The entity responsible for the collection, processing and use of your personal data with respect to federal data protection laws is Holidayguru BV. If you do not agree with the collection, processing and use of your personal data in accordance with these data protection provisions in general or with specific measures, you can send your objection by e-mail, fax or letter to the following contacts:
Holidayguru BV
hallo@holidayguru.nl
Privacy Statement
This Privacy Statement outlines all aspects regarding the security of personal data and the measures employed to protect your rights. Holidayguru adheres to the Dutch Personal Data Protection Act (WBP) and the General Data Protection Regulation (GDPR) of the European Union.
1. Acquisition and Use of Personal Data
1.1. General Information
We collect and use personal data to offer a user-friendly experience. Personal data means any information relating to an identified or identifiable natural person, e.g. name, address, contact information, IP-address, quantity of transferred data, etc.
1.2. Legal basis
The legal bases for processing data are:
Provision of products and services by this website: initiation and fulfilment of contract
Requests via post, e-mail or fax received by us: initiation and fulfilment of contract
Links to other offers and analysis of access: legitimate interest
1.3. Automatic Processing by Website Operator
The website www.holidayguru.nl is operated by a provider within the European Union, which stores system access in server logs for the operation of its web service. The following data is generally collected: IP-address, timestamp of access, latency information, selected paths and server responses. This data is used and stored for the sole purpose of error analysis. In the case of a legitimate suspicion of misuse based on concrete information, these log files may subsequently be examined.
Furthermore, Holidayguru uses service providers for the fulfilment of its service. These service providers (external data processors) are selected carefully and will be obligated to adhere to the same legal data protection regulations as Holidayguru. Only the necessary data for the fulfilment of the respective task will be forwarded to these service providers.
Services providers are, among other things, used for the distribution of newsletters or system alerts, for the delivery of electronic mail in general, for tracing users and retargeting, for customer feedback as well as for booking services.
1.4. Web Fonts
This website uses fonts, such as those from Google Fonts. Google Fonts is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“Google”). The integration of these fonts into the website is carried out by a server call, which is in many cases located in the USA. By executing a server call, data will be transmitted to the server. This data may entail information about which pages of the website were visited, as well as the IP-address of the visitor’s end device. Additional information can be obtained from Google’s privacy policy, which can be found under the following weblink: www.google.com/policies/privacy.
1.5. YouTube
We use the web service “YouTube”, a product of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“Google”), to integrate videos into our service. By opening a YouTube video, data will be sent to a server of this service provider, which may be located outside of the EU. Google processes information about this activity, such as the video viewed, device-ID, IP-address, cookie data with information such as the most recently visited webpage, language preferences and location information. Google’s privacy statement can be obtained via the following weblink: https://www.google.com/policies/privacy/. Users may opt-out by using the following link: https://adssettings.google.com/authenticated.
1.6. Google Maps
We use the service provider “Google Maps”, a product of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“Google”), to display maps and location information. By requesting a geographical map from Google Maps, data is sent to a server of the service provider, which may be located outside of the EU. Google processes information about this activity, such as information about the displayed content, device-ID, IP-address, cookie data with information such as the most recently visited webpage, language preferences, for advertisement purposes and location information. Google’s privacy statement can be obtained via the following weblink: https://www.google.com/policies/privacy/.
1.7. Facebook Pixel
We use Facebook Tracking Pixel for our web service to offer the best possible user experience for our customers. This is a service provided by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, as a component of the social network Facebook. When using Pixel, the following data is sent to the USA: IP-address.
Should you not wish to have Facebook Pixel monitor your activity, you can prevent the usage of cookies in each of your web browsers as set out in Section 3 under “cookies”.
1.8. TikTok Pixel
Our website uses the TikTok Pixel to understand visitor behavior and make ads more relevant. The TikTok Pixel collects data such as page views and purchases. This data helps us measure the effectiveness of ads on TikTok and tailor content to users' interests. More details about this use are available via the following weblink: https://www.tiktok.com/legal/page/eea/privacy-policy/en.
1.9. Messaging Services
By sending a start message to the company specified in the imprint (hereinafter referred to as the sender), I agree pursuant to Art. 6 para. 1 lit. a DSGVO that the sender may use my personal data (e.g.
surname and first name, telephone number, Messenger ID, profile picture, news, gender, language and information on user activities) for direct communication and the necessary data processing using the selected messenger.
To use this service, an existing messaging account with the respective provider is required.
Responsible providers of the messengers are:
– Facebook Messenger the Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA with the privacy policy available at www.facebook.com/about/privacy
– For Insta News is Pylba Inc., 314 27th Avenue, San Mateo, CA, 94403, USA, privacy statement available under apps.pylba.com/privacy.
I am aware that the respective provider receives personal data (in particular communication metadata), which is also processed on servers in countries outside the EU (e.g. USA) where an adequate level of data protection cannot be guaranteed. However, Whatsapp Inc and Facebook Inc are certified under the Privacy Shield Agreement and thus offer a guarantee of compliance with European data protection law.
Further information can be found in the above privacy policy for each messenger. The sender has neither exact knowledge nor influence on the data processing by the respective provider.
The technical service provider Chatvisor GmbH, Hafenstraße 47-51, 4020 Linz is used as the sender’s processor to provide the holidayguru Facebook Messenger Service
1.10. Internet Marketing Services
Google AdSense
We use services such as “Google AdSense”, a product of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“Google”) to provide advertisements. Google AdSense uses cookies (see paragraph 3, Cookies) as well as so-called web beacons (invisible graphics). By using these web beacons, information such as user traffic, conversion tracking and remarketing on the pages of this web service can be analysed. The information created by cookies and web beacons about the usage of this website (including the user’s IP-address) and delivery of advertisement formats are transmitted and stored in one of Google’s servers in the USA. This information may be passed on by Google to contracting parties of Google. However, Google will not match your IP-address with other data stored about you. You can prevent the usage of cookies (see paragraph 3, Cookies).
1.11. Data Input by the Website User
The usage of the websites provided by Holidayguru is generally possible without the disclosure of any personal information. If you wish to make use of the services and functions of our platform or our enterprise, it may become necessary to collect and process personal information. If we collect personal information (contact form, booking form, travel requests, newsletter subscriptions, forums, competitions, blog entries, etc.), we will inform you about purpose, extent, lawfulness and possible disclosure and will use the information solely for these purposes. Choosing to share this data is voluntary. Should you choose to do so, the transmission of this data will be encrypted.
1.12. Shopping Minds
Shopping Minds is a technical specialist when it comes to personalisation. We do this by creating profiles of website visitors on behalf of our clients and with the help of technology. A profile can, for example, record which products a visitor clicks on. Using this technology, we can make the content of the website (or shop) more relevant to the visitor by personalising the offer. This can also be applied in other (digital) communication tools. The goal is to make the total (brand) experience more personal.
Shopping Minds B.V. Vondellaan 136 – 140 3521 GH Utrecht, is responsible for the processing of personal data as set out in their privacy statement.
1.13. Axel Springer Teaser Ad
Tracking by Ad Up, a technology and service provider of Axel Springer Teaser Ad GmbH (Axel-Springer-Straße 65, 10969 Berlin), is integrated into our websites. By collecting anonymized and/or pseudonymized data, Ad Up can then display ads on websites that match your interests for a certain period of time.
Ad Up uses cookies to provide advertisers with so-called conversion tracking, which determines the effectiveness of their ads and keywords.
More information on data protection can be found at Axel Springer Teaser Ad GmbH at https://www.adup-tech.com/en/privacy-policy/. You can also use the “Activate opt-out cookie” button there to set an opt-out cookie in your browser and thus deactivate Ad Up in this browser.
1.14. Tradetracker
Holidayguru partners with affiliate network Tradetracker. The affiliate program offers a cookie period of 45 days; if a booking occurs within that period after a click on an affiliate link, the partner receives commission. The commission is calculated on the net sales value of the travel price, with a minimum of 4%. The program employs “last-click” tracking and also supports fingerprint tracking. Each transaction generated is checked weekly by Holidayguru to ensure the accuracy of bookings. Then the approved transactions are passed to the affiliate network and paid out to the partner. This program provides online partners with attractive returns and supports their interests through independent verification from the affiliate network.
1.15. Marigold Engage
When registering for our newsletter, you must provide us with your e-mail address and your full name. We use the e-mail address to send you the newsletter. We use your name to address you personally. We will store your e-mail address and the name you provide for the purpose of sending you the newsletter until you unsubscribe from our newsletter.
For statistical purposes, we record whether you open the newsletter and click on links in the newsletter. This enables us to understand which content is of particular interest to you. By subscribing to our newsletter and confirming your subscription as part of the double opt-in procedure, you expressly consent to this statistical recording in accordance with Art. 6 para. 1 lit. b GDPR. If you do not agree to this collection, you will unfortunately not be able to use our newsletter. In this case, you should unsubscribe from the newsletter immediately and thus object to the data processing.
You can unsubscribe at any time via the link provided in the newsletter or by sending us a corresponding message. By unsubscribing, you object to the further use of your e-mail address and your name for sending the newsletter.
The legal basis for the processing of data after registration for the newsletter is Art. 6 para. 1 sentence 1 lit. b GDPR.
We use the Marigold Engage (formerly Selligent) service to send our newsletter. This service is provided by our partner Marigold Engage: Selligent GmbH, Herzogspitalstraße 24 80331 Munich. This transfer takes place in accordance with Art. 6 para. 1 lit. f GDPR and serves our legitimate interest in the use of an effective, secure and user-friendly newsletter system. The data you enter for the purpose of subscribing to the newsletter (e.g. email address) will be stored on Marigold Engage's servers in the EU/EEA.
We use Marigold Engage Marketing Cloud, an offer from Selligent GmbH, Herzogspitalstraße 24 80331 Munich.
We use the services Marigold Engage Campaign (control and playout of CRM campaigns), Marigold Engage Site (identification and segmentation of customers) and Marigold Engage Cortex (machine learning and data processing). Marigold Engage's privacy policy and information on how the relevant data is used by Marigold Engage can be found at https://meetmarigold.com/privacy-notices/.
This website uses “Marigold Engage Site” for the anonymized analysis of user behaviour (e.g. articles read, booking buttons clicked) when visiting our websites. Anonymized information from website visitors is collected using technologies such as cookies, web beacons and social media usage analysis. The information collected via “Marigold Engage Site” about your use of this website is processed in Selligent GmbH systems and transmitted to us.
We have concluded an agreement with Selligent GmbH for processing on our behalf. If we ask users for their consent to the use of cookies, the legal basis for processing is consent pursuant to Art. 6 para. 1 lit. a GDPR. Otherwise, the processing is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR in a user-oriented and economically efficient operation of our online offer.
As part of its tracking services, Marigold Engage sets two cookies when you click on a link in the newsletter:
A session cookie: this is deleted when the internet browser is closed.
A first-party cookie: This is deleted after 12 months.
Further information can also be found in Marigold Engage's privacy policy, in particular at https://meetmarigold.com/privacy-notices.
2. Usage of Data
Holidayguru uses collected and processed personal data exclusively for the purposes of delivering services and for processing payments. By doing so, Holidayguru adheres to every applicable data protection law, in particular of the German Federal Data Protection Act/EU GDPR as well as the German Telemedia Act (Telemediengesetz).
2.1. Disclosure of Data
Holidayguru will not pass on your personal information to third parties for marketing or similar purposes. A disclosure of data occurs only if and to the extent it becomes necessary to fulfil the user agreement, if Holidayguru becomes legally obligated to, or if Holidayguru is required to disclose information in order to enforce the general conditions of use, similar agreements or rights and demands of Holidayguru.
Customer information via e-mail in terms of customer loyalty: we send current information to our customers to inform them about news and changes to our services. This information should not be confused with our newsletter. If, for example, it concerns our services, aspects relevant to security, or important information from inside our company, we can only share this information via e-mail. We hope you understand.
3. Cookies
Our website use cookies in order to provide the user with an effective and user-friendly experience. This justifies the usage of cookies and our legitimate interest in using this technology. Most web browsers offer a function to display all cookies used.
If you wish to generally deactivate the use of cookies, your browser provides a function to prevent your computer from accepting and storing cookies. To find out how to deactivate cookies in your respective browser, please use the help function in your browser. However, Holidayguru recommends leaving cookies enabled, as only then will you be able to fully benefit from the high level of user comfort that Holidayguru has intended.
4. Website Analysis
We use the following analysis tool for the evaluation of our websites and describe them as follows:
4.1. Google Analytics
We use the web analysis service Google Analytics, a product of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“Google”). Google analytics uses cookies, which are text files stored on your computer to enable an analysis of your usage of our website. The information generated by cookies about your usage of the website is generally transmitted and stored in one of Google’s servers in the USA. However, the IP address provided to will not be merged with other Google data. Furthermore, we have used the code “anonymizeIP” on this website for Google Analytics. This ensures that your IP-address will be masked as early as possible so that your data will be stored anonymously.
Google is certified under the EU-US Privacy Shield agreement and guarantees to adhere to European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
On behalf of the operator of this website, Google will use this information to analyse the usage of this website, to compile reports on the website activity and to render services related to usage of the website and internet for the website operator. You can prevent the storage of cookies by altering the respective setting in your web browser. However, doing so may mean that you are unable to use all the comfort functions of this website to their fullest extent.
Furthermore, we use Google Analytics to analyse data on double-click cookies and AdWords. If you do not consent to this, you can deactivate it in the Ads preferences manager: http://www.google.com/settings/ads/onweb/
Users personal data will be deleted or anonymised after 38 months.
4.2. INFOnline
Our website uses the measurement method (“SZMnG”) of INFOnline GmbH (https://www.infonline.de) to determine statistical values about the usage of our services. The purpose of measuring the scope is to statistically determine the frequency of use, the number of visitors on our website and their surfing habits – based on a uniform standard procedure – and to therefore obtain comparable values for the market.
User statistics for all digital services which are a member of the German Audit Bureau of Circulation (Informationsgemeinschaft zur Feststellung der Verbreitung von Werbeträgern e.V. IVW – http://www.ivw.eu) or which participate in the German Association of Online Research (Arbeitsgemeinschaft Online Forschung e.V. (AGOF) – http://www.agof.de) are regularly processed further by AGOF and the German Association of Media Analysis (Arbeitsgemeinschaft Media-Analyse e.V. (AGMA) – http://www.agma-mmc.de) and published as a performance value called “Unique User”. The IVW publishes key figures as “Page Impressions” and “Visits”. These ranges and statistics can be viewed on the respective websites.
Legal basis for processing
Analysis with the measuring method SZMnG by INFOnline GmbH is carried out with justifiable interest, according to Article 6 (1) lit. f) of the GDPR. Generating statistics and user categories serve the purpose of processing personal data. The statistics are also used to understand and verify the use of our services. User categories constitute the foundation for a strategic orientation of advertisement that serves our customers interest. Measuring the usage of our website is imperative for our marketing efforts and comparison with others in the market. Our legitimate interest stems from the economic usability of the findings that originate from user categories and statistics, and the market value of our website, which can be determined by comparing our statistics to those of third-party websites.
In addition, we have a legitimate interest in providing pseudonymised data to INFOnline, the AGOF and IVW for the purpose of market research (AGOF, AGMA) and for statistical purposes (INFOnline, IVW). Furthermore, we have a legitimate interest in using the pseudonymised data from INFOnline to develop and provide advertising material in accordance with the specific interests of our customers.
Nature of the Data
INFOnline GmbH gathers the following data, which are considered to be of personal nature according to the EU GDPR:
IP-address: Every device is required to have a unique address for the purpose of transferring data, the so-called IP-address. Storing this IP-address, at least temporarily, is a necessity due to the operating principle of the internet. IP-addresses are shortened by 1 byte and anonymized before being processed. There is no further processing or storage of the IP-address in its full length.
A randomly-generated client identifier: The processing system uses either a cookie with the identification “ioam.de”, a “local storage object”, or a signature compiled from various data transferred by the browser to recognise a computer system. This identifier is unique to a browser, so long as the cookie or local storage device is not deleted. Measuring data and subsequent matching to the respective client identifier will therefore also be possible if you visit websites that also use the measuring procedure (“SZMnG”) of INFOnline. The validity of the cookie is limited to a maximum of 1 year.
Usage of Data
The measuring procedure of INFOnline GmbH, which is used on this website, determines usage data. This is done for the purpose of generating the performance values of page impressions, visits, clients and other additional figures (such as qualified clients). The data measured during this process is used as follows:
A so-called geo-localisation, the process of matching a website access to the location of the access, is carried out exclusively based on anonymised IP-addresses and only to the level of federal state or region. Under no circumstances will it be possible to determine the exact location of the user.
The user data of a technology-based client (e.g. a browser on a device) are merged across web pages and stored in a database. This information is used to estimate social data, such as age and gender, and is forwarded to the service provider of AGOF to further analyse the reach of each website. The AGOF study estimates sociometrical data based on a randomised sample, which can be further subcategorized into age, gender, nationality, occupation, marital status, general household information, household income, place of residence, internet usage, online interests, location of use, user type.
Duration of Data Storage
The complete IP-address is not stored by INFOnline GmbH. The shortened IP-address is stored for a maximum of 60 days. User data in combination with a unique identifier is stored for a maximum of 6 months.
Disclosure of Data
The IP-address as well as the shortened IP-address will never be disclosed. Data with client identifiers for the AGOF study are disclosed to the following service providers of the AGOF:
Kantar Deutschland GmbH (https://www.tns-infratest.com/)
Ankordata GmbH & Co. KG (http://www.ankordata.de/homepage/)
Interrogare GmbH (https://www.interrogare.de/)
If you do not wish to participate in this collection of data, you have the right to revoke your consent. To do this, please click on the following link: https://optout.ioam.de
It is necessary to install a cookie to guarantee exclusion from this collection of data. If you delete the cookie in your browser, it will become necessary to repeat the opt-out procedure.
Additional information about data protection with respect to the measurement methods can be found on the INFOnline website (https://www.infonline.de), which is in charge of these measuring procedures, as well as on the website of AGOF (http://www.agof.de/datenschutz) and the website of IVW (http://www.ivw.eu).
4.3. Hotjar
We use Hotjar for a better understanding of the needs of our users and for continiously optimizing the services on this website. Hotjar’s technology helps us in gaining a better understanding of our users’ experiences (e.g. how much time users spend on which pages, which links they click, what they like and what they don’t like, etc.).
All of this helps us to tailor our offering to our users’ feedback. Hotjar uses cookies and other technologies to collect information about our users’ behavior and about their end devices (in particular, IP address of the device (only collected and stored in anonymous form), screen size, device type (Unique Device Identifiers), information about the browser used, location (country only), language preferred to view our website. Hotjar stores this information in a pseudonymous user profile. The information is not used by Hotjar or by us to identify individual users, nor is it merged with other data about individual users.
You can object to Hotjar storing a user profile and information about your visit to our website and to Hotjar tracking cookies on other websites by clicking this opt-out link.
5. Security
Holidayguru uses technical and organisational security measures in order to ensure the protection of your data from loss, false alterations and unauthorised access by third parties. In any case, access will only be granted to authorised persons and only to an extent that is necessary. Security measures are frequently upgraded in accordance with technological development.
6. Additional Information
6.1. Responsible Authority
Holidayguru
You can find our address and contact information at any time in our imprint under:
https://www.holidayguru.nl/imprint/
6.2. Data Protection Officer
P2 Consult
Jürgen Golda,
Wilhelm-Bläser-Str. 3c
D-59174 Kamen
Telefon: +49 2307 2874488
Mail: datenschutz@urlaubsguru.de
6.3. Storage Period
We store your data for as long as the purpose of the storage prevails (requests, projects, contracts, etc.). Should the purpose of storage lapse or consent be withdrawn, your data will be deleted during a periodic deletion run, provided that no other legal retention period must be adhered to.
6.4. Children
Holidayguru will never knowingly collect and process the data of children. If an underage person makes an inquiry, we will store the data only with the explicit consent of a legal guardian. If we are granted permission to store the data of an underage person, we will disclose this data only within legal requirements. “Children” in this context are people as defined by national law and regulations that are currently in effect in Germany.
6.5. Profiling of Your Data Will Not Occur
An automatic decision-making process and/or profiling with your data will not occur on our website.
6.6. Your Rights
You can contact us at any time if you wish to assert your right to information, deletion, restriction or retraction. Please use the contact information as provided on our website. Inquiries must be made in writing to ensure the identification of the person filing the request.
6.7. Right to Appeal
If you have any reasonable doubt about our handling of your data, please inform us or contact the respective supervisory authority.
6.8. Amendments
We reserve the right to amend this Privacy Statement at any time. Therefore, we recommend reviewing this privacy statement on a regular basis.
Privacy Statement | Version 3.4 | valid from 01/11/2024