We are subject to Swiss data protection law and, where applicable, foreign data protection law, such as the General Data Protection Regulation (GDPR) of the European Union (EU). The European Commission recognizes that Swiss data protection law provides adequate data protection.
1. Contact Information
Responsibility for the processing of personal data:
Brigels Resort AG
Via Plaun Rueun 44
We will inform you if there are other responsible parties for the processing of personal data in individual cases.
1.1 Data Protection Officer
We have the following data protection officer as a contact person for affected individuals and as a point of contact for supervisory authorities regarding data protection inquiries:
Brigels Resort AG
Via Plaun Rueun 44
1.2 Data Protection Representative in the European Economic Area (EEA)
We have the following data protection representative according to Art. 27 GDPR. The data protection representative serves as an additional point of contact for supervisory authorities and affected individuals in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the General Data Protection Regulation (GDPR):
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
2. Terms and Legal Basis
Personal data refers to any information relating to an identified or identifiable individual. An affected person is an individual whose personal data is processed.
Processing includes any handling of personal data, regardless of the means and methods used, including storing, disclosing, acquiring, collecting, deleting, storing, altering, 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 the processing of personal data.
2.2 Legal Basis
We process personal data – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – based on at least one of the following legal bases:
- Art. 6(1)(b) GDPR for the necessary processing of personal data to fulfill a contract with the data subject or to carry out pre-contractual measures.
- Art. 6(1)(f) GDPR for the necessary processing of personal data to protect our legitimate interests or the legitimate interests of third parties, unless the fundamental rights and freedoms of the data subject outweigh those interests. Legitimate interests include, in particular, our interest in conducting our activities and operations in a sustainable, user-friendly, secure, and reliable manner and being able to communicate about them, ensuring information security, protecting against misuse, enforcing our legal claims, and complying with Swiss law.
- Art. 6(1)(c) GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law
- Art. 6 (1) lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 (1) lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 (1) lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.
3. Article, Scope, and Purpose
We process personal data that is necessary to carry out our activities and operations permanently, in a user-friendly, secure, and reliable manner. Such personal data may include categories of inventory and contact data, browser and device data, content data, metadata, and 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(s) or as required by law. Personal data that is no longer necessary for processing will be anonymized or deleted.
We may have third parties process personal data on our behalf. We may also jointly process or disclose personal data to third parties. Such third parties are primarily specialized service providers whose services we utilize. We ensure data protection with these third parties as well.
We only process personal data with the consent of the data subject unless processing is permitted for other legal reasons. Processing without consent may be permissible, for example, to fulfill a contract with the data subject and for related pre-contractual measures, to safeguard our overriding legitimate interests when processing is evident from the circumstances, or after prior notification.
In this context, we particularly process information voluntarily provided by the data subject when contacting us, for example, via postal mail, email, instant messaging, contact forms, social media, or telephone, or when registering for a user account. We may store such information, for example, in an address book, customer relationship management system (CRM system), or similar tools. When we receive data about other individuals from third parties, the transmitting parties are obliged to ensure data protection for these individuals and ensure the accuracy of their personal data.
Furthermore, we process personal data that we receive from third parties, obtain from publicly accessible sources, or collect during the exercise of our activities and operations, to the extent and as permitted by legal reasons.
4. 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 countries, particularly for processing or having them processed there.
We may export personal data to all countries and territories on Earth and elsewhere in the universe, provided that, according to the assessment of the Swiss Federal Data Protection and Information Commissioner (FDPIC) or based on a decision by the Swiss Federal Council, the local law ensures adequate data protection and, where applicable, based on a decision by the European Commission, ensures adequate data protection in accordance with the General Data Protection Regulation (GDPR).
We may transmit personal data to countries whose laws do not ensure adequate data protection, provided that data protection is guaranteed for other reasons, in particular based on standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, such as obtaining the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. Upon request, we are happy to provide individuals with information about any guarantees or provide a copy of such guarantees.
5. Rights of Data Subjects
Data subjects, whose personal data we process, have rights according to Swiss data protection law. These rights include the right to information as well as the right to rectification, erasure, or blocking of the processed personal data.
Data subjects, whose personal data we process, can, if the General Data Protection Regulation (GDPR) is applicable, request free confirmation of whether we process personal data concerning them. In this case, data subjects can request information about the processing of their personal data, restrict the processing of their personal data, exercise their right to data portability, and have their personal data corrected, deleted ("right to be forgotten"), blocked, or completed.
Data subjects, whose personal data we process, can, if the GDPR is applicable, revoke their given consent at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects, whose personal data we process, have the right to lodge a complaint with a competent supervisory authority. The Federal Data Protection and Information Commissioner (FDPIC) is the supervisory authority for data protection in Switzerland.
6. Data Security
We implement appropriate technical and organizational measures to ensure data security that is appropriate to the respective risks. However, we cannot guarantee absolute data security.
Access to our website is secured using transport encryption (SSL/TLS, particularly with the Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers indicate transport encryption with a padlock icon in the address bar.
Our digital communication, like any digital communication in general, is subject to mass surveillance without cause or suspicion, as well as other forms of surveillance by security authorities in Switzerland, other parts of Europe, the United States of America (USA), and other countries. We have no direct control over the processing of personal data by intelligence agencies, police authorities, and other security agencies.
7. Use of the Website
Cookies can be stored in the browser temporarily as "session cookies" or for a specific period as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies allow, in particular, the recognition of a browser during the next visit to our website, thereby measuring the reach of our website, for example. However, permanent cookies can also be used for online marketing purposes.
For cookies used for performance and reach measurement or advertising, a general opt-out is possible for numerous services through 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).
7.2 Server Log Files
For each access to our website, we may record the following information if it is transmitted from your browser to our server infrastructure or can be determined by our web server: date and time, including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system, including user interface and version, browser, including language and version, accessed individual sub-page of our website, including the amount of data transferred, and the last visited website in the same browser window (referrer).
We store such information, which may also include personal data, in server log files. This information is necessary to provide our website permanently, in a user-friendly and reliable manner, and to ensure data security and particularly the protection of personal data, including by third parties or with the assistance of third parties.
7.3 Tracking Pixels
We may use tracking pixels, also known as web beacons, on our website. Tracking pixels, including those from third parties whose services we use, are small, usually invisible images that are automatically retrieved when visiting our website. Tracking pixels can capture the same information as server log files.
8. Notifications and Communications
We send notifications and communications via email and other communication channels such as instant messaging or SMS.
8.1 Success and Reach Measurement
Notifications and communications may contain web links or tracking pixels that capture whether an individual notification has been opened and which web links have been clicked. Such web links and tracking pixels may also capture the personal usage of notifications and communications. We require this statistical measurement of usage for success and reach measurement in order to effectively and user-friendly send notifications and communications based on the needs and reading habits of the recipients, as well as to provide them permanently, securely, and reliably.
8.2 Consent and Objection
You must generally provide explicit consent for the use of your email address and other contact addresses unless the use is permissible for other legal reasons. For obtaining consent, we strive to use the "double opt-in" procedure, which means you will receive an email with a web link that you must click to confirm, thereby preventing misuse by unauthorized third parties. For evidentiary and security purposes, we may log such consent, including the Internet Protocol (IP) address, date, and time.
You can generally object to receiving notifications and communications, such as newsletters, at any time. By raising such an objection, you can simultaneously object to the statistical measurement of usage for success and reach measurement. However, necessary notifications and communications related to our activities and operations remain unaffected.
8.3 Service Providers for Notifications and Communications
We send notifications and communications with the help of specialized service providers.
We primarily use:
9. Social Media
We maintain a presence on social media platforms and other online platforms to communicate with interested individuals and provide information about our activities and operations. In connection with such platforms, personal data may be processed outside of Switzerland and the European Economic Area (EEA).
For our social media presence on Facebook, including the so-called Page Insights, we are jointly responsible – to the extent the General Data Protection Regulation (GDPR) is applicable – with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to effectively and user-friendly provide our social media presence on Facebook.
10. Third-Party Services
We use services provided by specialized third parties to carry out our activities and operations permanently, user-friendly, securely, and reliably. Such services enable us to embed functions and content into our website. In the case of such embedding, the services used, for technical reasons, temporarily collect at least the internet protocol (IP) addresses of the users.
For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized form. This may include performance or usage data to provide the respective service.
We primarily use:
10.1 Digital Infrastructure
We use services provided by specialized third parties to utilize the necessary digital infrastructure related to our activities and operations. This includes hosting and storage services from selected providers.
10.2 Audio and Video Conferences
Depending on your circumstances, we recommend muting the microphone by default and blurring the background or using a virtual background during audio and video conferences.
We primarily use:
- Google Meet: Video conferences; Provider: Google; Specific information about Google Meet: "Google Meet - Security and Privacy for Users"
- Microsoft Teams: Platform for audio and video conferences among other features; Provider: Microsoft; Specific information about Teams: "Privacy and Microsoft Teams"
10.3 Mapping Data
We utilize services from third parties to embed maps into our website.
We primarily use:
- Google Maps, including Google Maps Platform: Mapping service; Provider: Google; Specific information about Google Maps: "How Google Uses Location Information"
10.4 Digital Audio and Video Content
We use services provided by specialized third parties to enable the direct playback of digital audio and video content, such as music or podcasts.
We primarily use:
- YouTube: Video platform; Provider: Google; Specific information about YouTube: "Privacy and Security Center", "My Data on YouTube"
We use services from third parties to embed selected fonts as well as icons, logos, and symbols into our website.
We primarily use:
We take advantage of the opportunity to display targeted advertisements for our activities and operations through third-party platforms such as social media platforms and search engines.
Through such advertising, our goal is to reach individuals who are already interested in or may be interested in our activities and operations (remarketing and targeting). To achieve this, we may provide relevant information, potentially including personal data, to third parties that enable such advertising. Additionally, we may track the success of our advertisements, particularly whether they lead to visits to our website (conversion tracking).
Third parties on which we advertise, and where you are logged in as a user, may associate your use of our online offering with your respective profile.
We primarily use:
- Google Ads: Search engine advertising; Provider: Google; Specific information about Google Ads: Advertising based on search queries, where various domain names, particularly doubleclick.net, googleadservices.com, and googlesyndication.com, are used for Google Ads, "Advertising" (Google), "Why am I seeing this ad?"
11. Website Extensions
We use extensions for our website to enable additional functionalities.
We primarily use:
- Google reCAPTCHA: Spam protection (distinguishing between desired comments from humans and undesired comments from bots or spam); Provider: Google; Specific information about Google reCAPTCHA: "What is reCAPTCHA?"
12. Success and Reach Measurement
We utilize services and programs to determine how our online offering is used. Within this framework, we can measure the success and reach of our activities and operations, as well as the impact of third-party links to our website. We may also experiment and compare the usage of different versions of our online offering or parts of our online offering using the "A/B testing" method. Based on the results of success and reach measurement, we can address errors, strengthen popular content, or make improvements to our online offering.
When using services and programs for success and reach measurement, individual users' internet protocol (IP) addresses need to be stored. IP addresses are generally truncated ("IP masking") to comply with the principle of data minimization through pseudonymization and thereby enhance the privacy of users.
When using services and programs for success and reach measurement, cookies may be used, and user profiles may be created. User profiles may include visited pages or viewed content on our website, information about screen size or browser window, and—at least approximately—location. User profiles are generally created in a pseudonymized manner. We do not use user profiles to identify individual users. However, certain third-party services where users are logged in may potentially associate the usage of our online offering with the user's account or profile on the respective service.
We primarily use:
- Google Analytics: Success and reach measurement; Provider: Google; Specific information about Google Analytics: Measurement across different browsers and devices (cross-device tracking) and with pseudonymized internet protocol (IP) addresses, which are only transmitted to Google in the USA in exceptional cases, "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 additional services from Google and third parties; Provider: Google; Specific information about Google Tag Manager: "Data Collected by Google Tag Manager"; further privacy information can be found for each integrated and managed service
13. Final Provisions