1. Name and contact details of the officer responsible for the data processing, as well as the company’s Data Privacy Officer
This data privacy information applies to the data processing by:
R & S Hotelbetriebsgesellschaft mbH,
Telephone: +49 (0) 30 7901260
Obligatory information on the officer responsible for the data processing according to Art. 37 (7) of the General Data Protection Regulation (GDPR)
Spirit Legal LLP Lawyers
Lawyer and Data Protection Officer
Contact via encrypted online form:
2. Gathering and storage of personal data, as well as the nature and purpose of its use
a) When visiting the website
When you access our website www.amanogroup.de, information will automatically be transmitted to our website’s server by the browser used on your terminal. This information will be temporarily saved in a log file. The following information will, in the process, be recorded without your involvement, and saved until it is deleted automatically:
- IP address of the computer transmitting the query;
- date and time of access;
- name and URL of the file accessed;
- website from which our site is accessed (referring URL);
- browser used and, if applicable, the operating system of your computer, as well the name of your access provider.
the aforementioned data will be processed by us for the following purposes:
- ensuring that the website is enabled to establish the connection smoothly;
- ensuring convenient use of our website;
- evaluating the system security and stability; and
- for further administrative purposes.
The legal basis for the data processing is Art. 6(1)(1)(f) GDPR. Our justified interest arises from the purposes for gathering data listed above. Under no circumstances will we use the data gathered for the purpose of drawing conclusions regarding your identity.
We moreover place cookies, as well as analysis services, when you visit our website. You can find further details about this in Clauses 4 and 5 of this Data Privacy Statement.
b) When subscribing to our newsletter
In so far as you have explicitly given your consent, pursuant to Art. 6(1)(1)(a) GDPR, we use your e-mail address to send you our newsletter regularly. Giving an e-mail address is sufficient for receiving the newsletter.
It is possible to unsubscribe at any time, for example via a link at the end of each newsletter. Alternatively, you can certainly also send your request to unsubscribe to email@example.com by e-mail at any time.
If you book a room with us, we gather and process the following data, which is necessary for mutual proper contractual fulfilment. The latter includes:
- Form of address:
- Christian name and surname
- Address, street and town
- Date of birth
- Telephone number
- E-mail address
- Data for processing the payment (e.g. credit card number)
The data processing for the purpose of making the booking is performed in accordance with Art. 6(1)(1)(a) GDPR based on your consent given voluntarily, as well as in accordance with Art. 6(1)(1)(a) GDPR for fulfilling the contract.
3. The passing on of data
Your personal data is not transmitted to third parties for purposes other than the purposes listed below.
We only pass on your personal data to third parties if:
- You have granted your express consent to the latter pursuant to Art. 6(1)(1)(a) GDPR;
- pursuant to Art. 6(1)(1)(f ) GDPR, it is necessary to pass it on in order to assert, exercise or defend legal claims and no reason exists to assume that you have an overwhelming interest, worthy of protection, in your data not being passed on;
- in the event that a statutory obligation to pass on the data exists pursuant to Art. 6(1)(1)(c) GDPR; and
- this is statutorily admissible and, under Art. 6(1)(1)(b) GDPR, is necessary in order to handle contractual relations with you.
We deploy cookies on our website. These are small files that your browser creates automatically and which are stored on your terminal (laptop, tablet, smartphone, etc.) if you visit our website. Cookies do not do any harm to your terminal, and do not contain any viruses, Trojan horses or other malware.
Information which emerges in connection with the respective specific terminal used is stored in the cookie. This does not, however, mean that we are thereby made directly aware of your identity.
In order to optimise usability, we also set temporary cookies, that are stored on your terminal for a certain pre-defined period of time. If you visit our website again, to make use of our services, it is automatically recognised that you have already visited us, as well as what data you entered and settings you selected, so that you do not have to enter them all over again.
Secondly, we set cookies to record statistics on the use of our website, and for the purpose of evaluating your use of our website in order to optimise our services for you (see Clause 5). These cookies enable us to automatically recognise that you have already previously visited us when you visit our website again. These cookies are automatically deleted after a certain pre-defined period of time.
The data processed by the cookies is required for the purposes mentioned, in order to preserve our justified interests, as well as those of third parties pursuant to Art. 6(1)(1)(f) GDPR.
Most browsers accept cookies automatically. You may, however, configure your browser in such a way that no cookies are stored on your computer, or that a notice always appears before a new cookie is created. Completely deactivating cookies may, however, lead to you not being able to use all the functions of our website.
5. Analysis tools
The tracking steps listed by us below and deployed by us are carried out based on Art. 6(1)(1)(f) GDPR. With the tracking measures deployed, we wish to ensure that our website is designed in line with our customers’ needs and also ensure ongoing optimisation of it. Secondly, we deploy the tracking steps in order to record statistics on the use of our website, and for the purpose of evaluating your use of our website in order to optimise our services for you. These interests are to be deemed justified in the sense of the foregoing provision.
The respective data processing purposes and data categories can be inferred from the corresponding tracking tools.
a) Google Analytics
In order to design our web pages in line with customer requirements, and to ensure that our web pages are optimised on an ongoing basis, we use Google Analytics, a web analysis service of Google Inc. (hereinafter referred to as “Google”). This involves pseudonymised usage profiles being created, and cookies deployed (see Clause 4). The information generated by the cookie on your use of this website, such as
- browser type/version;
- operating system used;
- referring URL (the page visited previously);
- host name of the accessing PC (IP address);
- time of the server query.
will be transmitted to a server of Google in the USA and stored there. The information will be used to evaluate use of the website, compile reports on the website activities, and provide further services associated with the use of the website and the Internet for market research purposes and to design these web pages in line with user requirements. This information may also be transmitted to third parties, in so far as such is required by law or if third parties process such data by order. Your IP address will never be merged with other data of Google. The IP addresses are anonymised, making it impossible to identify them (IP masking).
You can prevent the installation of cookies by setting your browser accordingly, however we would like to point out that, in that case, you may not be able to use all the functions of this website in their entirety.
You may, moreover, prevent the data generated by the cookie which relates to your use of the website (incl. your IP address) from being recorded, as well as the processing of such data by Google, by downloading and installing a browser add-on available at the following link
As an alternative to the browser add-on, in particular in the case of browsers on mobile terminals, you may additionally prevent your data from being recorded by Google Analytics by clicking on this link. An opt-out cookie is placed, which prevents your data from being recorded when visiting this website in future. The opt-out cookie only takes effect in this browser, and only when visiting our website, and will be stored on your device. If you delete the cookies in this browser, you need to re-set the opt-out cookie.
You can find further information on data privacy in connection with Google Analytics, for instance in the Google Analytics Help at the following link .
b) DoubleClick by Google
By using our web pages, you declare that you are in agreement with the processing of the data gathered about you by Google and the manner of data processing described above, as well as the purpose specified. You may prevent cookies being stored by setting your browser software accordingly. We would like to point out to you, however, that, in this case, you may not necessarily be able to use all functions of our web pages in their entirety. You can, furthermore, prevent the data generated by the cookies which relates to your use of the web pages from being recorded by Google, as well as the processing of such data by Google, by downloading and installing the browser plug-in available at the following link by selecting the corresponding option under the menu item DoubleClick Deactivation Plug-In. Alternatively you can deactivate the DoubleClick cookies on the website of the Digital Advertising Alliance, using the following link .
c) Google Tag Manager
This website uses Google Tag Manager. Google Tag Manager is a solution with which marketing website tags can be administered via an interface. The tool Tag Manager itself (which implements the tags) is a cookie-less domain and does not gather any personal data. The tool ensures that the deployment of other tags is triggered, which, for their part, gather data in certain circumstances. Google Tag Manager does not access such data. If a deactivation has been undertaken at domain or cookie level, it continues in force for all tracking tags that are implemented using Google Tag Manager.
d) Google Adwords Conversion Tracking
To statistically record the use of our website and to evaluate it for the purpose of optimizing our website, we also use Google conversion tracking. In doing so, Google Adwords will set a cookie (see section 4) on your computer if you have reached our website via a Google ad.
These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer’s website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page.
Each user receives a different cookie. Cookies can not be tracked through the websites of Adwords customers. The information gathered using the conversion cookie is used to generate conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers can see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive information that personally identifies users.
6. Social media plug-ins
Based on Art. 6(1)(1)(f) GDPR, we set social plug-ins on our website of the social networks Facebook, Twitter and Instagram, in order to make our hotels more well known in this way. The commercial purpose behind that is to be deemed a justified interest within the meaning of the GDPR. The responsibility for operating the hotels in line with data privacy regulations is to be guaranteed by their respective providers.
Social media plug-ins of Facebook are deployed on our website, in order to design the use of it in a more personal way.
Whenever you access a page on our website that contains one of these plug-ins, your browser establishes a direct connection to Facebook’s servers. The content of the plug-in is transmitted by Facebook directly to your browser and integrated by the latter into the web page. Integrating the plug-in sends information to Facebook indicating that you have accessed the corresponding page on our website, even if you do not have a Facebook account or are not logged into Facebook just now. Such information (including your IP address) is transmitted directly by your browser to one of Facebook’s servers in the USA where it is saved.
When you visit our website and are logged into Facebook at the same time, this enables to Facebook to link information about your visit to your Facebook account. Whenever you interact with the plug-ins, for example by pressing the “LIKE” or “SHARE” button, the corresponding information is likewise transmitted directly to one of Facebook’s servers, and stored there. In addition, the information is published on Facebook, and shown to your Facebook friends.
Facebook may use this information for the purposes of advertising, market research and designing the Facebook pages in line with users’ requirements. Usage, interest and relationship profiles are created by Facebook for this purpose, e.g. in order to evaluate your use of our website in regard to the advertisements shown to you on Facebook, to inform other Facebook users about your activities on our website, and to provide further services connected with the use of Facebook.
If you would prefer Facebook not to allocate the data gathered via our website to your Facebook account, you need to log out of Facebook prior to visiting our website.
Please infer the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your rights in this respect and the configuration options for protecting your private sphere from the data privacy policies of Facebook at the following link .
Plug-ins of the short message network of Twitter Inc. (hereinafter referred to as “Twitter”) are integrated into our website. You can recognise the Twitter plug-ins (“Tweet button”) by the Twitter logo on our website. You can find an overview of Tweet buttons here .
When you visit a page of our website containing such a plug-in, a direct connection is established between your web browser and the Twitter server. Twitter thereby receives the information that you have visited our website with your IP address. If you click on the Twitter “Tweet button” while you are logged into your Twitter account, you can link the content of our pages to your Twitter profile. Twitter can thereby allocate the visit to our pages to your user account. We are pointing out that we, as the provider of the pages, are not made aware of the content of the data transmitted or its use by Twitter.
If you do not wish Twitter to be able to allocate your visit to our pages to your Twitter account, please log out of your Twitter user account.
Social plug-ins (“plug-ins”) of Instagram are also used on our website, and are operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (hereinafter referred to as “Instagram”)
The plug-ins are designated with an Instagram logo, in the form of an “Instagram camera”, for example.
Whenever you access a page on our website that contains such a plug-in, your browser establishes a direct link to Instagram’s servers. The plug-in content is transmitted by Instagram directly to your browser and is integrated into the web page. As a result of this integration, Instagram receives the information that your browser has accessed the corresponding page on our website, even if you do not have an Instagram profile or are not logged into Instagram just now.
This information (including your IP address) is transmitted directly by your browser to one of Instagram’s servers in the USA and stored there. If you are logged into Instagram, Instagram can allocate the visit to our website directly to your Instagram account. Whenever you interact with the plug-ins, for example by pressing the “Instagram” button, this information is likewise transmitted directly to one of Instagram’s servers, and stored there.
In addition, the information is published in your Instagram account, and shown to your contacts there.
If you prefer Instagram not to allocate information about the data gathered via our website directly to your Instagram account, you need to log out of Instagram prior to visiting our website.
7. Rights of data subjects
You have the right:
- pursuant to Art. 15 GDPR, to request information about your personal data processed by us. You can in particular request information about the purposes of the processing, the category of personal data, the category of recipients to who your data has been or will be disclosed, the scheduled duration of storage, the existence of a right of correction, deletion, limitation of the processing or opposition, the existence of a right of appeal, the origin of your data, in so far as it was not gathered by us, and also the existence of automated decision-making, including profiling and any meaningful information on the details of the latter;
- pursuant to Art. 16 GDPR, request the immediate correction of incorrect data or completion of your personal data stored with us;
- pursuant to Art. 17 GDPR, request the deletion of your personal data stored with us, unless the processing is necessary in order to exercise the right of freedom of expression, and information for fulfilling a legal obligation, on grounds of the public interest or in order to assert, exercise or defend legal claims;
- pursuant to Art. 18 GDPR, request that the processing of your personal data be limited, in so far as the accuracy of the data is disputed by you, the processing is illegitimate, however you refuse to have it deleted and we no longer need the data, however you need it to assert, exercise or defend legal claims or you have filed an opposition against the processing under Art. 21 GDPR;
- pursuant to Art. 20 GDPR, to obtain your personal data that you have provided us with in a structured, common and machine-readable format, or to request the transmission of it to another officer responsible for data processing;
- pursuant to Art. 7(3) GDPR, to revoke your consent, previously granted to us, at any time. The consequence of this is that we can no longer, in the future, continue the data processing that was based on such consent; and
- pursuant to Art. 77 GDPR, complain to a supervisory authority. You can usually, for this purpose, contact the supervisory authority at your usual place of residence or place of work or our registered office.
8. The right of opposition
Should your personal data be processed on the basis of justified interests pursuant to Art. 6(1)(1)(f) GDPR, you are entitled, under Art. 21 GDPR, to file an opposition against the processing of your personal data, in so far as grounds exist for the latter which arise from your particular situation or the opposition is filed against direct advertising. In the latter case, you have a general right of opposition, which will be implemented by us without details of any special situation being required.
Should you wish to make use of your right of revocation or right of opposition, it is sufficient to send an e-mail to firstname.lastname@example.org
9. Data security
Within the context of the visit to our website, we use SSL (Secure Socket Layer) procedures in conjunction with the highest respective encryption level that is supported by your browser. This would generally be 256-bit encryption. Should your browser not support 256-bit encryption, we instead resort to 128-bit v3 technology. You can recognise whether an individual page of our website is transferred encrypted by the key or lock symbol being displayed in the lower status bar of your browser as closed.
In addition, we make use of suitable technical and organisational security measures to protect your data against incidental or intentional manipulation, partial or complete loss or destruction or against unauthorised access by third parties. The security procedures we deploy are regularly enhanced to reflect technological progress.
10. Topicality and amendment of this data privacy statement
This data privacy statement is currently valid and has the status of May 2018.
Through our website and services available via it being enhanced or due to altered statutory or official requirements, it may become necessary to amend this data privacy statement. The current respective data privacy statement can be accessed by you on the website at any time at https://www.amanogroup.de/en/privacy/ and printed out.