Privacy Policy

Valid from 1 April 2023

1. Scope

This privacy policy statement applies to the processing of personal data by (hereinafter collectively referred to as "Grächen"):

• Touristische Unternehmung Grächen AG
• TUG Gastro AG
• Verein Grächen und St. Niklaus Tourismus und Gewerbe

This privacy policy also covers the processing of personal data in connection with the website www.graechen.ch and at counters and sales points of Grächen.

This privacy policy statement applies as an integral part of the General Terms and Conditions (GTC) of Grächen and associated microsites, apps and social media sites.

This privacy policy takes into account the current legal requirements of the Swiss Federal Act on Data Protection (FADP), the Ordinance to the Federal Act on Data Protection (OFADP) and the legal requirements of the EU’s General Data Protection Regulation (GDPR).

2. Data collection via the website www.graechen.ch (as well as associated microsites)

2.1 Website visit

When visiting www.graechen.ch, each access is temporarily stored in a log file on a server. The following data is stored:

• IP address of the computer requesting access,
• date and time of the access,
• name and URL of the data retrieved,
• website from which our domain was accessed,
• operating system of your computer and the browser you used,
• country from which our website was accessed, and
• name of your internet provider.

Recording and processing of this data is generally carried out anonymously without reference to persons, and serves the purpose of enabling the use of the website (establishing a connection), ensuring system security and stability on a permanent basis and optimizing internet services, as well as internal statistical purposes. The aforementioned information is not referenced or stored with personal data.

Only in the event of an attack on the website's network infrastructure or in the event of suspected unauthorized or improper website use will the IP address be evaluated for the purpose of clarification and security and, if necessary, used in the context of criminal proceedings in order to identify and take civil and criminal action against the users concerned.

2.2 Event registrations

The website allows users to register for various events. The type of personal data recorded is dependent on the event. In the registration mask you will be informed as to which type of information is mandatory and which may be provided on a voluntary basis. The following data is regularly recorded:

• title
• first and last name
• E-mail address
• mailing address
• telephone number
• payment information
• allergies/intolerances

 

2.3. Booking accommodation

The website allows users to book accommodations offered by third parties (service providers). When booking accommodation, the following information is mandatory:

• title
• first and last name
• mailing address
• E-mail address
• telephone number
• country
• payment information

Please note that Grächen will forward the aforementioned information to the service provider in question in order to allow for the booking to be processed. The service provider will process your data in order to carry out the booking.

2.4. Booking packages

When booking a package deal, the following information is mandatory:

• title
• first and last name
• address, postal code, city
• E-mail address
• country
• telephone number
• last name, first name and birth date of other participants
• payment type and credit card information

Please note that Grächen will forward the aforementioned information to the involved service providers in order to allow for the booking to be processed. The service providers will process your data in order to carry out the booking.

2.5. Newsletter subscription

In order to receive the newsletter, truthful entry of the following personal data is required (* designates mandatory information):

• your E-mail address*
• title*
• first name*
• last name*
• optional: address

By subscribing to the newsletter, you expressly agree that Grächen may use your address and personal data for marketing campaigns, such as the delivery of the newsletter. You can unsubscribe from all marketing campaigns at any given time. You will find the contact details below in "Contacts". In addition, you will find an unsubscribe link in each of the newsletter emails.

Grächen is entitled to commission third parties with the technical processing of marketing campaigns and accordingly has the right to make your personal data available to third parties for this purpose. To send our newsletter, we use the email marketing service Mailchimp from The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA.

The Grächen newsletter may contain a so-called web beacon (tracking pixel) or similar technical tools. Web beacons are a non-visible graphic measuring 1 by 1 pixel which are associated with the user ID of the newsletter subscriber in question.

For every newsletter sent out, there is information regarding the used address file, the subject line, as well as the number of newsletters sent. Furthermore, it is possible to see which addresses have not yet received the newsletter, to which address it was sent and for which addresses the dispatch failed. In addition, there is information on the opening rate including information about which addresses have opened the newsletter. Finally, there is information on which addresses have unsubscribed. Grächen uses this data for statistical purposes and to optimize the newsletter in terms of content and structure. This enables Grächen to better tailor the information and offers in the newsletter to the individual interests of the recipients. The tracking pixel is deleted when you delete the newsletter.

To prevent the use of the web beacon in the newsletter, please configure your E-mail programs settings so as not to allow HTML to be displayed in messages, if this is not already the case by default.

2.6. Cookies

Grächen uses cookies. Cookies are information files which are automatically stored by your web browser on your computer’s hard drive whenever you visit a website. Cookies neither harm your computer’s hard drive nor do they transmit your personal data to us. Deactivating cookies may result in not all functionalities of the website being available to you.

2.7. Google Analytics

For the purpose of demand-oriented design and continuous optimization of the websites, Grächen uses the services of Google (Universal) Analytics, a web analytics service provided by Google Inc. (www.google.com). In this context, pseudonymized user profiles are created and small text files that are stored on your computer ("cookies") are used. The information generated by the cookie about your use of this website such as

• browser type/version
• operating system used
• referrer URL (the previously visited page)
• host name of the accessing computer (IP address)
• time of the server request
• device

is transmitted to servers of Google Inc, a company of the holding company Alphabet Inc, in the USA and stored there. In the process of doing so, the IP address is shortened by activating the IP anonymization ("anonymizeIP") on this website before transmission within the Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. The anonymized IP address transmitted by your browser as part of Google Analytics is not merged with other data from Google. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to website use and internet usage for the purposes of market research and demand-oriented design of these web sites. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of Google Inc. According to Google Inc., in no case will the IP address be associated with other data relating to the user.

Users can prevent the recording of the data generated by the cookie and related to website usage by the respective user (including the IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

As an alternative to the browser plugin, users can also click this link in order to prevent future tracking by Google Analytics on this website. This will result in an opt-out cookie being stored on the user’s end device. If users delete the cookies, the link will need to be clicked again.

Grächen draws your attention to the fact that the USA does not have a sufficient level of data protection from the point of view of the European Union. This is partially due to the topics mentioned in this section. Insofar as Grächen has explained in this privacy policy that recipients of data (such as Google) are based in the USA, Grächen will ensure either through contractual arrangements with these companies or by ensuring that these companies are certified under the EU-US Privacy Shield that your data is protected appropriately when it is with our partners.

2.8. Google Tag Manager

Google Tag Manager allows marketers to manage website tags via a user interface. The Tag Manager itself, which places the tags, works without the use of cookies and does not record any personal data. The Tag Manager ensures the dissolution of other tags that may be recording data. Corresponding statements for these third-party providers can be found in this privacy policy. Google Tag Manager does not use this data. In the event of users having deactivated cookies in some way, this deactivation will also apply to all tracking tags used by Google Tag Manager, meaning the tool will not change your cookie preferences.

Google may ask your permission to transmit some product data (e.g. your account information) to other Google products in order to activate certain functionalities, such as enabling the addition of new conversion tracking tags for Google Ads.  Furthermore, the Google developers occasionally verify information on product use in order to further optimize the product. However, Google will never transmit data of this type to other Google products without your permission.

2.9. Meta Pixel, Facebook Custom Audiences and Facebook Conversion

When using the website as well as the microsites, the so-called "Meta Pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used.

Thanks to the Meta Pixel, it is possible for Facebook to identify you, a visitor to our online offer, as being part of a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, Grächen uses the Meta Pixel to display the Facebook ads only to those Facebook users who have also shown an interest in Grächen's online offer or who display certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that Grächen transmits to Facebook (so-called "Custom Audiences"). With the help of the Meta Pixel, Grächen is looking to ensure that Facebook ads correspond to the potential interest of users and are not perceived as an annoyance. With the help of the Meta Pixel, Grächen can track the effectiveness of the Facebook ads for statistical and market research purposes, as it allows Grächen to see whether users were redirected after clicking on a meta ad on the website (so-called "conversion").

2.10. Facebook's Privacy Policy Statement

The processing of data by Facebook takes place within the scope of Facebook's data usage policy. Accordingly, general information on the display of Facebook ads can be found in the data usage policy of Facebook. Specific information and details about the Meta Pixel and how it works can be found in Facebook's help section.

2.11. EU-US Privacy Shield

Facebook is certified under the Privacy Shield Agreement and thereby guarantees compliance with European data protection legislation.

2.12. Right to objection

While Grächen has a justified interest in the use of the Meta Pixel and the storage of “conversion cookies”, Grächen also offers you the possibility to opt out. You may decline tracking by the Meta Pixel as well as the use of your data for the purpose of displaying Facebook ads. In order to configure which type of advertisements you want to be shown on Facebook, you can visit the corresponding site set up by Facebook and follow the steps outlined for configuring settings regarding user-based advertisements. The settings are made independent of platforms, meaning they apply to all devices such as desktop computer or mobile devices. You may object to the use of cookies used for tracking marketing reach and advertising purposes via the Network Advertising Initiative opt-out page and, additionally, the U.S. website aboutads.info or the European website youronlinechoices.com.

2.13. Links on Social Media Presences

Grächen has inserted links to Social Media Profiles on its website referring to the following networks:

• Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA,
• Instagram Inc., 1601 Willow Road, Menlo Park, California 94025, USA,
• Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA and
• Youtube, a service operated by Google Inc.
• LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland

When you click on the symbols of these social networks, you will automatically be referred to the profile on the corresponding network. In order to use the functionalities of the network in question, you may be required to log in to your user account on the corresponding network. When you click on a link to one of Grächen's social media profiles, a direct connection is established between your browser and the server of the social network in question. This provides the network with the information that you have visited our website with your IP address and clicked the link. If you click a link to a network while you are logged into your account with the network in question, the content of our site can be linked to your profile with the network, which means that the network can associate your visit to our website directly with your user account. If you want to prevent this, you should log out before clicking on the corresponding links. An association will be made in any case if you log in to the relevant network after clicking on the link.

3. Data collection outside of the website

3.1. General provisions

Grächen also processes your personal data outside of the scope of the website (e.g. when you contact them via E-mail or telephone, register for an event or accommodation on site, etc.).

3.2. Third-party services

In the case of third-party services, Grächen is considered as the agent and carries out the bookings on behalf of the service provider. Grächen forwards the data required for processing the booking to the corresponding service providers. These service providers are responsible for the further processing of the data under data protection law. Unless otherwise stated, the service providers will process the data in the booking process. They may rely on third parties to process the data on their behalf. Furthermore, hotel operators, holiday apartment/home agencies and camp site managers are required by law to register you and any persons travelling with you with the respective authorities.

Depending on the services booked, it may be necessary to collect particularly sensitive personal data or you may provide such information of your own accord. These data will be transferred to service providers for the purpose of correct contract fulfillment. By disclosing such data to Grächen, you expressly entitle Grächen to use this information in compliance with this privacy policy and to transfer it to the service providers.

3.3. Video surveillance

For the safety of our guests and staff, certain areas of the facilities as well as the sales points are under video surveillance. The recordings are stored for a limited time only.

4. Other provisions

4.1. Storage of your personal data in a central data base of Grächen

Grächen stores and processes personal data in a centralized manner. Grächen evaluates the data in the central data base for the purpose of improving products and services. The data is also evaluated for advertising purposes, in particular to offer you personalized services or product information.

4.2. Transmission of data to third parties

Grächen only transfers personal data if you have expressly consented to this, if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship.

Furthermore, data is transferred to third parties to the extent that is necessary within the scope of the use of our website and the execution of the contract (even outside of the website), namely the processing of your booking, registrations for events, ticket purchases as well as the analysis of your user behavior.

Various third-party service providers are explicitly mentioned in this privacy policy. Other service providers to whom personal data is transferred or who have or may have access to your personal data are the following two companies: Metanet AG, Josefstrasse 218, 8005 Zurich (web hosting) and Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (web server).

Finally, when you pay by credit card on the website, credit card information is forwarded to your credit card issuer as well as to the credit card acquirer. If you choose to pay by credit card, you will be asked to enter all mandatory information.

4.3. Transfer of personal data abroad

Grächen is entitled to forward your data to companies abroad if this is necessary in connection with the processing of your inquiries, the provision of services and marketing campaigns. These companies are obliged to maintain the privacy of users to the same extent as the provider itself. If the level of data protection in a country is deemed inadequate based on the EU General Data Protection Regulation, Grächen will employ a contract to ensure the protection of your personal data at all times in accordance with the EU General Data Protection Regulation.

4.4. Right to information, erasure and rectification

You can ask Grächen at any time and free of charge for information about your personal data stored by Grächen. Requests for information must be submitted in writing and include proof of identity. Likewise, you are entitled to request the erasure or rectification of your personal data stored by Grächen at any time.

You also have the right to demand that Grächen return the data that you have provided to Grächen (right to data portability). Upon request, Grächen will also pass on the data to a third party of your choice. You have the right to receive the data in a commonly used file format.

You can do this by sending a corresponding request by E-mail to info@graechen.ch. We would like to point out that Grächen reserves the right to demand proof of identity and that in the event of erasure of your data, you will no longer be able to use the services of Grächen, or at least not to the full extent.

You can revoke your consent to certain types of data processing at any time with effect for the future.

Please note that according to the law, certain data must be stored for a certain period of time. Such data must therefore remain stored by Grächen until the expiry of these periods.

4.5. Data security

Grächen employs adequate technical and organizational security measures in order to protect the data stored from manipulation, partial or total loss and unauthorized third-party access. The security measures are continuously updated in step with technological advancements.

Employees of Grächen and service providers contracted by Grächen are obliged to maintain confidentiality and to comply with the provisions of data protection legislation. Furthermore, they are only granted access to personal data to the extent necessary.

4.6. Data storage

Grächen only stores personal data for as long as required

• in order to use the aforementioned tracking services within the scope of our rightful interest; 
• in order to perform services that you have requested or to which you have consented to the extent stated above.

Contractual data will be stored for a longer period of time, as this is required according to legal obligations of safekeeping. Safekeeping obligations that require the retention of data result from accounting regulations and tax regulations.

5. Contact

For all information regarding data protection and your data, please contact info@graechen.ch.

6. Changes to this privacy policy

This privacy policy was last updated on [3/13/2023]. Grächen may change this privacy policy from time to time. Please visit Grächen's website regularly to check for updates to this privacy policy.