De instantie die verantwoordelijk is voor het verzamelen, verwerken en gebruiken van uw persoonlijke gegevens met betrekking tot de federale wetten voor gegevensbescherming is Holidayguru BV, Kaap Hoorndreef 66 3563AW Utrecht.
Als u niet akkoord gaat met het verzamelen, verwerken en gebruiken van uw persoonlijke gegevens in overeenstemming met deze bepalingen inzake gegevensbescherming in het algemeen of met specifieke maatregelen, kunt u uw bezwaar per e-mail, fax of brief sturen naar de volgende contactpersonen:
Kaap Hoorndreef 66
+31 30 249 3001
This Privacy Statement outlines all aspects regarding the security of personal data and the measures employed to protect your rights. Urlaubsguru GmbH adheres to the German Federal Data Protection Act (BDSG) 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, Urlaubsguru GmbH 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 Urlaubsguru GmbH. 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
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. 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:
– For Telegram Messenger is Telegram Messenger LLP 71-75 Shelton Street, Covent Garden, London, United Kingdom, privacy statement available under https://telegram.org/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.
Your consent to this data processing can be freely revoked at any time by entering “STOP” in the respective messenger.
To have all your data stored by our service provider removed, send a message with the text “DELETE ALL DATA” via your Messenger.
The technical service provider MessengerPeople GmbH, Herzog-Heinrich-Str. 9, 80336 Munich, Germany, will be used to provide the holidayguru WhatsApp service as an order processor for the sender.
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
1.9. Internet Marketing Services
1.10. 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.
We utilize the services of a partner for marketing of our digital advertisement panels : Ströer Digital Media GmbH, Kehrwieder 8-9, 20457 Hamburg, hereinafter: Ströer.
By using cookies on our website, Ströer collects data from web site visitors, such as device specifications, IP addresses (which are immediately anonymized) and information on previously visited websites. Analysis of this data allows for selection of content and advertisement that is of high relevance to the user, making advertisements more effective and user-friendly.
All information regarding data collection conducted on our website and on its usage, as well as opt-out options, can be found in the particularized privacy statement of Ströer Digital Media GmbH under https://www.stroeer.de/digitale-werbung/werbemedien/targeting-data/datenschutz.html
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.
2.Usage of Data
Urlaubsguru GmbH uses collected and processed personal data exclusively for the purposes of delivering services and for processing payments. By doing so, Urlaubsguru GmbH 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
Urlaubsguru GmbH 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 Urlaubsguru GmbH becomes legally obligated to, or if Urlaubsguru GmbH is required to disclose information in order to enforce the general conditions of use, similar agreements or rights and demands of Urlaubsguru GmbH.
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.
4. Website Analysis
We use the following analysis tool for the evaluation of our websites and describe them as follows:
4.1. Google Analytics
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.
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).
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.).
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.
Urlaubsguru GmbH 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
You can find our address and contact information at any time in our imprint under:
6.2 Data Protection Officer
Telephone No.: +49 2307 2874488
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.
Urlaubsguru GmbH 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.
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 3.3 | valid from 22/01/2019