Our Privacy Policy

Privacy Policy

Zermatt Holidays (hereinafter also referred to as "we", "us") collects and processes personal data concerning you or other persons (so-called "third parties"). We use the term "data" here synonymously with "personal data" or "personal information".
 
Personal data" refers to data that relates to specific or identifiable persons, i.e. it is possible to draw conclusions about their identity based on the data itself or with corresponding additional data. "Particularly sensitive personal data" is a category of personal data that enjoys special protection under applicable data protection law. For example, data revealing racial and ethnic origin, health data, information on religious or philosophical beliefs, biometric data for identification purposes and information on trade union membership are considered to be particularly sensitive personal data. Section 3 contains information on the data that we process within the scope of this privacy policy. "Processing" means any handling of personal data, e.g. obtaining, storing, using, adapting, disclosing and deleting.


In this Privacy Policy we describe what we do with your data when you use www.zermattholidays.com (hereinafter collectively referred to as the "Website"), purchase our services or products, otherwise engage with us under a contract, communicate with us or otherwise deal with us. Where appropriate, we will provide you with timely written notice of additional processing activities not mentioned in this Privacy Policy. In addition, we may inform you separately about the processing of your data, e.g. in declarations of consent, contractual terms, additional data protection declarations, forms and notices.
If you transmit or disclose data about other persons, such as family members, work colleagues, etc., we assume that you are authorised to do so and that this data is correct. By transmitting data about third parties, you confirm this. Please also ensure that these third parties have been informed of this privacy policy.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DPA") and the revised Swiss Data Protection Act ("revDSG"). However, whether and to what extent these laws are applicable depends on the individual case. 

 

Who is responsible for data processing?

Zermatt Holidays in 3920 Zermatt is responsible for the data processing by Zermatt Holidays described in this privacy policy, unless otherwise communicated in individual cases.

For each data processing operation, there are one or more bodies that are responsible for ensuring that the processing complies with the requirements of data protection law. This body is called the controller. It is responsible, for example, for responding to requests for information (section 11) or for ensuring that personal data is secured and not used in an unauthorised manner.

Other bodies may also be jointly responsible for the data processing described in this privacy policy if they are involved in deciding on the purpose or organisation. If you would like information on the individual controllers for a specific data processing operation, you are welcome to request information from us within the scope of the right to information (Section 11).

In section 3, section 7 and section 12 you will find further information on third parties with whom we work and who are responsible for their processing. If you have any questions or wish to exercise your rights vis-à-vis these third parties, please contact them directly.

You can contact us as follows for your data protection concerns and to exercise your rights in accordance with section 11:

Zermatt Holidays
Cor Groenenboom
CEO
Hinterdorfstrasse 76
3920 Zermatt
info@zermattholidays.com

 

What data do we process?

We process various categories of data about you. The most important categories are as follows:

  • Technical data: When you use our website or other electronic offers (e.g. free WLAN), we collect the IP address of your end device and other technical data to ensure the functionality and security of these offers. This data also includes logs in which the use of our systems is recorded. We generally store technical data for 6 months. To ensure the functionality of these offers, we can also assign you or your end device a customised code (e.g. in the form of a cookie, see section 12). The technical data itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, they can be linked to other data categories (and thus possibly to your person).

The technical data includes the IP address and information about the operating system of your end device, the date, region and time of use as well as the type of browser you use to access our electronic offers. This can help us to transmit the correct formatting of the website or, for example, to show you a website customised for your region. Although we know from the IP address which provider you are using to access our website (and therefore also the region), we cannot usually deduce who you are from this. This changes if you create a user account, for example, because personal data can then be linked to technical data (e.g. we can see which browser you are using to access an account via our website). Examples of technical data include logs that are generated in our systems (e.g. the log of user logins on our website).

  • Registration data: Certain offers, e.g. of competitions and services (e.g. login areas of our website, newsletter dispatch, free WLAN access, etc.) can only be used with a user account or registration, which can be done directly with us or via our external login service providers. In doing so, you must provide us with certain data and we collect data on the use of the offer or service. 
  • Communication data: If you are in contact with us via the contact form, by e-mail, telephone, letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the marginal data of the communication. If we want or need to establish your identity, e.g. if you request information, apply for media access, etc., we collect data to identify you (e.g. a copy of an identity document). We generally store this data for 12 months from the last exchange with you. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. E-mails in personal mailboxes and written correspondence are generally stored for at least 10 years. 
  • Master data: We define master data as the basic data that we require in addition to the contract data (see below) for the processing of our contractual and other business relationships or for marketing and advertising purposes, such as name, contact details and information, e.g. about your role and function, your bank account(s), your date of birth, customer history, powers of attorney, signature authorisations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (e.g. as a contact person of the business partner), or because we want to contact you for our own purposes or the purposes of a contractual partner (e.g. as part of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you yourself (e.g. when you make a purchase or register), from organisations for which you work or from third parties such as our contractual partners, associations and address dealers and from publicly accessible sources such as public registers or the internet (websites, social media, etc.). We generally store this data for 10 years from the last exchange with you, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. In the case of pure marketing and advertising contacts, the period is normally much shorter, usually no more than 2 years since the last contact.

The master data includes, for example, data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, nationality, details of associated persons, websites, social media profiles, photos and videos, copies of ID cards; furthermore, details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status with us, classifications and distribution lists, details of our interactions with you (if applicable, a history of these with corresponding entries), reports (e.g. from the media), details of your relationship with us (e.g. from the media), details of your personal data and your personal data. We also collect information about your relationship with us (customer, supplier, visitor, service recipient, etc.), information about your status with us, allocations, classifications and distribution lists, information about our interactions with you (possibly a history of these with corresponding entries), reports (e.g. from the media) or official documents (e.g. extracts from the commercial register, authorisations, etc.) that relate to you. We collect payment details such as your bank details, account number and credit card details. Consent or blocking notices are also part of the master data, as is information about third parties, e.g. contact persons, recipients of services, advertising recipients or representatives.

For contact persons and representatives of our customers, suppliers and partners, we process master data such as name and address, information on role, function in the company, qualifications and, if applicable, information on superiors, employees and subordinates and information on interactions with these persons.

Master data is not collected comprehensively for all contacts. Which data we collect in detail depends in particular on the purpose of the processing.

Contract data: This is data that arises in connection with the conclusion or processing of a contract, e.g. information on contracts and the services to be provided or provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing and information on reactions (e.g. complaints or information on satisfaction, etc.). We generally collect this data from you, from contractual partners and from third parties involved in the fulfilment of the contract, but also from third-party sources (e.g. providers of creditworthiness data) and from publicly accessible sources. We generally store this data for 10 years from the last contractual activity, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons.

Contract data includes information about the conclusion of the contract, about your contracts, e.g. type and date of conclusion of the contract, information from the application process (such as an application for our products or services) and information about the contract in question (e.g. its duration) and the processing and administration of the contracts (e.g. information in connection with invoicing, customer service, support with technical matters and the enforcement of contractual claims). Contract data also includes information on defects, complaints and adjustments to a contract, as well as information on customer satisfaction, which we can collect e.g. by means of surveys. Contract data also includes financial data such as information on creditworthiness (i.e. information that allows conclusions to be drawn about the likelihood of claims being settled), reminders and debt collection. We receive some of this data from you (e.g. when you make payments), but also from credit agencies and debt collection agencies and from publicly accessible sources (e.g. a commercial register).

Behavioural and preference data: Depending on the relationship we have with you, we try to get to know you and better tailor our products, services and offers to you. To do this, we collect and use data about your behaviour and preferences. We do this by evaluating information about your behaviour in our area, and we can also supplement this information with data from third parties, including from publicly accessible sources. Based on this, we can, for example, calculate the probability that you will use certain services or behave in a certain way. Some of the data processed for this purpose is already known to us (e.g. when you use our services), or we obtain this data by recording your behaviour (e.g. how you navigate our website). We anonymise or delete this data when it is no longer relevant for the purposes pursued, which can be between 2-3 weeks (for movement profiles) and 24 months (for product and service preferences), depending on the type of data. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. We describe how tracking works on our website in section 12.

Behavioural data is information about certain actions, e.g. about your reaction to electronic communications (e.g. whether and when you opened an email) or about your location as well as about your interaction with our social media profiles and about your participation in competitions, contests and similar events. For example, we may collect your location data wirelessly through unique codes sent by your mobile phone or when you use our website. We will inform you of the collection of anonymous movement profiles at the relevant locations by means of appropriate signs; we will only create a personalised movement profile with your consent.

Preference data provides us with information about your needs, which products or services might be of interest to you or when and how you are likely to react to messages from us. We obtain this information from the analysis of existing data, such as behavioural data, so that we can get to know you better, tailor our advice and offers more precisely to you and generally improve our offers. In order to improve the quality of our analyses, we can link this data with other data that we also obtain from third parties such as address dealers, government agencies and publicly accessible sources such as the Internet, e.g. with information on your household size, income bracket and purchasing power, shopping behaviour and contact details of relatives and anonymous information from statistical offices.

Behavioural and preference data can be evaluated on a personal basis (e.g. to show you personalised advertising), but also on a non-personal basis (e.g. for market research or product development). Behavioural and preference data can also be combined with other data (e.g. movement data can be used for contact tracing as part of a health protection concept).

Other data: We also collect data from you in other situations. In connection with official or court proceedings, for example, data is collected (such as files, evidence, etc.) that may also relate to you. We may also collect data for health protection reasons (e.g. as part of protection concepts). We may receive or produce photos, videos and audio recordings in which you may be recognisable (e.g. at events, through security cameras, etc.). We may also collect data about who enters certain buildings or has access rights to them and when (including during access controls, based on registration data or visitor lists, etc.), who takes part in events or campaigns (e.g. competitions) and when, or who uses our infrastructure and systems and when. The retention period for this data depends on the purpose and is limited to what is necessary. This ranges from a few days for many of the security cameras and usually a few weeks for contact tracing data to visitor data, which is usually stored for 3 months, to reports on events with images, which can be stored for several years or longer.

You provide us with much of the data mentioned in this Section 3 yourself (e.g. via forms, in the context of communication with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, subject to individual cases, e.g. as part of binding protection concepts (legal obligations). If you wish to conclude contracts with us or make use of services, you must also provide us with data as part of your contractual obligation in accordance with the relevant contract, in particular master data, contract data and registration data. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you must provide us with registration data.

Insofar as this is not prohibited, we also obtain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media or the Internet including social media) or receive data from authorities and other third parties (such as credit agencies, address dealers, associations, contractual partners, Internet analysis services, etc.). 

 

For what purposes do we process your data?

We process your data for the purposes explained below. Further information for the online area can be found in sections 12 and 13. These purposes and the underlying objectives represent legitimate interests on our part and, where applicable, on the part of third parties. You will find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular to respond to enquiries and assert your rights (Section 11) and to contact you in the event of queries. In particular, we use communication data and master data for this purpose and, in connection with offers and services used by you, also registration data. We retain this data in order to document our communication with you, for training purposes, for quality assurance and for enquiries.

We process data for the purpose of entering into, managing and processing contractual relationships.

We conclude contracts of various kinds with our business and private customers, with suppliers, subcontractors or other contractual partners, such as partners in projects or with parties in legal disputes. In particular, we process master data, contract data and communication data and, depending on the circumstances, registration data of the customer or the persons to whom the customer provides a service. This includes, for example, the recipients of our products or services who receive vouchers and invitations from our customers and may become our customers when they redeem them. In this case, we process data for the fulfilment of the contract with these recipients, but also with the contractual partners who have invited them.

As part of the business initiation process, personal data - in particular master data, contract data and communication data - is collected from potential customers or other contractual partners (e.g. in an order form or contract) or results from communication. We also process data in connection with the conclusion of the contract to check creditworthiness and to open the customer relationship. In some cases, this information is checked for compliance with legal requirements.

As part of the processing of contractual relationships, we process data for the administration of the customer relationship, for the provision and collection of contractual services (which also includes the involvement of third parties, such as logistics companies, security services, advertising service providers, banks, insurance companies or credit agencies, which may in turn provide us with data), for consulting and for customer support. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of processing, as are accounting, contract termination and public communication.

We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalised advertising about our products and services and those of third parties (e.g. advertising contractual partners). This may, for example, take the form of newsletters and other regular contacts (electronically, by post, by telephone), via other channels for which we have contact information from you, but also as part of individual marketing campaigns (e.g. events, competitions, etc.) and may also include free services (e.g. invitations, vouchers, etc.). You can refuse such contacts at any time (see the end of this section 4) or refuse or revoke your consent to be contacted for advertising purposes. With your consent, we can target our online advertising on the Internet more specifically to you (see section 12).

e may also process your data for security purposes and for access control.

We continuously review and improve the appropriate security of our IT and other infrastructure (e.g. buildings). Like all companies, we cannot rule out data security breaches with absolute certainty, but we do what we can to reduce the risks. We therefore process data e.g. for monitoring, controls, analyses and tests of our networks and IT infrastructures, for system and error checks, for documentation purposes and as part of backup copies. Access controls include controlling access to electronic systems (e.g. logging in to user accounts) as well as physical access control (e.g. building access). For security purposes (preventive and to investigate incidents), we also keep access logs and visitor lists and use surveillance systems (e.g. security cameras). We will inform you of surveillance systems at the relevant locations by means of appropriate signs.

We process personal data to comply with laws, instructions and recommendations from authorities and internal regulations ("compliance").

This includes, for example, the implementation of health and safety concepts or the legally regulated fight against money laundering and terrorist financing. In certain cases, we may be obliged to make certain enquiries about customers ("Know Your Customer") or to submit reports to the authorities. The fulfilment of disclosure, information or reporting obligations, e.g. in connection with supervisory and tax obligations, also requires or entails data processing, e.g. the fulfilment of archiving obligations and the prevention, detection and clarification of criminal offences and other violations. This also includes the receipt and processing of complaints and other reports, the monitoring of communications, internal investigations or the disclosure of documents to an authority if we have sufficient reason to do so or are legally obliged to do so. Your personal data may also be processed in the event of external investigations, e.g. by a law enforcement or supervisory authority or an authorised private body. We also process data to support our shareholders and other investors and fulfil our obligations in this regard. For all these purposes, we process in particular your master data, your contract data and communication data, but possibly also behavioural data and data from the categories of other data. The legal obligations may relate to Swiss law, but also to foreign regulations to which we are subject, as well as self-regulation, industry standards, our own corporate governance and official instructions and requests.

We also process data for the purposes of our risk management and in the context of prudent corporate governance, including business organisation and corporate development.

For these purposes, we process master data, contract data, registration data and technical data in particular, but also behavioural and communication data. For example, we need to monitor our debtors and creditors as part of our financial management, and we need to avoid becoming victims of offences and abuses, which may require the evaluation of data for corresponding patterns. We may also carry out profiling and create and process profiles for these purposes and to protect you and us from criminal or abusive activities (see also section 6). As part of the planning of our resources and organisation of our operations, we must evaluate and process data on the use of our services and other offers or exchange information with others (e.g. outsourcing partners), which may also include your data. The same applies to services provided to us by third parties. As part of our corporate development, we may sell or acquire businesses, parts of businesses or companies to or from others or enter into partnerships, which may also lead to the exchange and processing of data (including from you, e.g. as a customer or supplier or as a supplier representative).

We may process your data for other purposes, e.g. as part of our internal processes and administration or for training and quality assurance purposes.

These additional purposes include, for example, training and education purposes, administrative purposes (such as the management of master data, accounting and data archiving and the testing, management and ongoing improvement of IT infrastructure), the protection of our rights (e.g. to enforce claims in court, in or out of court and before authorities in Switzerland and abroad or to defend ourselves against claims, for example by preserving evidence, conducting legal investigations and participating in court or official proceedings) and the evaluation and improvement of internal processes. We may use recordings of (video) conferences for training and quality assurance purposes. The protection of other legitimate interests is also one of the other purposes, which cannot be listed exhaustively.

On what basis do we process your data?

If we ask for your consent for certain processing (e.g. for the processing of particularly sensitive personal data, for marketing mailings, for the creation of personalised movement profiles and for advertising control and behaviour analysis on the website), we will inform you separately about the corresponding purposes of the processing. You can withdraw your consent at any time with effect for the future by sending us written notification (by post) or, unless otherwise stated or agreed, by email; our contact details can be found in Section 2. For the withdrawal of your consent in the case of online tracking, see Section 12. If you have a user account, you can also withdraw your consent or contact us via the relevant website or other service. Once we have received notification of the withdrawal of your consent, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Where we do not ask for your consent for processing, we base the processing of your personal data on the fact that the processing is necessary for the initiation or execution of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest, in particular to pursue the purposes and associated objectives described above under Section 4 and to be able to implement corresponding measures. Our legitimate interests also include compliance with statutory provisions, insofar as this is not already recognised as a legal basis by the applicable data protection law (e.g. in the case of the GDPR, the law in the EEA and Switzerland). However, this also includes the marketing of our products and services, the interest in better understanding our markets and managing and further developing our company, including its operations, securely and efficiently.

If we receive sensitive data (e.g. health data, information on political, religious or ideological views or biometric data for identification purposes), we may also process your data on the basis of other legal grounds, e.g. in the event of disputes due to the necessity of processing for any legal proceedings or the enforcement or defence of legal claims. In individual cases, other legal grounds may apply, which we will communicate to you separately if necessary. 

What applies to profiling and automated individual decisions?

We may automatically evaluate certain of your personal characteristics for the purposes stated in Section 4 using your data (Section 3) ("profiling") if we want to determine preference data, but also to determine risks of misuse and security risks, to carry out statistical analyses or for operational planning purposes. For the same purposes, we can also create profiles, i.e. we can combine behavioural and preference data, but also master and contract data and technical data assigned to you in order to better understand you as a person with your different interests and other characteristics. However, we can also create anonymous and - with your consent - personalised movement profiles of you.

If you are one of our customers, we can, for example, use "profiling" to determine which other products you are likely to be interested in based on your purchases. We can also use this to check your creditworthiness before offering you a purchase on account. For your protection, an automated analysis of data can also check the likelihood of a particular transaction being fraudulent. This allows us to stop the transaction for clarification. This is to be distinguished from "profiles". This refers to the linking of various data in order to gain information about key aspects of your personality (e.g. what you like or how you behave in certain situations) from the totality of this data. Profiles can also be used for marketing and security purposes, for example.

We use anonymous movement profiles in a non-personalised manner, for example to provide our contractual partners with recommendations on how to avoid peak times. For personalised movement profiles, we use personal data, for example, to draw attention to interesting offers and products in your vicinity, to infer your interests from the position data (dwell time) and to inform you which products and services other contractual partners with similar interests have used or, for example, where health-related protection concepts specify contact tracing.

In both cases, we pay attention to the proportionality and reliability of the results and take measures to prevent misuse of these profiles or profiling. If these can have legal consequences or significant disadvantages for you, we always provide for a manual review. 

 

Who do we disclose your data to?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other purposes listed in Section 4, we also transfer your personal data to third parties, in particular to the following categories of recipients:

  • Service providers: We work with service providers in Switzerland and abroad who process data about you on our behalf or under joint responsibility with us or who receive data about you from us under their own responsibility (e.g. IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit agencies or address verifiers).

To enable us to provide our products and services efficiently and focus on our core competences, we procure services from third parties in numerous areas. These services include IT services, the dispatch of information, marketing, sales, communication and printing services, facility management, security and cleaning, the organisation and staging of events and receptions, debt collection, credit agencies, address verifiers (e.g. to update address databases in the event of relocations), anti-fraud measures and services from consulting firms, lawyers, banks, insurers and telecommunications companies. We provide these service providers with the data required for their services, which may also relate to you. These service providers may also use such data for their own purposes, e.g. information about outstanding debts and your payment behaviour in the case of credit agencies or anonymised information to improve services. In addition, we conclude contracts with these service providers that provide for data protection provisions, unless such protection is required by law. Our service providers may also process data on how their services are used and other data generated in the course of using their services as independent controllers for their own legitimate interests (e.g. for statistical analyses or billing). Service providers provide information about their independent data processing in their own data protection declarations. You can find more information on how Microsoft processes data here: https://privacy.microsoft.com/de-de/privacystatement; for the use of Microsoft Teams in particular here https://docs.microsoft.com/de-de/microsoftteams/teams-privacy.

  • Contractual partners including customers: This initially refers to customers (e.g. service recipients) and other contractual partners of ours, as this data transfer arises from these contracts. For example, you receive registration data for vouchers issued and redeemed, invitations, etc. If you work for such a contractual partner yourself, we may also transmit data about you to them in this context. This may also include health data. The recipients also include contractual partners with whom we cooperate or who advertise for us and to whom we therefore transmit data about you for analysis and marketing purposes (these may in turn be service recipients, but also sponsors and providers of online advertising, for example). We require these partners to only send you advertising or display it based on your data if you have consented to this (for the online area, see section 12).
  • If you act as an employee for a company with which we have concluded a contract, the fulfilment of this contract may result in us informing the company, for example, how you have used our service. Cooperation and advertising contract partners receive selected master, contract, behavioural and preference data from us so that they can carry out non-personal evaluations in their area (e.g. about the number of our customers who have viewed their advertising) and also use data for advertising purposes (including targeting you). For example, advertising contract partners should be able to communicate with suitable other customers of ours and send them advertising.
  • Authorities: We may disclose personal data to offices, courts and other authorities in Switzerland and abroad if we are legally obliged or authorised to do so or if this appears necessary to protect our interests. This may also include health data. The authorities process data about you that they receive from us on their own responsibility.

Use cases include criminal investigations, police measures (e.g. health protection concepts, combating violence, etc.), regulatory requirements and investigations, legal proceedings, reporting obligations and pre- and extrajudicial proceedings as well as statutory information and co-operation obligations. Data may also be disclosed if we wish to obtain information from public authorities, e.g. to justify an interest in obtaining information or because we need to say about whom we require information (e.g. from a register).

  • Other persons: This refers to other cases where the inclusion of third parties results from the purposes in accordance with Section 4, e.g. recipients of services, media and associations in which we participate or if you are part of one of our publications.

Other recipients are, for example, delivery recipients or third-party payment recipients other than those specified by you, other third parties also in the context of agency relationships (e.g. if we send your data to your lawyer or your bank) or persons involved in official or court proceedings. If we work with the media and send them material (e.g. photos), you may also be affected by this under certain circumstances. The same applies to the publication of content (e.g. photos, interviews, quotes, etc.) on our website or in other publications. As part of our corporate development, we may sell or acquire businesses, parts of businesses, assets or companies or enter into partnerships, which may also result in the disclosure of data (including your data, e.g. as a customer or supplier or as a supplier representative) to the persons involved in these transactions. In the course of communication with our competitors, industry organisations, associations and other bodies, data may also be exchanged that also concerns you.

All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.).

We also allow certain third parties to collect personal data from you on our website and at events organised by us (e.g. media photographers, providers of tools that we have integrated on our website, etc.). Insofar as we are not decisively involved in this data collection, these third parties are solely responsible for it. If you have any concerns and wish to assert your data protection rights, please contact these third parties directly. See section 12 for the website. 

Is your personal data also transferred abroad?

As explained in section 7, we also disclose data to other organisations. These are not only located in Switzerland. Your data can therefore be processed both in Europe and in the USA; in exceptional cases, however, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection regulations (we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exemption clause. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the fulfilment of a contract requires such disclosure, if you have given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.

Many countries outside of Switzerland, the EU and the EEA do not currently have laws that guarantee an adequate level of data protection from the perspective of the FADP or the GDPR. The contractual precautions mentioned above can partially compensate for this weaker or missing legal protection. However, contractual precautions cannot eliminate all risks (in particular from state access abroad). You should be aware of these residual risks, even if the risk may be low in individual cases and we take further measures (e.g. pseudonymisation or anonymisation) to minimise it.

Please also note that data exchanged via the Internet is often routed via third countries. Your data may therefore be sent abroad even if the sender and recipient are located in the same country.

 

How long do we process your data?

We process your data for as long as our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes require it or storage is technically necessary. Further information on the respective storage and processing periods can be found in the individual data categories in section 3 or in the cookie categories in section 12. If there are no legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our normal processes. 

 

How do we protect your data?

We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to counteract the risks of loss, unintentional alteration, unwanted disclosure or unauthorised access. 

 

What rights do you have?

To make it easier for you to control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and which of your data we are processing;
  • the right to have us correct data if it is incorrect;
  • the right to request the deletion of data;
  • the right to request that we provide you with certain personal data in a commonly used electronic format or transfer it to another controller
  • the right to withdraw consent where our processing is based on your consent
  • the right to request further information necessary to exercise these rights;

If you wish to exercise the above rights against us, please contact us in writing, at our premises or, unless otherwise stated or agreed, by e-mail; our contact details can be found in section 2. In order for us to rule out misuse, we must identify you (e.g. with a copy of your ID, unless otherwise possible).

Please note that these rights are subject to conditions, exceptions or restrictions under the applicable data protection law (e.g. to protect third parties or business secrets). We will inform you accordingly if necessary.

In particular, we may need to further process and store your personal data in order to fulfil a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defence of legal claims, or to comply with legal obligations. To the extent permitted by law, in particular to protect the rights and freedoms of other data subjects and to protect legitimate interests, we may therefore refuse a data subject's request in whole or in part (e.g. by blacking out certain content that concerns third parties or our business secrets).

If you do not agree with our handling of your rights or data protection, please let us or our data protection officer (Section 2) know. In particular, if you are located in the EEA, the United Kingdom or Switzerland, you also have the right to lodge a complaint with the data protection supervisory authority in your country. A list of authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_de. You can contact the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can contact the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/adresse.html. 

 

Do we use online tracking and online advertising technologies?

We use various technologies on our website with which we and third parties engaged by us can recognise you when you use our website and, under certain circumstances, track you over several visits. We will inform you about this in this section.

Essentially, this is so that we can distinguish between your access (via your system) and access by other users, so that we can ensure the functionality of the website and carry out analyses and personalisation. We do not want to draw conclusions about your identity, even if we can, insofar as we or third parties engaged by us can identify you by combining this with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you visit the website, for example by our server (or the servers of third parties) assigning you or your browser a specific identification number (so-called "cookie").

Cookies are individual codes (e.g. a serial number) that our server or a server of our service provider or advertising contract partner transmits to your system when you connect to our website and that your system (browser, mobile) receives and stores until the programmed expiry date. Each time you access our website again, your system transmits these codes to our server or the server of the third party. This allows you to be recognised, even if your identity is unknown.

Other techniques can also be used to recognise you with a greater or lesser degree of probability (i.e. to distinguish you from other users), e.g. "fingerprinting". Fingerprinting combines your IP address, the browser you use, screen resolution, language selection and other information that your system communicates to each server, resulting in a more or less unique fingerprint. In this way, cookies can be dispensed with.

Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can therefore be "tracked" (traced). If we integrate offers from a contractual advertising partner or provider of an analysis tool on our website, they can track you in the same way, even if you cannot be identified in individual cases.

We use such techniques on our website and allow certain third parties to do the same. However, depending on the purpose of these technologies, we may ask for your consent before using them. You can programme your browser to block or deceive certain cookies or alternative technologies or to delete existing cookies. You can also add software to your browser that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the heading "Data protection") or on the websites of the third parties listed below. A distinction is made between the following cookies (technologies with comparable functions such as fingerprinting are also included here):

  • Necessary cookies: Some cookies are necessary for the functioning of the website as such or for certain functions. For example, they ensure that you can switch between pages without losing the information entered in a form. They also ensure that you remain logged in. These cookies are only temporary ("session cookies"). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond a session (i.e. a visit to the website) if you use this function (e.g. selected language, consent given, the function for automatic log-in, etc.). These cookies have an expiry date of up to 24 months.

 

  • Performance cookies: In order to optimise our website and corresponding offers and better tailor them to the needs of users, we use cookies to record and analyse the use of our website, possibly even beyond the session. We do this by using third-party analysis services. We have listed these below. Before we use such cookies, we will ask for your consent. Performance cookies also have an expiry date of up to 24 months. Details can be found on the websites of the third-party providers.

We may also integrate other third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (e.g. by clicking a button), the relevant providers can recognise that you are on our website. If you have an account with the social media provider, they can assign this information to you and thus track your use of online services. These social media providers process this data on their own responsibility.

We currently use offers from the following service providers and advertising contract partners (insofar as they use data from you or cookies set by you for advertising purposes):

  • Google Analytics: Google Ireland (based in Ireland) is the provider of the "Google Analytics" service and acts as our Google Ireland relies on Google LLC (based in the USA) as its processor (both "Google"). Google uses performance cookies (see above) to track the behaviour of visitors to our website (duration, frequency of pages accessed, geographical origin of access, etc.) and compiles reports for us on the use of our website on this basis. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before being forwarded to the USA and therefore cannot be traced. We have switched off the settings "Data transfer" and "Signals". Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these persons. If you agree to the use of Google Analytics, you explicitly consent to such processing, which also includes the transfer of personal data (in particular usage data for the website and app, device information and individual IDs) to the USA and other countries. You can find information on Google Analytics data protection here

https://support.google.com/analytics/answer/6004245 and if you have a Google account, you will find further information on processing by Google here https://policies.google.com/technologies/partner-sites?hl=de.

 

What data do we process on our pages in social networks?

We may operate pages and other online presences ("fan pages", "channels", "profiles", etc.) on social networks and other platforms operated by third parties and collect the data about you described in section 3 and below. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presence and link this data with other data about you known to the platforms (e.g. about your behaviour and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalise advertising) and to control their platforms (e.g. which content they display to you).

 

We receive data about you when you communicate with us via online presences or view our content on the corresponding platforms, visit our online presences or are active on them (e.g. publish content, make comments). These platforms also collect technical data, registration data, communication data, behavioural data and preference data from you or about you (for the terms, see section 3). These platforms regularly statistically analyse the way in which you interact with us, how you use our online presences, our content or other parts of the platform (what you view, comment on, "like", share, etc.) and link this data with other information about you (e.g. information about your age and gender and other demographic information). In this way, they also create profiles about you and statistics on the use of our online presences. They use this data and profiles to show you our or other advertising and other content on the platform in a personalised way and to control the behaviour of the platform, but also for market and user research and to provide us and other bodies with information about you and the use of our online presence. We can partially control the analyses that these platforms create regarding the use of our online presence.

We process this data for the purposes described in section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see section 12) and for market research. You will find information on the relevant legal bases in section 5. We may redistribute content published by you (e.g. comments on an announcement) ourselves (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the usage guidelines (e.g. inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy policies of the platforms. There you can also find out in which countries they process your data, what rights of access, erasure and other rights of data subjects you have and how you can exercise these or obtain further information. We currently use the following platforms:

  • Facebook: Here we operate the page facebook.com/zermattholidays. The entity responsible for operating the platform for users is Meta Platforms Ireland Ltd, Dublin, Ireland. Their privacy policy is available at www.facebook.com/policy. Some of your data will be transferred to the USA. You can object to advertising here: www.facebook.com/settings?tab=ads. We are jointly responsible with Facebook Ireland Ltd, Dublin, Ireland, for the data that is collected and processed when you visit our site for the creation of "Page Insights". As part of Page Insights, statistics are compiled about what visitors do on our page (comment on posts, forward content, etc.). This is described at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us to understand how our site is used and how we can improve it. We only receive anonymous, aggregated data. We have regulated our responsibilities regarding data protection in accordance with the information on facebook.com/legal/terms/page_controller_addendum.

 

  • Instagram: Here we operate the website https://www.instagram.com/zermattholidays/. The entity responsible for operating the platform for users is Meta Platforms Ireland Ltd, Dublin, Ireland. Their privacy policy can be found at https://help.instagram.com/155833707900388. Some of your data will be transferred to the USA. You can object to advertising here: www.facebook.com/settings?tab=ads. We are jointly responsible with Facebook Ireland Ltd, Dublin, Ireland, for the data that is collected and processed when you visit our site for the creation of "Page Insights". As part of Page Insights, statistics are compiled about what visitors do on our page (comment on posts, forward content, etc.). This is described at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us to understand how our site is used and how we can improve it. We only receive anonymous, aggregated data. We have regulated our responsibilities regarding data protection in accordance with the information on facebook.com/legal/terms/page_controller_addendum.

 

Can this privacy policy be amended?

This privacy policy is not part of any contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last update: 22/08/2023