Privacy Policy
New Privacy Policy as per September 1st 2023 – General Data Protection Regulation (GDPR)
With this privacy policy, we inform which personal data we process in connection with our activities and operations including our www.hotelschweizerhof.com-Website. In particular, we provide information on what personal data we process, for what purpose, how and where. We also provide information about the rights of persons whose data we process.
For individual or additional activities and actions, further data protection declarations as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.
We are subject to Swiss data protection law and any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
1. CONTACT ADDRESSES
Responsibility for the processing of personal data:
Hotel Schweizerhof Zurich
Bahnhofplatz 7
8001 Zurich
We indicate if there are other persons responsible for the processing of personal data in individual cases.
2. TERMS AND LEGAL BASIS
2.1 Terms
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) comprises 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 processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law such as, in particular, the Swiss Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
We process - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - personal data in accordance with at least one of the following legal bases:
Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner, as well as to communicate about them, to ensure 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 necessary processing of personal data to comply 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 (1) (d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another individual.
3. NATURE, VOLUME AND PURPOSE
We process those personal data that are necessary to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. In particular, such personal data may 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 and contract and payment data.
We process personal data for the period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer required will be anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.
As a matter of principle, we only process personal data with the consent of the persons concerned. If and to the extent that the processing is permitted for other legal reasons, we may waive the requirement to obtain 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.
In this context, we process in particular information that a data subject voluntarily provides to us when contacting us - for example, by letter, e-mail, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obligated to ensure data protection with respect to these persons and to ensure the accuracy of this personal data.
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 for legal reasons.
4. APPLICATIONS
We process personal data about applicants to the extent that it is necessary for assessing their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, resumes and other application documents as well as online profiles.
We process - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - personal data about applicants in particular in accordance with Art. 9 (2) lit. b GDPR.
We use third-party services to advertise jobs via e-recruitment and to enable and manage applications.
5. PERSONAL DATA ABROAD
We process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer Personal Data to other countries, in particular to process it or have it processed there.
We may export Personal Data to all states and territories on Earth and elsewhere in the universe, provided that the law there ensures 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 - adequate data protection in accordance with the decision of the European Commission.
We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or a copy of any guarantees upon request.
6. RIGHTS OF DATA SUBJECTS
6.1 Data protection rights
We grant data subjects all claims in accordance with applicable data protection law. In particular, data subjects have the following rights:
Information: Data subjects may 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 required to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
Deletion and objection: Data subjects can have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
Data release and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.
We may suspend, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements they must meet in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to statutory retention obligations.
We may exceptionally provide for costs for the exercise of rights. We will inform data subjects in advance of any costs.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
6.2 Right of complaint
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have the right - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - to lodge a complaint with a competent European data protection supervisory authority.
7. DATA SECURITY
We take appropriate technical and organizational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.
Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communication is subject - as is basically all digital communication - to mass surveillance without cause or suspicion and other monitoring 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 agencies and other security authorities.
8. USE OF THE WEBSITE
8.1 Cookies
We may use cookies. Cookies - our own cookies (first-party cookies) as well as 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 specific storage period. In particular, cookies enable us to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request - at least if and to the extent necessary - the express consent to the use of cookies.
For cookies used for performance and reach measurement or for advertising, a general objection ("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 Server log files
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliably as well as to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.
8.3 Tracking pixel
We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels - also from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. With pixel counters, the same information can be collected as in server log files.
9. NOTIFICATIONS AND MESSAGES
We send notifications and communications via email and other communication channels such as instant messaging or SMS.
9.1 Performance and Reach Measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked. Such web links and tracking pixels may also record the use of notifications and messages on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able 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 Refusal
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure wherever possible, i.e. you receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
In general, you can revoke the receipt of notifications and communications, such as newsletters, at any time. With such an objection, you can simultaneously object to the statistical recording of usage for performance and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.
9.3 Service providers for notifications and communications
We send notifications and communications 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 as well as to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of 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 in each case. These provisions inform in particular about the rights of data subjects directly against the respective platform, which includes, for example, the right to information.
For our social media presence on Facebook, including the so-called Page Insights, we are - if and insofar as the General Data Protection Regulation (GDPR) is applicable - jointly responsible with Meta Platforms Ireland Limited (Ireland). 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 presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly manner.
Further information about the nature, volume and purpose of data processing, information about the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Responsible Party Addendum" with Facebook and 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 "Page Insights Information" including "Page Insights Data Information".
11. THIRD PARTY SERVICES
We use services of specialized third parties in order to carry out our activities and operations in a durable, user-friendly, safe and reliable manner. Such services allow us, among other things, to embed functions and content in our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling 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 is, for example, performance or usage data in order to be able to offer the respective service.
In particular, we use:
Google services: Provider: 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", Privacy Policy, "Google is committed to complying with applicable data protection laws", "Privacy Policy Guide in Google Products", "How we use data from websites or apps where our services are used" (information provided by Google), "Types of cookies and other technologies used by Google", "Personalized advertising" (activation / deactivation / settings).
Services of Microsoft: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: "Data protection at Microsoft", "Data protection and privacy (Trust Center)", privacy policy, data protection dashboard (data and privacy settings).
11.1 Digital infrastructure
We use services from specialized third parties to make use of required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
In particular, we use:
METANET: Hosting; Provider: METANET AG (Switzerland); Information on data protection: data protection declaration, "Technical-organizational measures".
11.2 Contact options
We use services from selected providers in order to better communicate with third parties such as potential as well as existing customers.
11.3 Audio and Video Conferencing
We use specialized audio and video conferencing services to communicate online. We can use them, for example, to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services such as privacy statements and terms of use apply in addition.
Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or fading in a virtual background.
We use in particular:
Microsoft Teams: platform for audio and video conferencing, among other things; provider: Microsoft; Teams-specific information: "Privacy and Microsoft Teams".
11.4 Online collaboration
We use services of third parties to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy statements, also apply.
11.5 Social media functions and social media content
We use services and plugins from third parties to embed functions and content from social media platforms as well as to enable the sharing of content on social media platforms and in other ways.
In particular, we use:
Facebook (social plugins): Embedding of Facebook functions and Facebook content, for example "Like" or "Share"; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: privacy policy.
Instagram Platform: Embedding of Instagram content; Provider: Meta Platforms Ireland Limited (Ireland) and other meta companies (including in the USA); data protection information: data protection statement (Instagram), data protection statement (Facebook).
11.6 Advertising
We use the option of displaying targeted advertising for our activities and operations on third parties such as social media platforms and search engines.
With such advertising, we would like to reach in particular persons who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding - possibly also personal - information to third parties that enable such advertising. We may also determine whether our advertising is successful, that is, in particular, whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are logged in as a user may be able to associate the use of our website with your profile there.
In particular, we use:
Facebook Advertising (Facebook Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting, in particular with the Facebook pixel, as well as Custom Audiences including Lookalike Audiences, data protection statement, "advertising preferences" (user registration required).
Google Ads: search engine advertising; provider: Google; Google Ads-specific data: Advertising based on search queries, among other things, using different domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - for Google Ads, "Advertising" (Google), "Why do I see a certain ad?".
Instagram Ads: social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting in particular with Facebook Pixel as well as Custom Audiences including Lookalike Audiences, data protection declaration (Instagram), data protection declaration (Facebook), "Advertising preferences" (Instagram) (user registration required), "Advertising preferences" (Facebook) (user registration required).
Microsoft Advertising: search engine advertising on Bing, DuckDuckGo and Yahoo!; provider: Microsoft; Microsoft Advertising-specific information: "Microsoft Advertising Privacy Policy", "Microsoft Advertising Policy: Legal, Privacy and Security", "Advertising Settings" (objection to personalized advertising).
12. EXTENSIONS FOR THE WEBSITE
We use extensions for our website to provide additional functionality.
In particular, we use:
Google reCAPTCHA: spam protection (distinguishing between wanted comments from humans and unwanted comments from bots as well as spam); provider: Google; Google reCAPTCHA-specific information: "What is reCAPTCHA?"
13. PERFORMANCE AND REACH MEASUREMENT
We try to determine how our online offering is 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 to our website. But we can also, for example, try out and compare how different parts or versions of our online offering are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
In most cases, the Internet Protocol (IP) addresses of individual users are stored for performance and reach measurement. In this case, IP addresses are generally shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymization.
Cookies may be used for performance and reach measurement and user profiles may be created. 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 are created exclusively in pseudonymous form and are not used to identify individual users.Individual services of third parties with which users are registered can, if necessary, assign the use of our online offer to the user account or user profile with the respective service.
We use in particular:
Clarity: Recording and analysis of user behavior on websites; Provider: Microsoft; Clarity-specific data protection information: "What data does Clarity collect? ("What data does Clarity collect?", "Data retention"), Cookie policy.
Google Analytics: performance and reach measurement; provider: Google; Google Analytics-specific disclosures:Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA as an exception, "Privacy Policy", "Browser Add-on to deactivate Google Analytics".
Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: "Data collected with Google Tag Manager"; further information on data protection can be found with the individual integrated and managed services.
14. VIDEO SURVEILLANCE
We use video surveillance for the prevention of criminal offences and for the preservation of evidence in the event of criminal offences, as well as for the exercise of our house rights. This involves - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - overriding legitimate interests pursuant to Art. 6 (1) lit. f GDPR.
We store recordings from our video surveillance for as long as they are necessary for the preservation of evidence.
We may secure recordings on the basis of legal obligations, to enforce our own legal claims and in the event of suspected criminal acts, as well as transmit them to competent bodies such as, in particular, judicial or law enforcement authorities.
15. FINAL TERMS
We have created this data protection declaration with the data protection generator of Datenschutzpartner.
We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.
