protocol used (e.g., HTTP/1.1)
and
possibly your username from registration/authentication.
The collection and processing of this data is intended to enable the use of our website (establishing a connection), ensure the long-term security and stability of the system, and enable the optimization of our online offering, as well as for internal statistics purposes. These processes are based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The IP address is also analyzed with other data for the purpose of recognizing and defending against attacks on the network infrastructure or other unauthorized or abusive uses of the website, and may be used in the context of criminal proceedings for identification and civil and criminal action against the user concerned. These processes are based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.
Use of our contact form

You have the option to use a form to contact us. For this, we require the following information:

first and last name
email address
message
We only use this data, as well as your optionally provided phone number, to respond to your contact request in the best and most personalized way. The processing of this data is necessary for the execution of pre-contractual measures in accordance with Art. 6 para. 1 lit. b GDPR or is based on our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR, respectively.
Subscription to our newsletter

You have the option to subscribe to our newsletter on our website. For this, you need to register and provide the following data: title first name and last name email address The above data is essential for data processing. You can also provide other optional data (date of birth and country[A2]). We process this data exclusively to personalize the information and offers we send you and to better tailor them to your interests. By registering, you consent to the processing of the data you have provided for the regular sending of the newsletter to the address you have provided, as well as for the statistical analysis of your user behavior and the optimization of the newsletter. This consent represents our legal basis for processing your email address in accordance with Art. 6 para. 1 lit. a GDPR. We are authorized to use third parties for the technical implementation of advertising campaigns and are authorized to transmit your data for this purpose (see section 13 below). At the end of each newsletter, you will find a link to unsubscribe at any time. As part of your unsubscribe, you can optionally indicate the reason. Your personal data is deleted after you unsubscribe. Further processing only takes place in anonymous form for the purpose of optimizing our newsletter.

Creating a customer account

To make reservations on our site, you can place an order as a visitor or open a customer account. When you register for a customer account, we collect the following data:

title
first name and last name
postal address
date of birth
phone number
email address
password
This data, as well as other optional information (e.g., company name), is collected for the purpose of providing you with direct and password-protected access to your basic data stored in our system. You can view your previous and current reservations there or manage or modify your personal data. Your consent in accordance with Art. 6 para. 1 lit. a GDPR is the legal basis for data processing for this purpose.
Booking on the website, by correspondence, or by phone

If you make reservations through our website, by correspondence (email or mail), or by phone, we need the following data for contract execution:

title
first name and last name
postal address
date of birth
phone number
language
information about your credit card
email address
We use this data, as well as other optional information you provide (e.g., expected arrival time, motor vehicle license plate, preferences, comments), exclusively for contract execution unless otherwise specified in this privacy policy or if you have given separate consent. We will process this data, in particular, to record your reservation in accordance with your request, provide the reserved services, contact you in case of uncertainties or problems, and ensure that payment is correctly made. Contract execution in accordance with Art. 6 para. 1 lit. b GDPR is the legal basis for data processing for this purpose.

Cookies

Cookies in many ways make your visit to our site simpler, more enjoyable, and more useful. Cookies are files containing information that your web browser automatically stores on your computer's hard drive when you visit our site. For example, we use cookies to temporarily store your selected services and information entered when you fill out a form on our site so that you do not have to enter them again when you visit a subpage. Furthermore, cookies can also be used to identify you as a registered user after you have registered on our site. This saves you from having to log in again when you visit another subpage. Most web browsers automatically accept cookies. However, you can configure your browser to not store any cookies on your computer or to always display a notice before a new cookie is created. However, completely disabling cookies may mean that you cannot use all the features of our website. For information on how to delete cookies from your browser, please refer to its help menu. Further information can be found at: https://www.aboutcookies.org/. We use the following cookies:

Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics uses "cookies," text files that are stored on your computer and that enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymization on this website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide the website operator with other services related to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case, you may not be able to use all the functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Your rights regarding personal data
You have the following rights regarding your personal data:
Right to information (Art. 15 GDPR):
You have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed and, if so, information about such personal data and the processing.
Right to rectification (Art. 16 GDPR):
You have the right to request the correction of inaccurate personal data concerning you, including completion of incomplete personal data.
Right to deletion (Art. 17 GDPR):
You have the right to request the deletion of personal data concerning you if the legal requirements are met.
Right to restrict processing (Art. 18 GDPR):
You have the right to request the restriction of processing of your personal data under certain circumstances.
Right to data portability (Art. 20 GDPR):
Under certain circumstances, you have the right to receive your personal data in a structured, common, and machine-readable format.
Right to object (Art. 21 GDPR):

If we process personal data on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) or to perform a task carried out in the public interest/exercise of official authority (Art. 6 para. 1 lit. e GDPR), you have the right to object to such processing on grounds relating to your particular situation.

Right to withdraw consent (Art. 7 para. 3 GDPR):

If you have given us your consent to process your personal data, you have the right to withdraw your consent at any time. The legality of the processing carried out on the basis of the consent until the withdrawal is not affected by this.

Right to lodge a complaint with a supervisory authority (Art. 77 GDPR):

If you believe that the processing of personal data concerning you is unlawful, you have the right to lodge a complaint with a supervisory authority responsible for data protection.

Data security

We use appropriate technical and organizational security measures to protect your stored personal data against manipulation, partial or complete loss, and against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

Amendments to this privacy policy

We reserve the right to amend this privacy policy at any time without notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will notify you of the change in the event of an update by email or other suitable means.

Status: [March 31, 2022]

Data Processing Related to Your Stay

Upon your arrival at our hotel, we need the following information about you and the people accompanying you:

First and last name
Postal address and canton
Date of birth
Place of birth
Nationality
Official identification and number
Check-in and check-out date
Room number
We collect this information to fulfill legal obligations, particularly those arising from police and hotel legislation. To the extent required by applicable provisions, we may transmit this information to the competent police authority. We have a legitimate interest under Article 6(1)(f) of the GDPR to comply with legal provisions.

Recording of Provided Services

If you use additional services during your stay (e.g., mini-bar or pay-per-view TV), we record the details of the service and the date of use for billing purposes. The processing of this data is necessary for the performance of your contract with us under Article 6(1)(b) of the GDPR.

Reservation Platforms

If you make reservations through a third-party platform, the platform operator sends us various personal information. Typically, this includes the data mentioned in section 5 of this privacy policy. Furthermore, inquiries regarding your reservation may also be forwarded to us. We process this data to fulfill your reservation request and provide the reserved services. The legal basis for processing data for this purpose is the performance of a contract under Article 6(1)(b) of the GDPR. Lastly, platform operators may inform us about disputes related to a reservation. They may also provide us with data regarding the reservation process, where a copy of the booking confirmation can serve as proof of its effective closure. We process this data to protect and enforce our rights. For these processes, we rely on our legitimate interest under Article 6(1)(f) of the GDPR. Please also review the respective privacy policies of the providers.

Centralized Data Storage and Data Linking

We store the data specified in sections 2-5 and 8-10 in a centralized electronic data processing system. Data related to you is systematically collected and linked for the processing of your reservations and the execution of contractual services. To do this, we use software from the company D-EDGE, located at 14-16 Bd Poissonnière - 75009 Paris. The processing of this data by the software is based on our legitimate interest under Article 6(1)(f) of the GDPR for efficient customer data management.

Retention Period

We only store personal data for as long as necessary for the use of the aforementioned tracking services and subsequent processing based on our legitimate interest. We keep contractual data for a longer period when required by legal retention obligations. The obligations to retain data arise from provisions regarding reporting to authorities, financial accounting, and tax law. In accordance with these provisions, business communications, concluded contracts, and accounting records must be kept for up to 10 years. Once we no longer need this data for service execution, it is blocked and can only be used for accounting and tax purposes.

Data Transmission to Third Parties

We only transmit your personal data when you have expressly consented to it, when we are legally obligated to do so, or when it is necessary to enforce our rights, particularly those arising from the contractual relationship. Additionally, we may transmit your personal data to third parties to enable the use of the website and contract execution, including off-site services, especially for processing your reservations. Our web host [OVH] is a service provider to whom we transmit personal data collected via the website or who has access to it. The website is hosted on servers in [FRANCE]. The data transmission serves the purpose of providing and maintaining the functionality of our website. This processing is based on our legitimate interest under Article 6(1)(f) of the GDPR. Finally, we transmit information about your credit card to the card issuer and acquirer during credit card payments on our website. If you choose to pay by credit card, you must enter all necessary information. The legal basis for data transmission is the performance of a contract under Article 6(1)(b) of the GDPR. Regarding the processing of credit card information by these third parties, please also read the terms and privacy policy of your credit card issuer. Please also refer to sections 7-8 and 10-11 for information on data transmission to third parties.

Transfer of Personal Data Abroad

We are also entitled to transfer your personal data to third-party companies (mandated service providers) abroad for the data processing specified in this privacy policy. These companies are subject to the same level of data protection as we are. If the level of data protection in a particular country does not correspond to Swiss or European levels, we ensure, through contractual agreements, that the protection of your personal data is equivalent to that in Switzerland or the EU.

You have the right to request information about the personal data we hold about you. Furthermore, you have the right to correct incorrect data and request the deletion of your personal data as long as there is no legal obligation to retain it or a legal basis for processing it. You also have the right to request the return of data you have provided (data portability) to a third party of your choice. You have the right to receive the data in a standard format. You can contact us for the aforementioned purposes at the following email address: info@hotelcr.ch. We may, at our discretion, request proof of identity for the processing of your requests.

Data Security

We use appropriate technical and organizational security measures to protect the personal data we store about you from manipulation, partial or total loss, and unauthorized access by third parties. Our security measures are continually improved based on technological advances. You should always keep your access data confidential and close the browser window when you have finished your communication with us, especially if you are not the only person using the computer. Data protection is also taken very seriously within our company. Our employees and contracted service providers are bound by confidentiality and comply with legal data protection requirements.

Note on Data Transfers to the United States

For the sake of completeness, we inform users whose residence or registered office is in Switzerland that the United States is subject to surveillance measures by U.S. authorities. These generally allow for the recording of all personal data of individuals whose data has been transferred from Switzerland to the United States. This is done without differentiation, limitation, or exception based on the pursued purpose and without an objective criterion that would allow for limiting U.S. authorities' access to the data and its subsequent use for very specific, strictly limited purposes that could justify the interference that accessing this data and its use entails. Furthermore, we inform you that, in the United States, there are generally no legal remedies available to data subjects from Switzerland enabling them to access the data concerning them and obtain its correction or deletion, or to seek judicial protection against general access rights of U.S. authorities. We explicitly draw the attention of the data subject to this legal and factual situation so that they can make an informed decision to consent to the use of their data. We inform users domiciled in an EU member state that the United States, especially due to the issues mentioned in this section, does not provide an adequate level of data protection.

To the extent that we have explained in this privacy policy that certain data recipients (e.g., Google) have their headquarters in the United States, we will ensure either through contractual provisions with these companies or through their certification under the EU-U.S. or Swiss-U.S. Privacy Shield that your data is given a reasonable level of protection by our partners.

Right to Lodge a Complaint with a Data Protection Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. Version: [2018]

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