Your privacy rights are our highest priority and we will do our best to protect these rights. We would like to inform you about the type, purpose and scope of the processing of personal data within our online offer (website and integrated services and functions).

We have implemented numerous technical and organizational measures to ensure that the personal data processed is protected as completely as possible. Our security measures are continuously improved in line with technological developments. Nevertheless, data transmission on the Internet can have security gaps, so that absolute protection cannot be guaranteed. You are therefore free to transmit personal data to us in other ways, for example by telephone.

Table of contents

• Nature and purpose of the processed data
• Responsible for processing
• definition of terms
• Your rights
• Legal basis of processing
• Duration of storage
• deletion
• Cooperation with processors
• Tramino software and services
  • Hosting, access data and log files
  • Using Amazon Web Services (Cloudfront/S3)
  • Use of cookies
  • SSL encryption
  • contact forms
  • Booking & ordering system
• Social networks
  • Our presence on social networks
• Google services
  • Use of YouTube
  • Use of Google Analytics
  • Use of Google Maps
  • Use of Google Fonts (local hosting)
  • Use of Google ReCaptcha
• Validity of the privacy policy

Nature and purpose of the processed data

Type of data processed

• Address data (first and last name, address, telephone number, e-mail)
• Text input (messages), photographs (uploads)
• Usage data, websites visited, access times
• IP addresses and metadata (device information)

Affected people

• Visitors and users of our online offer

purpose of processing

• Provision of the online presence with content and functions
• Processing of bookings and orders
• Processing of contact requests and sent messages
• Safety measures
• Statistical evaluations

Responsible for processing

Responsible in terms of the General Data Protection Regulation is:

Curlconsult – Curling Development, Consulting & Management
Sebastian Stock
Riedweg 20
3806 Bönigen
SWITZERLAND
Mobile +41 79 8309893
info@curlconsult.com

definition of terms

• "Personal data" is all information that can be identified about persons known to us or by means of data stored by us.
• "Processing" is any operation carried out manually or automatically, in which personal data is loaded, assigned, stored or changed.
• We refer to persons, authorities or institutions who decide on the purposes and means of processing personal data as “responsible persons”.

Your rights

• You have the right to confirmation as to whether your data is being processed by us, to information about this information and to the provision of a copy of the data (Art. 15 GDPR)
• You have the right to correct or complete the data concerning you (Article 16 GDPR)
• You have the right to have your data deleted immediately (Article 17 GDPR) or to request that their processing be restricted (Article 18 GDPR).
• You have the right to receive your personal data as a file or to request transmission to other responsible parties (Art. 20 GDPR)
• You have the right to object to future processing of your data at any time (Art. 21 GDPR)
• You have the right to revoke your consent in accordance with Article 7 (3) GDPR with effect for the future
• You also have the right, in accordance with Article 77 GDPR, to lodge a complaint with the competent supervisory authority.

Legal basis of processing

Art. 6 of the GDPR serves our company as the legal basis for all processing operations. We only process your data if:

• you have given your consent to the processing of your personal data for one or more specific purposes
  the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures, which take place at your request
• the processing is necessary for compliance with a legal obligation to which you are subject
• the processing is necessary to protect your vital interests or those of another person
• the processing is necessary for the performance of a task that is in the public interest or in the exercise of official authority that has been assigned to us (Meldegesetz)
• the processing is necessary to protect our legitimate interests or those of a third party, unless the interests or fundamental rights and freedoms of the data subject that require the protection of personal data prevail, especially if the data subject is a child.

Duration of storage

We adhere to the respective statutory retention period for the maximum duration of the storage of your personal data. After this period has expired, the corresponding data will be routinely deleted if they are no longer required to fulfill the contract or to initiate a contract

deletion

All personal data processed by us will be deleted or restricted for further processing in accordance with Art. 17 & 18 DSGVO. In concrete terms, this means: Personal data will be deleted if they are no longer required to fulfill the desired purposes or if the statutory storage obligation has expired. This applies in particular to invoices, accounting documents and business records.

Cooperation with processors

If a transmission of the data to third parties is necessary to fulfill the contract, this only takes place:

• on the basis of the legal permission in accordance with Article 6 (1) (b) GDPR
  based on your consent
• if there is a legal obligation to do so
• on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.)
• If we commission third parties with the processing on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 DSGVO.

Tramino software and services

For the operation of this website and the associated software, we use the products of our technical service provider Tramino (head office: Weststrasse 30, D-87561 Oberstdorf, data protection declaration )on the basis of our legitimate interests in accordance with Article 6 (1) (f) GDPR and one Order processing contract in accordance with Article 28 Paragraph 3 Sentence 1 GDPR. The service provider does not use the personal data processed in the process itself or pass it on to third parties.

Together with Tramino, we use technical and organizational security measures in accordance with § 9 BDSG to protect your data managed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons. Our security measures are continuously improved in line with technological developments. We store information relevant to data protection exclusively on secure IT systems in Germany. Access to it is only possible for a few authorized persons and persons who are responsible for the technical, administrative or editorial support of data and who are responsible for special data protection.

Hosting, access data and log files

For the purpose of operating this online offer, we use hosting services from Tramino for the following services:

• Provision of our online platform
• Provision of software, computing capacity, storage space and database
• Security services and technical maintenance

In doing so, we or our hosting provider process content data, personal data, contract data, usage data, meta and communication data on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Article 6 Paragraph 1 Letter f GDPR in conjunction with Article 28 GDPR of customers, interested parties and visitors of this online offer. In particular, every access to the server on which this service is located is stored in a log file.

In detail, the following is saved:

• Name of the retrieved web page or file
• Date and time of retrieval
• amount of data transferred, notification of successful retrieval
• Browser type and version as well as the operating system used
• the address of the previously visited website
• the IP address of the visitor from the provider used

Log file information is stored for a maximum of 30 days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

Our hoster will only process your data to the extent that this is necessary to fulfill its performance obligations and will follow our instructions in relation to this data.

If a corresponding consent was requested, the processing takes place exclusively on the basis of Art. 6 Para. 1 lit. a DSGVO and § 25 Para B. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Our hoster (Tramino) obtains its technical infrastructure from IDKOM Networks GmbH , Dieselstraße 1, 87437 Kempten (Allgäu) and has concluded an order processing contract with this subcontractor.

Amazon Web Services (Cloudfront/S3)

We use the Content Delivery Network (CDN) "Amazon CloudFront" which is based on the storage service "Amazon S3". The provider is Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg.

We use the "Cloudfront" and "S3" services from Amazon Web Services to deliver images and files on our website. The domains are: storage.tramino.net (Cloudfront) and tramino.s3.amazonaws.com (S3)

Amazon CloudFront is a globally distributed content delivery network. Technically, the information transfer between your browser and our website is routed via the content delivery network. This enables us to increase the global accessibility and performance of our website.

The use of Amazon CloudFront and S3 is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6 Para. 1 lit. f GDPR). Data transfer to the USA is based on the standard contractual clauses of the EU Commission. See here for details . Learn more about Amazon CloudFront CDN here .

We have concluded an order processing contract (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that the personal data of our website visitors is only processed according to our instructions and in compliance with the GDPR.

Use of cookies

Our website uses cookies. Cookies are small text files that are filed and saved on your computer system via your internet browser. A specific internet browser can be recognized and identified via the unique cookie ID. The purpose of this recognition is to make it easier for users to use our website. In detail, we use cookies as follows:

• We assign the contents of your shopping cart to your browser so that you can continue a booking or order that you have started at a later point in time.
• If you make settings on our site (e.g. the travel period in the booking mask), we assign them to your browser so that you do not have to enter them again the next time you visit
• If you access our site via a link from another site, we assign the previous address to your cookie and read this information in the event of a booking, order or inquiry in order to be able to statistically determine how our customers found us
• If you use a login function, you do not have to re-enter your access data every time you visit your website

You can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. In addition, cookies that have already been set can be deleted in your Internet browser at any time. If you permanently deactivate the setting of cookies, not all functions of our website may be usable.

SSL encryption

In order to protect the security of your data during transmission, we use state-of-the-art encryption methods (e.g. SSL) via HTTPS.

contact forms

Our contact forms are processed with software from Tramino (headquarters: Weststrasse 30, D-87561 Oberstdorf, data protection declaration ). If you contact us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user will be processed in order to process the contact request and its processing in accordance with Article 6 (1) (b) GDPR. User information is stored in a customer relationship management system ("CRM system"). We delete the requests if they are no longer necessary to fulfill your request. We review necessity every two years; Furthermore, the statutory archiving obligations apply.

Booking & ordering system

Our bookings or orders are processed with software from Tramino (headquarters: Weststrasse 30, D-87561 Oberstdorf, data protection declaration ). This service provider is used on the basis of our legitimate interests in accordance with Article 6 Paragraph 1 lit .

Data collected when booking or ordering (address data with address, communication data such as telephone number and e-mail address) as well as information on the accompanying persons (names, dates of birth) are stored in a customer relationship management system ("CRM system"). If you provide special personal data that is relevant to the fulfillment of our services, e.g. If, for example, you indicate allergy-related intolerances, these are also saved. We delete this data if it is no longer required to fulfill your request. We review necessity every two years; Furthermore, the statutory archiving obligations apply.

Our presence on social networks

We are involved in social networks and platforms in order to be able to communicate with the customers and prospects active there and to be able to provide information about our services. When using the respective networks or platforms, the terms and conditions and data protection guidelines of their respective operators apply. We only process user data if they communicate with us on social networks or platforms, write posts or send us messages.

Use of YouTube

This website includes videos from the YouTube website . The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We always embed YouTube videos in such a way that no elements are loaded from YouTube before you click "Play" to watch the video.

In some cases, YouTube videos can also be integrated in the extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the extended data protection mode does not necessarily exclude the transfer of data to YouTube partners. This is how YouTube establishes a connection to the Google DoubleClick network, regardless of whether you are watching a video.
As soon as you start a YouTube video on this website, a connection to the YouTube servers is established. The YouTube server is informed which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, YouTube can save various cookies on your end device after starting a video or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can receive information about visitors to this website. This information is used, among other things, to collect video statistics, to improve user-friendliness and to prevent attempts at fraud. If necessary, after the start of a YouTube video, further data processing operations can be triggered over which we have no influence.

YouTube is used in the interest of an attractive presentation of our online offers. This represents a legitimate interest within the meaning of Article 6 Paragraph 1 Letter f GDPR. If a corresponding consent has been requested, the processing takes place exclusively on the basis of Article 6 Paragraph 1 Letter a GDPR and Article 25 Paragraph 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

You can find more information about data protection at YouTube in their data protection declaration .

Use of Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as B. Page views, length of stay, operating systems used and origin of the user. This data is assigned to the respective end device of the user. There is no assignment to a user ID.

Furthermore, we can use Google Analytics to record your mouse and scrolling movements and clicks, among other things. Furthermore, Google Analytics uses various modeling approaches to supplement the recorded data sets and uses machine learning technologies for data analysis. Google Analytics uses technologies that enable the user to be recognized for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transmitted to a Google server in the USA and stored there.

The use of this service is based on your consent in accordance with Article 6 Paragraph 1 Letter a GDPR and Section 25 Paragraph 1 TTDSG. The consent can be revoked at any time. Data transfer to the USA is based on the standard contractual clauses of the EU Commission. See here for details .

IP anonymization:We have activated the IP anonymization function on this website. As a result, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before it is transmitted to the USA. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser plugin: You can prevent Google from collecting and processing your data by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de. More information on how Google Analytics handles user data can be found in Google's privacy policy .

Google Analytics Ecommerce Measurement:This website uses the "e-commerce measurement" function of Google Analytics. With the help of e-commerce measurement, the website operator can analyze the purchasing behavior of website visitors to improve their online marketing campaigns. Information such as the orders placed, average order values, shipping costs and the time from viewing a product to purchasing it are recorded. This data can be summarized by Google under a transaction ID that is assigned to the respective user or their device.

Order processing: We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Disable Google Analytics

Use of Google Maps

We bind the maps of the “Google Maps” service provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. A contract has been concluded with Google in accordance with the EU standard contractual clauses to ensure an appropriate level of data protection when transferring personal data to third countries. Please also note the data protection declaration of Google.

We use the Google Maps API to visually display geographic information. When using Google Maps, Google also collects, processes and uses data about the use of the map functions by visitors. You can find more information about data processing by Google in the Google data protection informationremove . There you can also change your personal data protection settings in the data protection center.

Use of Google Fonts (local hosting)

This site uses so-called Google Fonts, which are provided by Google, to display fonts. The Google fonts are installed locally at our web host Tramino and are delivered from the comet.tramino.net domain. There is no connection to Google servers.

For more information about Google Fonts, see the Google Fonts FAQ and "Google's privacy policy"https://policies.google.com/privacy?hl=de.

Use of Google ReCaptcha

We integrate the function for detecting bots, e.g. when making entries in online forms ("ReCaptcha") from the provider Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. A contract has been concluded with Google in accordance with the EU standard contractual clauses to ensure an appropriate level of data protection when transferring personal data to third countries. Please also note the data protection declaration of Google.

With Google reCaptchaIt should be checked whether the data input on our website (e.g. in a contact form) is done by a human or by an automated program. For this purpose, reCaptcha analyzes the behavior of the website visitor based on various characteristics (e.g. IP address, length of stay of the website visitor on the website or mouse movements made by the user). This analysis starts automatically as soon as the website visitor enters the website. The data collected is forwarded to Google in the background and the website visitor is not informed that an analysis is taking place.

Validity of the privacy policy

By using our website, you agree to the use of data described above. It may become necessary to change this data protection declaration due to the further development of our website or the implementation of new technologies. We reserve the right to change the data protection declaration at any time with effect for the future. We therefore recommend that you read the data protection declaration again regularly.