Privacy Policy
Thisprivacy policyprovides information about the processing of personal data in connection with ouractivities and operations, including ourwebsiteunder the domain name sport-lodge.ch. In particular, we provide information about why, how, and where we process personal data. We also provide information about the rights of individuals whose data we process.
We may publish further data protection declarations or other information on data protection for individual or additional activities and operations.
We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
Inits decision of July 26, 2000, the European Commission recognized that Swiss data protection law ensures adequate data protection. Inits report of January 15, 2024, the European Commission confirmed this adequacy decision.
Table of contents
- 1. Contact addresses
- 2. Terms and legal basis
- 3. nature, scope and purpose of the processing of personal data
- 4. disclosure of personal data
- 5. communication
- 6. applications
- 7. data security
- 8. personal data abroad
- 9. rights of data subjects
- 10. use of the website
- 11 Notifications and messages
- 12. social media
- 13. services of third parties
- 14. success and reach measurement
- 15. final notes on the privacy policy
1. Contact addresses
The responsible party in terms of data protection law is:
Sport-Lodge Klosters
Doggilochstrasse 36
7250 Klosters
In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.
Data protection officers or data protection advisors
We have the following data protection officer or the following data protection advisor as a point of contact for data subjects and authorities for inquiries relating to data protection:
Michaela Wolf
Sport-Lodge Klosters
Doggilochstrasse 36
7250 Klosters
2. Terms and legal basis
2.1 Terms
Data subject: Natural person about whom we process personal data.
Personal data: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data concerning trade union, political, religious or philosophical opinions and activities, data concerning health, privacy or membership of an ethnic or racial group, genetic data, biometric data uniquely identifying a natural person, data concerning criminal or administrative sanctions or prosecutions, and data concerning social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, collection, deletion, disclosure, arrangement, organization, storage, modification, dissemination, linking, destruction and use of personal data.
European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.
2.2 Legal basis
We process personal data in accordance with Swiss law, in particular theFederal Act on Data Protection(Data Protection Act, DPA) and theOrdinance on Data Protection(Data Protection Ordinance, DPO).
If and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process 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 and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests - including the legitimate interests of third parties - unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are, in particular, the permanent, humane, secure and reliable performance of our activities and operations, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill 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 necessary processing of personal data 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 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
- Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. nature, scope and purpose of the processing of personal data
We process personal data that isnecessaryto enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also constitute particularly sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, insofar as such processing is permissible.
We process personal data, where necessary, with the consent of the individuals concerned. In many cases, we can process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also ask individuals for their consent even if their consent is not required.
We process personal data for the duration required for the respective purpose. We anonymize or delete personal data in particular depending on statutory retention and limitation periods.
4. disclosure of personal data
We maydisclose personal datato third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use.
We may disclose personal data within the scope of our activities and operations, in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.
5. communication
We process personal data in order to communicate with individuals, authorities, organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example by letter or email. We may store such data in an address book or similar tool.
Third parties who provide us with data about other persons are obliged to independently ensure the data protection of these persons. In particular, they must guarantee that such data is accurate and may be transmitted.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We can also use such services to manage and otherwise process the data of the persons concerned beyond direct communication.
We use in particular:
- Mews: Property management system (PMS) for hotels and other accommodation; Service provider: Mews System B.V. (Netherlands); Privacy Policy: Privacy Policy, "Data Privacy".
6. applications
We process personal data about applicants to the extent necessary to assess 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 may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms.
We also process personal data that applicants voluntarily disclose or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.
We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants, in particular in accordance with Art. 9 para. 2 lit. b GDPR.
7. data security
We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.
Access to our website and our other digital presence is provided using transport encryption (SSL/TLS, in particular with theHypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption.
Our digital communication - like all digital communication in general - is subject to mass surveillance without cause or suspicion 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 forces and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.
8. personal data abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.
We can export personal data to allcountries on Earthand elsewhere inthe universe, provided that the local law complies withthe decision of the Swiss Federal Counciland—if and to the extent that the General Data Protection Regulation (GDPR) is applicable – also in accordance withthe decision of the European Commission.
We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.
9. rights of data subjects
9.1 Data protection claims
We grant data subjects all rights in accordance with applicable law. Data subjects have the following rights in particular:
- Information: Data subjects can 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 claims and ensure transparency. This includes the processed personal data as such, but also 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.
- Opportunity to express your own point of view and human review: Affected persons can express their own point of view and request verification by a human being in the case of decisions that are based exclusively on automated processing of personal data and that have legal consequences for them or significantly affect them (automated individual decisions).
- Deletion and objection: Data subjects can have their personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.
We may defer, 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 that must be met 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 confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.
In exceptional cases, we may charge costs for the exercise of rights. We will inform affected persons of any costs in advance.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
9.2 Legal protection
Data subjects have the right to enforce their data protection claims by taking legal action or to lodge a complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB ). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany.
10. use of the website
10.1 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 specific 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. Cookies enable us to recognize a browser when you visit our website again and thus measure the reach of our website, for example. Permanent cookies can also be used for online marketing, for example.
Cookies can be completely or partially deactivated, restricted, or deleted at any time in your browser settings. Browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively seek your express consent to the use of cookies, at least to the extent required by applicable law.
For cookies that are used to measure success and reach 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).
10.2 Logging
We can log at least the following information for each access to our website and our other digital presence, provided that this information is determined or transmitted as standard when such accesses are made to our digital infrastructure: date and time including time zone,IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpage of our website accessed including amount of data transferred,last website accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence is permanently available, user-friendly, and reliable. The information is also necessary to ensure data security, including by third parties or with the help of third parties.
10.3 Tracking pixels
We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is recorded in log files.
11 Notifications and messages
11.1 Measuring success and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages effectively and in a user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
11.2 Consent and objection
You must always consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and time stamp, for reasons of proof and security.
You can object to receiving notifications and communications such as newsletters at any time . With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
11.3 Service provider for notifications and messages
We send notifications and messages with the help of specialized service providers.
We use in particular:
- MAILINGWORK: Email marketing platform; Service provider: Mailingwork GmbH (Germany); Privacy policy: Privacy policy, "Privacy policy and sending newsletters - What do you need to know?".
12. social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside 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 particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights - if and insofar as the General Data Protection Regulation (GDPR) is applicable. 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 way.
Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Data Controller Addendum" with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights data".
13. services of third parties
We use services from specialized third parties in order to be able to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used collect the IP addresses of users at least temporarily for technically compelling reasons.
For necessary security, 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.
We use in particular:
- Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) in some cases for users in the European Economic Area (EEA) and Switzerland; General information on data protection:"Data protection and security principles,""More information on how Google uses personal data,"Data protection declaration,"Google is committed to complying with applicable data protection laws," "Guide to data protection in Google products," "How we use data from websites or apps on which our services are used,"Cookie policy,"Advertising you can control" (settings for personalized advertising).
13.1 Digital infrastructure
We use the services of specialized third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
- Hostpoint: Hosting; Service provider: Hostpoint AG (Switzerland); Privacy policy: Privacy policy.
- WordPress.com: Blog hosting and website builder; Service provider: Automattic Inc (USA) / Aut O'Mattic A8C Ireland Ltd (Ireland) for users in Europe and elsewhere; Privacy Policy: Privacy Policy, Cookie Policy.
13.2 Card material
We use third-party services to embed maps in our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: "How Google uses location information".
13.3 E-Commerce
We operate e-commerce and use third-party services in order to successfully offer services, content or goods.
13.4 Payments
We use specialized service providers to process payments securely and reliably. The legal texts of the individual service providers, such as general terms and conditions (GTC) or data protection declarations, also apply to the processing of payments.
We use in particular:
- Stripe: Payment processing; providers: Stripe Inc. (USA) / Stripe Capital Europe Limited (Ireland) / Stripe Payments Europe Limited (SPEL, Ireland) / Stripe Payments UK Limited (United Kingdom); data protection information:"Stripe Privacy Center,"data protection declaration,cookie policy.
13.5 Advertising
We use the option of displaying targeted advertising on third parties such as social media platforms and search engines for our activities and operations.
In particular, we would like to use such advertising to reach people 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 - data to third parties who make such advertising possible. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may be able to assign the use of our website to your profile there.
We use in particular:
- Google Ads: Search engine advertising; Service provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, whereby various domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - are used for Google Ads, privacy policy for advertising, "Manage displayed advertising directly via ads".
- Meta Ads: Social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) andother Meta companies(including in the US); data protection information: targeting, including retargeting, in particular with the Meta Pixel and Custom Audiences including Lookalike Audiences,privacy policy,"advertising preferences"(user registration required).
14. success and reach measurement
We try to measure the success and reach of our activities and operations. In this context, we can also measure the impact of third-party feedback or check how different parts or versions of our digital presence are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content, or make improvements.
In most cases, theIP addressesof individual users are recorded for the purpose of measuring success and reach. In this case, IP addresses arealwaysshortened ("IP masking") in order to comply with the principle of data minimization through pseudonymization.
Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle,any user profiles are created exclusively on a pseudonymous basis and are not used to identify individual users. Individual third-party services to which users are logged in may assign the use of our online offering to the user account or user profile for the respective service.
We use in particular:
- Google Marketing Platform: Success and reach measurement, in particular withGoogle Analytics; provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices(cross-device tracking)with pseudonymized IP addresses, which are only transferred in full to Google in the USAin exceptional cases;privacy policy for Google Analytics,"Browser add-on to disable Google Analytics."
- Google Tag Manager: Integration and management of services from Google and third parties, in particular for measuring success and reach; Provider: Google; Google Tag Manager-specific information: Privacy policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.
15. final notes on the privacy policy
We have created this privacy policy with the data protection generator of Datenschutzpartner.
We may update this privacy policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current privacy policy on our website.