Politica sulla riservatezza

Privacy Policy

With this Privacy Policy, we inform you about the processing of personal data in connection with our activities and operations, including our niraalpina.com website. We provide information about the purposes, methods, and locations of the processing of various personal data. Additionally, we outline the rights of individuals whose data we process.

For specific or additional activities and operations, separate privacy policies, as well as other legal documents such as Terms and Conditions (T&C), Terms of Use, or Participation Rules, may apply.

We adhere to Swiss data protection law and, where applicable, foreign data protection laws, particularly those 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

Responsible for the processing of personal data:

Alpine Hospitality (Switzerland) AG
Via dal Corvatsch 76
7513 Silvaplana-Surlej
Switzerland

info@niraalpina.com

We will inform you if there are other responsible parties for the processing of personal data in specific cases.

1.1 Data Protection Officer or Data Protection Advisor

We have the following Data Protection Officer or Data Protection Advisor as a point of contact for data subjects and authorities for inquiries related to data protection:

Niculin Manzoni
Alpine Hospitality (Switzerland) AG
Via dal Corvatsch 76
7513 Silvaplana-Surlej
Switzerland

niculin.manzoni@niraalpina.com

1.2 Data Protection Representation in the European Economic Area (EEA)

We have the following data protection representation according to Art. 27 GDPR. The data protection representation serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the General Data Protection Regulation (GDPR):

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

info@niraalpina.com

2.1 Definitions

Personal data refers to any information relating to an identified or identifiable individual. A data subject is a person about whom personal data is processed.

Processing includes any operation or set of operations performed on personal data, regardless of the means and methods used, such as collecting, recording, organizing, storing, adapting, altering, retrieving, consulting, using, disclosing, transmitting, disseminating, aligning, combining, restricting, deleting, or destroying 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.

We process personal data in accordance with Swiss data protection law, including the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection (FADP).

If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data based on at least one of the following legal bases:

  • Art. 6(1)(b) GDPR for the necessary processing of personal data to fulfill a contract with the data subject or to take pre-contractual measures.
  • Art. 6(1)(f) GDPR for the necessary processing of personal data to pursue our legitimate interests or those of third parties, except where such interests are overridden by the fundamental rights and freedoms of the data subject. Legitimate interests include, in particular, our interest in conducting our activities and operations permanently, user-friendly, securely, and reliably, as well as communicating about them, ensuring information security, protecting against misuse, enforcing our own legal claims, and complying with Swiss law.
  • Art. 6(1)(c) GDPR for the necessary processing of personal data to comply with a legal obligation to which we are subject under potentially applicable laws of Member States of the European Economic Area (EEA).
  • Art. 6(1)(e) GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Art. 6(1)(a) GDPR for the processing of personal data with the data subject's consent.
  • Art. 6(1)(d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

3. Type, Scope, and Purpose

We process those personal data that are necessary to carry out our activities and operations permanently, user-friendly, securely, and reliably. Such personal data may include categories of inventory and contact data, browser and device data, content data, meta or marginal data, usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration that is necessary for the respective purpose(s) or as required by law. Personal data that is no longer necessary for processing will be anonymized or deleted.

We may have personal data processed by third parties. We may process or transmit personal data together with third parties. Such third parties are primarily 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 subject unless the processing is permissible for other legal reasons. Processing without consent may be permissible, for example, to fulfill a contract with the data subject and for corresponding pre-contractual measures, to safeguard our overriding legitimate interests, if the processing is evident from the circumstances, or after prior notification.

In this context, we particularly process information that a data subject voluntarily provides to us when contacting us, for example, via postal mail, email, 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, a Customer-Relationship-Management (CRM) system, or similar tools. If we receive data about other individuals from third parties, the transmitting parties are obligated to ensure data protection for these individuals and to ensure the accuracy of this personal data.

Furthermore, we process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of our activities and operations, to the extent and insofar as such processing is permissible for legal reasons.

4. Personal Data Abroad

We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, particularly to process them or have them processed there.

We may export personal data to all countries and territories on Earth as well as elsewhere in the Universe, provided that the local law in accordance with the decision of the Swiss Federal Council ensures adequate data protection and â€“ if and to the extent that the General Data Protection Regulation (GDPR) is applicable â€“ in accordance with the decision of the European Commission ensures adequate data protection.

We may transfer personal data to countries where data protection is not guaranteed, provided that data protection is ensured for other reasons, particularly based on standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if specific data protection requirements are met, such as the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. Upon request, we are happy to provide affected individuals with information about any guarantees or provide a copy of any guarantees.

5. Rights of Data Subjects

Data subjects, whose personal data we process, have the rights according to Swiss data protection law. These rights include the right to information and the right to correct, delete, or block the processed personal data.

Data subjects, whose personal data we process and to the extent that the General Data Protection Regulation (GDPR) is applicable, can request confirmation free of charge as to whether we process personal data concerning them. In such cases, data subjects can request information about the processing of their personal data, restrict the processing of their personal data, exercise their right to data portability, as well as correct, delete ("right to be forgotten"), block, or complete their personal data.

Data subjects, whose personal data we process and to the extent that the GDPR is applicable, have the right to revoke their consent at any time with effect for the future and to object to the processing of their personal data at any time.

Data subjects, over whom we process personal data, have the right to lodge a complaint with a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

6. Data Security

We implement appropriate technical and organizational measures to ensure data security that is appropriate for the respective risks. However, we cannot guarantee absolute data security.

Access to our website is secured through transport encryption (SSL/TLS, especially with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication is subject to mass surveillance without cause or suspicion and other surveillance by security authorities in Switzerland, other parts of Europe, the United States of America (USA), and other countries, as is the case with generally any digital communication. We have no direct influence on the processing of personal data by intelligence services, police authorities, and other security agencies.

7. Use of the Website

7.1 Cookies

We may use cookies. Cookies - both first-party cookies (cookies set by us) and third-party cookies (cookies set by third-party services we use) - are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.

Cookies can be stored in the browser temporarily as "session cookies" or for a specific period as so-called persistent cookies. "Session cookies" are automatically deleted when the browser is closed. Persistent cookies have a specific storage duration. Cookies allow, in particular, the recognition of a browser during the next visit to our website, thus enabling us to measure the reach of our website, for example. Persistent cookies can also be used for online marketing, among other purposes.

Cookies can be disabled or deleted entirely or partially in the browser settings at any time. However, without cookies, our website may not be fully available. We request - at least if required - explicit consent for the use of cookies.

For cookies used for success measurement and reach analysis or for advertising, a general objection ("opt-out") is possible for numerous services via the 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).

7.2 Server Log Files

We may capture the following information for each access to our website, provided they are 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, accessed individual sub-page of our website, including the amount of data transferred, and the last webpage visited in the same browser window (referer or referrer).

We store such information, which may also represent personal data, in server log files. This data is necessary to permanently and reliably provide our website in a user-friendly manner, as well as to ensure data security and, in particular, the protection of personal data - even through third parties or with the assistance of third parties.

7.3 Tracking Pixels

We may use tracking pixels (also known as web beacons) on our website. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can capture the same information as server log files.

8. Notifications and Communications

We send notifications and communications via email and other communication channels, such as instant messaging or SMS.

8.1 Success and Reach Measurement

Notifications and communications may contain web links or tracking pixels that record whether a single notification was opened and which web links were clicked. Such web links and tracking pixels may also capture personal usage data related to notifications and communications. We require this statistical data collection for success and reach measurement purposes, in order to effectively and user-friendly send notifications and communications based on the needs and reading habits of the recipients, as well as to ensure their continuous, secure, and reliable delivery.

8.2 Consent and Objection

You must generally expressly consent to the use of your email address and other contact details, unless the use is permissible for other legal reasons. For possible consent, we will use the "Double Opt-in" procedure whenever possible. This means that you will receive an email with a web link that you need to click to confirm your consent, to prevent misuse by unauthorized third parties. We may log such consents, including Internet Protocol (IP) address, as well as date and time, for evidentiary and security purposes.

You can generally object to receiving notifications and communications, such as newsletters, at any time. By objecting, you can also simultaneously opt-out of the statistical recording of usage data for success and reach measurement. Necessary notifications and communications related to our activities and operations remain unaffected.

8.3 Service Providers for Notifications and Communications

We send notifications and communications using specialized service providers.

We particularly use:

9. Social Media

We are present on social media platforms and other online platforms to communicate with interested individuals and provide information about our activities. In connection with such platforms, personal data may be processed outside of Switzerland and the European Economic Area (EEA).

The terms and conditions, usage policies, privacy statements, and other provisions of each platform's operator apply in each case. These provisions provide information, particularly regarding the rights of data subjects directly vis-à-vis the respective platform, including the right to information.

For our Social Media presence on Facebook, including the so-called Page Insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland) if the General Data Protection Regulation (GDPR) applies. 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 effectively and user-friendly provide our Social Media presence on Facebook.

Further information about the nature, scope, and purpose of data processing, information about the rights of data subjects, as well as contact details of Facebook and Facebook's data protection officer can be found in the Facebook Data Policy. We have concluded the so-called Controller Addendum with Facebook, which, among other things, establishes 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".

10. Services from Third Parties

We use services from specialized third parties to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. With such services, we can embed functions and content into our website. In the course of such embedding, the used services, for technical reasons, may temporarily record the Internet Protocol (IP) addresses of users.

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 an aggregated, anonymized, or pseudonymized form. For example, this includes performance or usage data to provide the respective service.

We use in particular:

10.1 Digital Infrastructure

We utilize services from specialized third parties to access the required digital infrastructure in connection with our activities and operations. This includes hosting and storage services from selected providers.

In particular, we use:

  • WordPress.com: Blog hosting and website builder; Providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users, among others, in Europe; Data protection information: Privacy Policy, Cookie Policy.

10.2 Contact Options

We utilize services from selected providers to enhance communication with third parties, such as potential and existing customers.

In particular, we use:

10.3 Audio and Video Conferences

We use specialized services for audio and video conferences to facilitate online communication. This allows us to conduct virtual meetings, online classes, and webinars. Please note that participating in audio and video conferences is subject to the terms and conditions specified by each service, including their privacy policies and terms of use.

We recommend that, depending on your situation, you consider muting your microphone by default and blurring your background or using a virtual background during audio and video conferences.

In particular, we use:

10.4 Map Material

We use services from third parties to embed maps into our website.

In particular, we use:

10.5 Fonts

We use services from third parties to embed selected fonts as well as icons, logos, and symbols into our website.

In particular, we use:

10.6 Advertising

We use the option to display targeted advertising for our activities and operations on third-party platforms such as social media and search engines.

With such advertising, we aim to reach individuals who are already interested in or might be interested in our activities and operations (remarketing and targeting). For this purpose, we may transmit corresponding â€“ possibly personal â€“ information to third parties that enable such advertising. Additionally, we can determine the success of our advertising, particularly whether it leads to visits to our website (conversion tracking).

Third parties on which we advertise and where you are logged in as a user may associate the use of our online services with your respective profile.

We use in particular:

11. Extensions for the Website

We use extensions for our website to enable additional functionalities.

We use in particular:

  • Google reCAPTCHA: Spam protection (distinguishing between desired comments from humans and undesired comments from bots or spam); Provider: Google; Google reCAPTCHA-specific information: "What is reCAPTCHA?".

12. Success and Reach Measurement

We use services and programs to determine how our online offering is used. In this context, we can measure the success and reach of our activities and operations, as well as the impact of third-party links to our website. For example, we may try out and compare how different versions of our online offering or parts of our online offering are used (A/B test method). Based on the results of the success and reach measurement, we can fix errors, strengthen popular content, or make improvements to our online offering.

When using services and programs for success and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened ("IP masking") to follow the principle of data minimization and improve the privacy of users.

When using services and programs for success and reach measurement, cookies may be used, and user profiles may be created. User profiles may include, for example, the pages visited or the content viewed on our website, information about the size of the screen or browser window, and the at least approximate location. Generally, user profiles are created in a pseudonymized form. We do not use user profiles to identify individual users. Some third-party services, where users are logged in, may associate the use of our online offering with the user account or profile at the respective service.

We use in particular:

  • Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (Cross-Device Tracking) and with pseudonymized Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, "Privacy", "Browser add-on to deactivate Google Analytics".
  • Google Tag Manager: Integration and management of other services for success 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.

13. Video Surveillance

We use video surveillance for the prevention and documentation of criminal offenses, as well as to exercise our right to protect our premises. This is based on overriding legitimate interests according to Article 6(1)(f) of the General Data Protection Regulation (GDPR), provided that the GDPR is applicable.

We store recordings from our video surveillance for as long as necessary for evidence purposes.

We may secure recordings based on legal obligations, to enforce our own legal claims, and in case of suspicion of criminal offenses. Furthermore, we may transmit such recordings to competent authorities, especially to courts or law enforcement agencies.

14. Final Provisions

We have created this privacy policy using the Privacy Policy Generator provided by Datenschutzpartner.

We reserve the right to modify and supplement this privacy policy at any time. We will inform about such changes and additions in an appropriate manner, especially by publishing the current privacy policy on our website.