Valid from August 31, 2023
We, SWISS HOTEL PROPERTIES SA, located in Interlaken, Switzerland, are committed to protecting your privacy and continuously improving the services we provide to you.
This Information Security and Privacy Statement applies to the website www.shp.net.
We are subject to Swiss and, where applicable, international regulations. Accordingly, we observe internationally recognized principles to ensure data protection and data security. This declaration informs you in particular about how we collect personal data that becomes available to us via the website, for what purposes it is used, to whom it may be disclosed and what your rights are in connection with the use of your personal data by us.
If you do not agree with this statement, do not access the website or use our services and products.
Who is responsible for your personal data
Personal data is any information relating to an identified or identifiable natural or legal person, e.g. surname, first name, address, e-mail, date of birth in combination with postal code or telephone number.
The responsible party in terms of data protection legislation is SWISS HOTEL PROPERTIES SA, Höheweg 39-49, 3800 Interlaken, e-mail: firstname.lastname@example.org
How we process personal data
Which personal data we collect for which processing purposes
Personal data automatically transmitted via the use of the portal
SWISS HOTEL PROPERTIES SA collects and stores information that your browser automatically transmits to us in „server log files“ when you visit our website. The data collection is based on your will and interest to visit our website and our legitimate interests to operate the website. These may include the following data:
· Browser type and version;
· Operating systems used;
· Referrer URL (the previously visited website);
· Host name of the accessing computer;
· Date and time of the server request;
· Internet Protocol (IP) address;
· Amount of data transferred;
· Other similar data and information that serve to avert danger in the event of attacks on our IT systems.
This personal data is not merged with other personal data and is stored separately from any other personal data transmitted by the user. They are deleted by us after three months at the latest.
SWISS HOTEL PROPERTIES SA uses the personal data collected automatically to fulfill the following purposes:
· to enable the display, operation and functionality of the portal;
· Ensure the stability and security of the system;
· to improve and protect our services;
· for statistical purposes in the event of attacks on the network infrastructure on which the web site is provided.
Personal data that the user transmits to us
SWISS HOTEL PROPERTIES SA collects and processes personal data that the user voluntarily submits to us by means of an online form directly on the website, via our contact e-mail address, via any other applications linked to the portal, by telephone or in any other way. This information includes, for example, the following personal data:
· Surnames, first names, postal addresses, e-mail address, telephone number, date of birth, gender;
· Your message or request.
The provision of this personal data is expressly on a voluntary basis. Without this personal data, however, we will not be able to provide the services requested by the user in the desired quality or at all.
SWISS HOTEL PROPERTIES SA uses the personal data provided by the user to fulfill the following purposes:
· To provide, maintain, protect and optimize the services and information offered;
· communicate with you and provide you with the best possible and personalized information you need from us (e.g., about our products and services);
· to offer you new services and information and, based on your profile, to suggest services and information tailored to you that may be of interest to you;
· to comply with legal or other regulatory requirements and internal regulations;
· To establish, exercise and/or defend actual or potential legal claims, investigations or similar proceedings;
· for other lawful purposes, if this processing results from the circumstances or was indicated at the time of collection.
On what legal basis do we process personal data about you
The processing of this personal data is based on the following legal bases:
· Your consent, only if it can be revoked at any time (e.g. when you sign up for our newsletter and other marketing communications);
· for the fulfillment of a contract with you or for the intention to enter into a contract with you;
· to comply with a legal obligation (e.g. for tax reasons or for the purpose of judicial investigations or proceedings) or
· To protect our legitimate interests (e.g., protection and security of our services, systems, assets; compliance with legal, regulatory and contractual obligations; assertion, exercise or defense of legal claims; maintenance and efficient organization of business operations; improvement and development of our services; and sale and marketing of our services).
If the processing is based on your consent or our legitimate interests, you can withdraw your consent or object to this processing at any time by contacting us directly at email@example.com. Please note, however, that the withdrawal of your consent does not affect the lawfulness of the processing based on the consent prior to its withdrawal.
With whom we share your personal data
SWISS HOTEL PROPERTIES SA takes the necessary measures to ensure that only our authorized personnel and our auxiliary persons who have the necessary knowledge have access to your personal data in order to fulfill the purposes for which your personal data was collected.
We may disclose your personal data to the following possible categories of recipients in accordance with the purposes and legal bases of processing described above, to the extent necessary for the intended data processing:
· Service providers who process personal data on behalf of and at the instruction of SWISS HOTEL PROPERTIES SA (so-called order processors, such as in the areas of IT, hosting and support);
· Customers, partners, suppliers, insurance companies and other business partners;
· marketing agencies, the public, including visitors to the Group’s websites and social media;
· Industry organizations, associations and other bodies;
· Acquirers or parties interested in acquiring business units, companies or other parts of the Group;
· Courts, arbitration boards, law enforcement agencies, regulatory agencies, attorneys, and other parties in potential or actual legal proceedings when necessary to comply with law or to establish, exercise, or defend rights or legal claims.
We select our partners and order processors carefully and only with sufficient assurance that they have appropriate technical and organizational measures in place in accordance with legal requirements. Our order processors can only process personal data upon documented instructions from us. They are all subject to confidentiality requirements and may only use your personal data to the extent necessary to fulfill the purpose for which your personal data was collected, unless otherwise required by law.
Transfer of personal data to countries outside the EEA
When data is transferred to countries that do not ensure an adequate level of protection, we ensure adequate data protection by taking appropriate safeguards, such as
· contractual guarantees (e.g., based on EU standard clauses),
· based on binding corporate rules,
· the transmission of data in accordance with your express consent,
· for the conclusion or performance of a contract with you, or
· in connection with the establishment, exercise or enforcement of legal claims.
For more information about our reasonable security precautions, please contact us by email at firstname.lastname@example.org.
How long we keep information about you
In principle, personal data is deleted as soon as it is no longer required to achieve the purpose for which it was collected, unless longer retention is necessary to fulfill legal obligations (e.g., retention and documentation obligations), contractual or pre-contractual obligations or legitimate business interests of us (e.g., to assert, exercise or defend legal claims).
On this basis, we usually process personal data in compliance with the following rules and obligations:
· The personal data automatically transmitted by you through the use of our website for the purpose of displaying, operating and ensuring the functionality of the portal will be deleted within three months.
· The personal data you provide to us in connection with the use of our services and products offered on our portal or which you otherwise provide to us via the e-mail contact address will generally be stored by us until you request us to delete it, revoke your consent to its storage or the purpose for storing the data no longer applies (e.g. after processing of your inquiry has been completed).
· For contract-related Personal Data (including business records and communications), we retain Personal Data for as long as the contractual relationship exists and thereafter for ten additional years after termination of the contractual relationship, unless (i) a shorter or longer legal retention period applies in an individual case, (ii) retention is required for evidentiary or other good cause under applicable law, or (iii) deletion of the data is required sooner (e.g., because the data is no longer needed or we must delete the relevant data).
Depending on their function and purpose, the cookies we use can be divided into the following categories: Functional Cookies, Performance Cookies and Advertising Cookies. This website only uses functional cookies. These cookies serve a variety of purposes for the presentation, functionality and performance of a website and, in particular, to improve visitors‘ experience and enjoyment of the website. They allow a website to remember information already provided (e.g. username, location or language selection) and provide visitors with enhanced, more personalised functionality. Functional cookies are used, for example, to remember things like your login details. These cookies cannot track your movement on other websites.
You can configure your browser settings so that no cookies are stored on your computer. Complete deactivation of cookies may mean that you cannot use all the functions of our website.
Using the contact form
You have the possibility to contact us via contact form. For this we usually need the following information:
· First name
· Last name
· Phone number
· City and country
We use this data only to inform you about news, as requested. The processing of this data is therefore necessary within the meaning of Art. 6 para. 1 lit. b GDPR for the implementation of pre-contractual measures or is in our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.
No automated decisions including profiling with legal effect
We will not make any decision about you which is based solely on automated processing – including profiling – and which produces legal effects concerning you or similarly significantly affects you.
SWISS HOTEL PROPERTIES SA has implemented organizational and technical measures to maintain the security of personal data and to protect it against unauthorized or unlawful processing, accidental loss, alteration, disclosure or access.
SWISS HOTEL PROPERTIES SA may use third parties as data processors to collect and process your personal data. The data processors we engage will only process your personal data in accordance with our instructions and are required by law to take strict security precautions when handling personal data.
Unfortunately, the transmission of information over the Internet is not completely secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. For this reason, you are always free to submit your personal information to us by other means, such as by telephone or by mail. Once we have received your data, we apply strict procedures and stringent security measures to prevent unauthorized access.
Third-party privacy statements
Our website is not intended for children, and we do not knowingly collect Personal Information from children under the age of 16 unless we have the express consent of their parents. If we are notified or otherwise learn that personal information of a child under 16 has been improperly collected, we will take all reasonable steps to delete that personal information.
What are your rights
You can request information from SWISS HOTEL PROPERTIES SA, with proof of your identity, as to whether personal data about you is being processed. In addition, you have the right to request the correction, destruction or restriction of personal data about yourself, as well as to object to the processing of your personal data. If the processing is based on your consent or our legitimate interests, you may withdraw your consent or object to this processing at any time by contacting us directly by email at email@example.com. In certain cases, you have the right to receive personal data generated by the use of online services in a structured, common and machine-readable format, so that further use and transmission to any third-party provider is possible.
Requests in this regard should be addressed to SWISS HOTEL PROPERTIES SA via the following e-mail address: firstname.lastname@example.org. SWISS HOTEL PROPERTIES SA reserves the right to limit your rights under applicable law and, for example, not to disclose comprehensive information or to delete personal data. Please note that even after a request to delete your personal data, we must retain it in whole or in part within the scope of legal and contractual retention obligations. Deletion of your personal data may result in you no longer being able to use our services.
If we reject your request or if you are not satisfied with our processing, you are also entitled to file a complaint with the competent supervisory authority and to lodge an appeal with the competent authority. The competent authority is the Federal Data Protection and Information Commissioner (FDPIC) in Bern: http://www.edoeb.admin.ch
Swiss Hotel Properties SA
SWISS HOTEL PROPERTIES SA reserves the right to adapt, supplement or otherwise change this personal data protection statement at any time and without stating reasons. The current personal data protection statement as published on the website shall apply.
Version: August 31, 2023