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Privacy Policy

1. Privacy at a Glance

General information: The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on data protection, please refer to our Privacy Policy below.

Who is responsible for data collection on this website? Data processing on this website is carried out by the website operator. You can find their contact details in the section 'Notice regarding the responsible party' in this Privacy Policy.

How do we collect your data? Some data is collected when you provide it to us — for example, data you enter into a contact form. Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g. internet browser, operating system, or time of page access). This data is collected automatically as soon as you access this website.

What do we use your data for? Part of the data is collected to ensure the website is provided without errors. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated via the website, the transmitted data is also processed for contract offers, orders or other service requests.

What rights do you have regarding your data? You have the right at any time to receive free information about the origin, recipients and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

Analytics tools and third-party tools: When you visit this website, your browsing behaviour may be statistically analysed. This is done primarily using so-called analytics programmes. Detailed information on these analytics programmes can be found in this Privacy Policy.

2. Hosting

We host the content of our website with the following provider: External hosting. This website is hosted externally. The personal data collected on this website is stored on the servers of the host. This may include IP addresses, contact requests, meta and communication data, contractual data, contact details, names, website accesses and other data generated via a website.

External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6(1)(f) GDPR). Where appropriate consent has been obtained, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

We use the following host: IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. E-mail: datenschutz@ionos.de

Our host will only process your data to the extent necessary to fulfil its service obligations and will follow our instructions with regard to this data.

Data processing agreement: We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law which guarantees that the personal data of our website visitors is processed only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Disclosures

Data protection: The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this Privacy Policy. When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This Privacy Policy explains what data we collect and what we use it for. It also explains how and for what purpose this takes place. We would like to point out that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Notice regarding the responsible party: The party responsible for data processing on this website is: Jürgen Eberth, Private Travel Club, Sudetenstr. 12, 96250 Ebensfeld, Germany. Phone: +49 151 42357021. E-mail: contact@private-travel-club.com. The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses).

Storage duration: Unless a more specific storage period has been stated in this Privacy Policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion takes place after these reasons cease to apply.

Legal bases for data processing on this website: Where you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR where special categories of data are processed pursuant to Art. 9(1) GDPR. In the case of an express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. Where you have consented to the storage of cookies or access to information on your device (e.g. via device fingerprinting), processing is additionally based on § 25(1) TDDDG. Consent can be revoked at any time. Where data is required for the performance of a contract or for pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data where required to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR.

Recipients of personal data: In the course of our business activities, we work with various external parties. In doing so, it is sometimes necessary to transfer personal data to these external parties. We only pass on personal data to external parties where this is necessary for the performance of a contract, where we are legally obliged to do so (e.g. disclosure to tax authorities), where we have a legitimate interest in doing so pursuant to Art. 6(1)(f) GDPR, or where another legal basis permits the transfer. When using processors, we only pass on personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to data processing: Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of data processing carried out before the revocation remains unaffected.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR): Where data processing is based on Art. 6(1)(e) or (f) GDPR, you have the right at any time to object to the processing of your personal data on grounds relating to your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this Privacy Policy. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims (objection pursuant to Art. 21(1) GDPR). Where your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection pursuant to Art. 21(2) GDPR).

Right to lodge a complaint with a supervisory authority: In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged breach. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedy.

Right to data portability: You have the right to have data which we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a standard, machine-readable format. Where you request the direct transfer of data to another controller, this will only be done insofar as it is technically feasible.

Access, rectification and erasure: Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correction or deletion of this data. For this and any other questions on the subject of personal data, you can contact us at any time.

Right to restriction of processing: You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases: If you dispute the accuracy of your personal data stored with us, we generally need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data. If the processing of your personal data was or is unlawful, you can request the restriction of data processing instead of erasure. If we no longer need your personal data, but you need it for the exercise, defence or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure. If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data. Where the processing of your personal data has been restricted, this data may — apart from being stored — only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

SSL/TLS encryption: This website uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the website operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from 'http://' to 'https://' and by the padlock symbol in your browser line. When SSL/TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to advertising emails: The use of contact data published within the framework of the obligation to provide an imprint for the purpose of sending unsolicited advertising and information materials is hereby expressly prohibited. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam emails.

4. Data Collection on This Website

Server log files: The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: browser type and browser version, operating system used, referrer URL, hostname of the accessing computer, time of server request, IP address. This data is not merged with other data sources. This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of his website — for this purpose, the server log files must be recorded.

Contact form: If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you provide there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not share this data without your consent. The processing of this data is carried out on the basis of Art. 6(1)(b) GDPR, where your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time. The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after we have completed processing your enquiry). Mandatory statutory provisions — in particular retention periods — remain unaffected.

Enquiry by e-mail or telephone: If you contact us by e-mail or telephone, your request including all resulting personal data (name, request) will be stored and processed by us for the purpose of handling your request. We do not share this data without your consent. The processing of this data is carried out on the basis of Art. 6(1)(b) GDPR, where your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time. The data you send us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Mandatory statutory provisions — in particular statutory retention periods — remain unaffected.

5. Social Media

Instagram: Functions of the Instagram service are integrated on this website. These functions are offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. When the social media element is active, a direct connection is established between your device and the Instagram server. Instagram thereby receives information about your visit to this website.

If you are logged into your Instagram account, you can link the content of this website with your Instagram profile by clicking the Instagram button. This allows Instagram to associate your visit to this website with your user account. We point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Instagram. The use of this service is based on your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

Where personal data is collected on our website using the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of data and its forwarding to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The text of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Instagram tool and for the privacy-compliant implementation of the tool on our website. Facebook is responsible for the data security of the Instagram products. Data subject rights (e.g. requests for information) regarding the data processed at Instagram can be asserted directly with Facebook. If you assert data subject rights with us, we are obliged to forward them to Facebook.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381

The company holds a certification under the 'EU-US Data Privacy Framework' (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/4452

For further information, please refer to Instagram's Privacy Policy: https://privacycenter.instagram.com/policy/

6. Analytics Tools

Google Tag Manager / Google Analytics: This website uses Google Tag Manager and Google Analytics, services provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies that enable analysis of your use of the website. The information generated by the cookie about your use of this website is generally transmitted to and stored on a server of Google in the USA.

The use of Google Analytics is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. Where appropriate consent has been obtained, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR. Consent can be revoked at any time.

The company holds a certification under the 'EU-US Data Privacy Framework' (DPF). For further information on how Google handles user data, please refer to Google's Privacy Policy: https://policies.google.com/privacy

Yandex.Metrica: This website also uses Yandex.Metrica, a web analytics service provided by Yandex LLC, Ulitsa Lva Tolstogo 16, Moscow, Russia. Yandex.Metrica uses cookies to analyse user behaviour. Data collected is stored on Yandex servers in Russia. As Russia does not provide an equivalent level of data protection to the EU, the transfer of data is carried out on the basis of your explicit consent in accordance with Art. 49(1)(a) GDPR. Consent may be withdrawn at any time. For more information: https://yandex.ru/legal/confidential

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