Data Privacy
Privacy Policy
This privacy policy is to inform you about what personal data we process in connection with our activities and operations, including our christoffeldavos.ch website. In particular, we will inform you about why, how and where we process which personal data. We will also inform you about the rights of persons whose data we process. Further privacy policies and other legal documents such as general terms and conditions, terms of use or conditions of participation may apply to individual or additional activities and operations.
We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
The European Commission recognized with decision of July 26, 2000 that Swiss data protection law ensures adequate data protection. With report from January 15, 2024, the European Commission confirmed this adequacy decision.
1. Contact addresses
1.1 Responsibility for the processing of personal data:
Christoffel Ferienwohnungen AG
Promenade 41
7270 Davos-Platz
info@christoffeldavos.ch
In individual cases, there may be other controllers for the processing of personal data or a joint controllership with at least one other controller.
1.2 Data protection officers or data protection advisors
We have the following data protection officer or data protection consultant as a point of contact for data subjects and authorities for inquiries related to data protection:
Eva Marty
Christoffel Ferienwohnungen AG
Promenade 41
7270 Davos-Platz
info@christoffeldavos.ch
2. Definitions and legal basis
2.1 Definitions
Personal data is any information relating to an identified or identifiable natural person.
Particularly sensitive personal data includes data on trade union, political, religious or ideological views and activities, data on health, privacy or ethnicity or race, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures.
Processing includes any handling of personal data, regardless of the means and procedures used, for example, querying, matching, adapting, archiving, storing, reading, disclosing, obtaining, collecting, deleting, disclosing, organizing, organizing, storing, modifying, distributing, linking, destroying and using personal data. A data subject is a natural person about whom we process 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 and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act (FADP) and the Data Protection Ordinance (DSV).
If and insofar as the General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:
Art. 6 para. 1 lit. b GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
Art. 6 para. 1 lit. f GDPR for the processing of personal data 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 or by the interests of the data subject. Legitimate interests include, in particular, our interest in being able to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner and to communicate about them, to guarantee information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
Art. 6 para. 1 lit. c GDPR for the processing of personal data necessary for compliance with a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
Art. 6 para. 1 lit. e GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
Art. 6 para. 1 lit. d GDPR for the processing of personal data necessary to protect the vital interests of the data subject or of another natural person.
3. Nature, scope and purpose
We process the personal data that is necessary to enable us to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Such personal data may in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data, as well as contract and payment data.
We process personal data for the period necessary for the relevant purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also ensure data protection with such third parties.
We process personal data only with the consent of the data subjects. If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations or to 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 our activities and operations, if and to the extent that such processing is permitted by law.
4. Communication
We process personal data in order to communicate with third parties. In this context, we process in particular data that a data subject transmits when making contact, for example by letter post or e-mail. We may store such data in an address book or with comparable tools.
Third parties who transmit data about other persons are obliged to guarantee data protection to such data subjects. To do this, the accuracy of the transmitted personal data must be ensured, among other things.
5. Data security
We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. In particular, we ensure the confidentiality, availability, traceability and integrity of the personal data processed by means of our measures, but without being able to guarantee absolute data security.
Access to our website and our other online presence is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.
Our digital communication – like basically all digital communication – is subject 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 corresponding processing of personal data by secret services, police forces and other security authorities. We also cannot rule out the possibility that individual data subjects may be monitored specifically.
6. personal data in foreign countries
We generally process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, in particular for the purpose of processing it or having it processed there.
We may export personal data to all countries and territories on earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and, if and to the extent that the General Data Protection Regulation (GDPR) is applicable, in accordance with the decision of the European Commission.
We may transfer personal data to countries whose laws do not guarantee adequate data protection if data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the special data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. We will be happy to provide data subjects with information about any guarantees on request or provide a copy of any guarantees.
7. Rights of data subjects
7.1 Data protection rights
We grant data subjects all rights under applicable data protection law. In particular, data subjects have the following rights:
Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of the processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
Rectification and restriction: Data subjects can rectify inaccurate personal data, complete incomplete data and have the processing of their data restricted.
Erasure and objection: Data subjects can have personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.
Data disclosure and data transfer: Data subjects can request the disclosure of personal data or the transfer of their data to another controller.
We may postpone, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may draw the attention of data subjects to any conditions that may have to be fulfilled in order for them to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of business confidentiality or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part on the grounds of legal obligations to retain data.
We may exceptionally charge a fee for exercising the rights. We will inform data subjects in advance of any costs.
We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
7.2 Legal protection
Data subjects have the right to enforce their data protection claims through the courts or to file a report or complaint with a competent data protection supervisory authority.
The data protection supervisory authority for data subjects to file 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 – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – are organized as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), the data protection supervisory authorities have a federal structure, in particular in Germany.
8. Use of the website
8.1 Cookies
We may use cookies. Cookies – our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are 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 of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a certain storage duration. In particular, cookies enable us to recognize a browser the next time you visit our website and thus, for example, measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be partially or completely disabled and deleted at any time in the browser settings. Without cookies, however, our website may no longer be fully available. We actively request – at least if and insofar as necessary – express consent to the use of cookies.
For cookies used to measure success and reach or for advertising, a general opt-out is possible for numerous 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 may log at least the following information for each access to our website and our other online presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-pages of our website accessed including the amount of data transferred, last website accessed in the same browser window (referrer or referrer).
We log such information, which may also constitute personal data, in log files. The information is necessary to provide our online presence in a sustainable, user-friendly and reliable manner. The information is also necessary to ensure data security – including by third parties or with the help of third parties.
8.3 Web beacons
We may integrate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – usually take the form of small, invisible images or scripts formulated in JavaScript that are automatically retrieved when our online presence is accessed. Tracking pixels can be used to collect at least the same information as in log files.
9. Notifications and messages
We send notifications and messages by email and through other communication channels such as instant messaging or SMS.
9.1 Performance and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links were clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We need this statistical recording of use for measuring success and reach in order to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
9.2 Consent and objection
You must generally consent to the use of your email address and other contact addresses, unless such use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain any consent that has been confirmed twice. In this case, you will receive a message with instructions for the double confirmation. We may log consents obtained, including IP address and time stamp, for evidence and security reasons.
You can object to receiving notifications and messages such as newsletters at any time. By objecting, you can simultaneously object to the statistical recording of usage for measuring success and reach. We reserve the right to send necessary notifications and messages in connection with our activities and operations.
9.3 Service providers for notifications and messages
We send notifications and messages with the help of specialized service providers.
10. Social media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.
We are jointly responsible for our social media presence on Facebook, including Page Insights, together with Meta Platforms Ireland Limited (Ireland) – if and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook page. We use Page Insights to provide an effective and user-friendly social media presence on Facebook.
Further information about the type, scope and purpose of data processing, information about the rights of data subjects and the contact details of Facebook and its data protection officer can be found in the Facebook data protection declaration. We have concluded the so-called “addendum for controllers” with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page “Information about Page Insights” including “Information about Page Insights Data”.
11. Third-party services
We use the services of specialized third parties to enable us to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. When such embedding occurs, the services used collect the IP addresses of users at least temporarily for technical reasons.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This may include, for example, performance or usage data in order to provide the respective service.
In particular, we use:
Services from Google: providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; general information on data protection: “Privacy and security principles”, data protection declaration, “Google is committed to complying with applicable data protection laws” “Guide to privacy in Google products”, “How we use information from sites or apps that use our services” (information from Google), “Types of cookies and similar technologies that Google uses”, “Advertising you can control” (“Personalized advertising”).
11.1 Digital infrastructure
We use the services of specialized third parties to provide the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
exigo: hosting; provider: exigo ag (Switzerland); information on data protection: data protection declaration, “data protection / security”.
11.2 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols into our website.
In particular, we use:
Google Fonts: fonts; provider: Google; Google Fonts-specific information: “Your Privacy and Google Fonts”, “Privacy and data collection”.
11.3 E-commerce
We operate e-commerce and use third-party services to successfully offer services, content or goods.
11.4 Payments
We use specialized service providers to process our customers' payments securely and reliably. The legal texts of the individual service providers, such as general terms and conditions (GTC) or data protection declarations, also apply to the processing of payments.
In particular, we use:
Stripe: payment processing; providers: Stripe Inc. (USA) / Stripe Payments Europe Limited (SPEL, Ireland) for users in the European Economic Area (EEA) and Switzerland and partly in the United Kingdom / Stripe Payments UK Limited (United Kingdom) and Stripe Capital Europe Limited (Ireland) partly for users in the United Kingdom; information on data protection: “Stripe Datenschutz Center” (“Stripe Privacy Center”), data protection declaration, cookie guidelines.
SumUp: card payment processing; provider: SumUp Payments Limited (United Kingdom) / SumUp Limited (Ireland) / SumUp EU Payments UAB (Lithuania); information on data protection: privacy policy, cookie policy, “security & data protection”.
Worldline: payment processing, particularly with mobile payment solutions; providers: Worldline SA (France), Worldline Schweiz AG (Switzerland) and other Worldline companies around the world (including in the USA); information on data protection: privacy policy, “program for responsible data handling”, cookie policy.
11.5 Advertising
We use the option of having targeted advertising displayed for our activities and operations by third parties such as social media platforms and search engines.
With this advertising, we particularly want to reach people who are already interested in our activities and operations or who could be interested (remarketing and targeting). To do this, we may transfer the relevant information – which may include personal data – to third parties that enable such advertising. We may also determine whether our advertising is successful, in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may be able to associate your use of our website with your profile there.
We use in particular:
Facebook advertising (Facebook Ads): social media advertising; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: remarketing and targeting in particular with the Facebook pixel as well as custom audiences including lookalike audiences, privacy policy, “advertising preferences” (user registration required).
Google Ads: search engine advertising; provider: Google; Google Ads-specific information: advertising based, among other things, on search queries, with various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – being used for Google Ads, 'Advertising' (Google), 'Display advertising managed directly by Ads'.
Instagram Ads: social media advertising; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the US); data protection information: remarketing and targeting, in particular with Facebook pixels, as well as custom audiences including lookalike audiences, privacy policy (Instagram), privacy policy (Facebook ), 'advertising preferences' (Instagram) (user registration required), 'advertising preferences' (Facebook) (user registration required).
12. Performance and reach measurement
We try to determine how our online services are used. In this context, we can, for example, measure the success and reach of our activities and operations, as well as the effect of third-party links on our website. However, we can also try out and compare how different parts or versions of our online services are used (“A/B test” method). Based on the results of the performance and reach measurement, we can, in particular, correct errors, strengthen popular content or make improvements to our online offering.
In most cases, the IP addresses of individual users are stored to measure performance and reach. In this case, IP addresses are always shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization.
Cookies may be used and user profiles created to measure success and reach. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles created are exclusively pseudonymized and are not used to identify individual users. Individual third-party services for which users are registered may associate the use of our online services with the user account or user profile for the respective service.
In particular, we use:
Google Analytics: performance and R eichweitenmessung; 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 in exceptional cases completely transmitted to Google in the US, “Privacy”, “Browser Add-on to disable Google Analytics ”. Google Tag Manager: integration and management of other services for measuring success and reach, as well as other services from Google and third parties; Provider: Google; Google Tag Manager-specific information: “Data collected by Google Tag Manager”; further information on data protection can be found in the individual integrated and managed services.
13. Final provisions
We have created this data protection declaration with the data protection generator from Datenschutzpartner.
We may amend and supplement this data protection declaration at any time. We will provide information about such amendments and supplements in a suitable form, in particular by publishing the current data protection declaration on our website.