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Data Privacy Policy

This data privacy policy was drawn up together with with regard to the New Federal Act on Data Protection (nFADP). This is an automated translation which might not be perfect (please refer to the original version).

This Privacy Policy informs about the personal data we process in connection with our activities and operations including our website. Specifically, it details the purposes, methods, and locations of our personal data processing. It also informs about the rights of individuals whose data we process.

Additional privacy policies and other legal documents such as Terms and Conditions (T&C), Terms of Use, or participation conditions may apply for specific or additional activities and operations.

We are subject to Swiss data protection law and any applicable foreign data protection law, particularly that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. Contact Addresses

Responsibility for the processing of personal data:

Brigels Resort AG
Via Plaun Rueun 44
7165 Brigels

In individual cases, there may be other parties responsible for processing personal data or joint responsibility with at least one other party.

1.1 Data Protection Officer or Data Protection Advisor

We have appointed the following Data Protection Officer or Data Protection Advisor as a point of contact for affected individuals and authorities regarding inquiries related to data protection:

Gérard Carigiet
Brigels Resort AG
Via Plaun Rueun 44
7165 Brigels

1.2 Data Protection Representation in the European Economic Area (EEA)

We have the following data protection representation according to Art. 27 GDPR:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg

The data protection representation serves as an additional point of contact for affected individuals and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the GDPR.

2.1 Terms

Personal data are all information relating to an identified or identifiable natural person. An affected person is an individual whose personal data we process.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adjusting, archiving, storing, reading, disclosing, obtaining, collecting, raising, deleting, making known, ordering, organizing, preserving, modifying, spreading, linking, destroying, and using personal data.

The European Economic Area (EEA) includes the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data.

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

When the General Data Protection Regulation (GDPR) applies, we process personal data based on at least one of the following legal bases:

  • Art. 6 para. 1 lit. b GDPR for processing necessary for the performance of a contract with the data subject or to take steps at the request of the data subject prior to entering into a contract.
  • Art. 6 para. 1 lit. f GDPR for processing necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data. Legitimate interests include our interest in carrying out our activities and operations in a sustainable, user-friendly, secure, and reliable manner, as well as communicating about it, ensuring information security, protecting against misuse, asserting our own legal claims, and complying with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for processing necessary for compliance with a legal obligation to which we are subject under the law of member states in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for processing necessary for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for processing personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for processing necessary to protect the vital interests of the data subject or another natural person.

3. Type, Scope, and Purpose

We process the personal data that are necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. Such personal data may fall into categories such as inventory and contact data, browser and device data, content data, meta or marginal data, usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration necessary for the respective purpose or purposes, or as required by law. Personal data that are no longer necessary for processing are anonymized or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer personal data to third parties. Such third parties are especially specialized providers whose services we use. We also ensure data protection with such third parties.

We generally process personal data only with the consent of the data subjects. Where processing is permitted on other legal grounds, we may refrain from seeking consent. For example, we may process personal data without consent to fulfill a contract, comply with legal obligations, or protect overriding interests.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of carrying out our activities and operations, provided and to the extent such processing is permitted on legal grounds.

4. Communication

We process personal data to communicate with third parties. In this context, we process data that a data subject transmits to us, for example, via postal mail or email. We may store such data in an address book or with similar tools.

Third parties who transmit data about other persons are required to ensure data protection for such affected individuals. This includes, among other things, verifying the accuracy of the transmitted personal data.

We use selected services from suitable providers to improve communication with third parties.

5. Data Security

We implement suitable technical and organizational measures to ensure data security appropriate to the risk level. Our measures particularly aim to ensure the confidentiality, availability, traceability, and integrity of processed personal data, though absolute data security cannot be guaranteed.

Access to our website and other online presences is secured through transport encryption (SSL / TLS, especially with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

Our digital communication is subject – like all digital communication in general – 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 directly influence the respective processing of personal data by intelligence services, police departments, and other security authorities. Nor can we exclude the possibility that specific individuals may be monitored deliberately.

6. Personal Data Abroad

We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other states, in particular, to process them there or have them processed.

We can export personal data to any state and territory on Earth as well as elsewhere in the universe, provided that the local law ensures an adequate level of data protection according to the decision of the Swiss Federal Council and – to the extent the General Data Protection Regulation (GDPR) applies – according to the decision of the European Commission.

We may transfer personal data to countries whose laws do not ensure an adequate level of data protection, provided data protection is ensured for other reasons, particularly on the basis of standard data protection clauses or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the special legal requirements for such transfer are met, for example, the explicit consent of the data subjects or a direct connection to the conclusion or fulfillment of a contract. We gladly provide affected individuals with information about possible guarantees or a copy of such guarantees upon request.

7. Rights of Data Subjects

7.1 Data Protection Claims

We grant all rights to data subjects according to applicable data protection law. Data subjects have, in particular, the following rights:

  • Access: Data subjects can request information about whether we process personal data concerning them and, if so, what specific data. Furthermore, they are entitled to receive additional information necessary to exercise their data protection claims and ensure transparency. This includes the processed personal data themselves, as well as information about the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the source of the personal data.
  • Rectification and Restriction: Data subjects can correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
  • Deletion and Objection: Data subjects can have their personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
  • Data Provision and Data Transfer: Data subjects can request the provision of personal data or the transfer of their data to another controller.

We may defer, restrict, or refuse the exercise of rights by data subjects within the legally permissible framework. We can point out any prerequisites that data subjects must fulfill to exercise their data protection claims. For example, we may partially or fully refuse disclosure with reference to trade secrets or the protection of other persons. Likewise, we may partially or fully refuse deletion of personal data with reference to statutory retention obligations.

We may exceptionally charge costs for exercising rights. We inform affected individuals in advance about any potential costs.

We are obligated to identify data subjects who request information or assert other rights by reasonable means. Data subjects are required to cooperate.

Data subjects have the right to enforce their data protection claims through legal proceedings or to file a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for complaints against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities for complaints from data subjects – to the extent that the General Data Protection Regulation (GDPR) applies – are organized as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany.

8. Use of the Website

8.1 Cookies

We may use cookies. Cookies – both our own (first-party cookies) and those of 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 can be stored in the browser temporarily as "session cookies" or for a certain period as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies, in particular, allow a browser to be recognized on the next visit to our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing.

Cookies can be completely or partially disabled and deleted in the browser settings at any time. Without cookies, our website may not be fully available. We ask for – at least to the extent necessary – 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 many 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).

8.2 Logging

We can log at least the following information for each access to our website and other online presence, provided these are transmitted to our digital infrastructure during such access: Date and time including timezone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including the amount of data transferred, the last webpage called up in the same browser window (referrer or referrer).

We log such information, which can also constitute personal data, in log files. The information is necessary to provide our online presence in a permanent, user-friendly, and reliable manner. The information is also necessary to ensure data security – also by third parties or with the help of third parties.

8.3 Tracking Pixels

We can incorporate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels – also from third parties whose services we use – are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when accessing our online presence. Tracking pixels can capture at least the same information as logged in log files.

9. Notifications and Communications

We send notifications and communications via email and through other communication channels such as instant messaging or SMS.

9.1 Success and Reach Measurement

Notifications and communications may contain web links or tracking pixels that capture whether an individual message was opened and which web links were clicked. Such web links and tracking pixels can also capture the use of notifications and communications on a personal basis. We need this statistical capture of use for success and reach measurement, to send notifications and communications effectively and user-friendly based on the needs and reading habits of the recipients in a permanent, secure, and reliable manner.

You must generally consent to the use of your email address and other contact addresses unless the use is permitted for other legal reasons. We may use the "Double Opt-in" procedure for obtaining double-confirmed consent. In this case, you will receive a notification with instructions for double confirmation. We may log obtained consents including IP address and timestamp for evidence and security reasons.

You can generally object to receiving notifications and messages such as newsletters at any time. With such an objection, you can simultaneously object to the statistical collection of usage for success and reach measurement. Required notifications and communications related to our activities and operations are reserved.

9.3 Service Providers for Notifications and Communications

We send notifications and communications with the help of specialized service providers.

We use, in particular:

10. Social Media

We are present on social media platforms and other online platforms to communicate with interested individuals and inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC), terms of use, privacy policies, and other provisions of the individual operators of such platforms also apply. These provisions particularly inform about the rights of data subjects directly against the respective platform, including, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are – to the extent that the General Data Protection Regulation (GDPR) applies – 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 insights into how visitors interact with our Facebook presence. We use Page Insights to effectively and user-friendly provide our social media presence on Facebook.

Further information about the type, 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 the Facebook Privacy Policy. We have concluded the so-called "Controller Addendum" with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the page "Information on Page Insights" including "Information on Page Insights Data".

11. Third-Party Services

We use services from specialized third parties to be able to conduct our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed functions and content into our website. Such embedding requires the utilized services to temporarily capture the IP addresses of users for technical reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we utilize may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized manner. This may include performance or usage data to offer the respective service.

We use, in particular:

11.1 Digital Infrastructure

We use services from specialized third parties to access the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

11.2 Automation and Integration of Apps and Services

We utilize specialized platforms to integrate and connect existing third-party apps and services. With such "No-Code" platforms, we can also automate processes and activities with third-party apps and services.

We use, in particular:

11.3 Audio and Video Conferencing

We use specialized services for audio and video conferencing to communicate online. For example, we can hold virtual meetings, conduct online classes, and webinars. Participation in audio and video conferences is also subject to the legal texts of the individual services, such as privacy policies and terms of use.

We recommend, depending on the situation, muting the microphone by default during participation in audio or video conferences and blurring the background or using a virtual background.

We use, in particular:

11.4 Maps

We use services from third parties to embed maps into our website.

We use, in particular:

11.5 Digital Audio and Video Content

We use services from specialized third parties to enable the direct playback of digital audio and video content, such as music or podcasts.

We use, in particular:

11.6 Fonts

We use services from third parties to embed selected fonts as well as icons, logos, and symbols into our website.

We use, in particular:

11.7 E-Commerce

We operate e-commerce and use services from third parties to successfully offer services, content, or goods.

11.8 Payments

We use specialized service providers to securely and reliably process payments from our customers. The processing of payments is also subject to the legal texts of the individual service providers, such as Terms and Conditions (T&C) or privacy policies.

We use, in particular:

11.9 Advertising

We utilize the possibility of showing targeted advertising on third-party platforms such as social media platforms and search engines for our activities and operations.

We aim to reach individuals who are already interested in our activities and operations or who might be interested (Remarketing and Targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We can also determine whether our advertising is successful, specifically whether it leads to visits to our website (Conversion Tracking).

Third parties, where we advertise and where you as a user are registered, may be able to associate the use of our website with your profile there.

We use, in particular:

12. Website Extensions

We use extensions for our website to be able to use additional functions. We can use selected services from suitable providers or use such extensions on our own server infrastructure.

We use, in particular:

  • Google reCAPTCHA: Spam protection (differentiation between desired content from humans and unwanted content from bots and spam); Provider: Google; Google reCAPTCHA-specific information: "What is reCAPTCHA?".

13. Success and Reach Measurement

We attempt to determine how our online offer is used. In this context, for example, we can measure the success and reach of our activities and operations as well as the impact of third-party links on our website. We can also test and compare how different parts or versions of our online offer are used ("A/B testing" method). Based on the results of the success and reach measurement, we can, in particular, fix errors, enhance popular content, or make improvements to our online offer.

For success and reach measurement, the IP addresses of individual users are stored in most cases. IP addresses are generally shortened ("IP masking") in this case to follow the principle of data minimization through the corresponding pseudonymization.

For success and reach measurement, cookies may be used, and user profiles created. Possible user profiles include, for example, visited individual pages or viewed content on our website, information about the size of the screen or browser window, and the - at least approximate - location. Generally, any user profiles are created exclusively in a pseudonymized form and not used for the identification of individual users. Individual services from third parties, where users are logged in, may possibly associate the use of our online offer with the user account or user profile at the respective service.

We use, in particular:

  • Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: Measurement across different browsers and devices (Cross-Device Tracking) as well as with pseudonymized IP addresses, which are only exceptionally transmitted fully to Google in the USA, "Privacy", "Browser Add-on for Disabling Google Analytics".
  • Google Tag Manager: Integration and management of other services for success and reach measurement as well as other services from Google and third parties; Provider: Google; Google Tag Manager-specific information: "Data collected by Google Tag Manager"; further privacy information can be found at the individual integrated and managed services.

14. Final Provisions

We have created this Privacy Policy with the Privacy Policy Generator from Datenschutzpartner. The present privacy policy is an unofficial translation from the original German version.

We can adjust and supplement this Privacy Policy at any time. We will inform about such adjustments and supplements in a suitable manner, in particular by publishing the current Privacy Policy on our website.