Privacy Policy

Privacy policy of Siemanet S.L.

(as of 25.05.2018)

As part of our privacy policy we inform the clients of our agency and the visitors of our Internet presence about the collection and processing of personal data by us. Personal data is any information that can be related to an identified or identifiable natural person, for example names, addresses, e-mail addresses, but also user behaviour.

1. Who is to be responsible for data processing?

Siemanet S.L. is responsible in the meaning of the General Data Protection Regulation (GDPR).

If there are any questions regarding data protection, feel free to contact us for assistance.

2. On what legal basis do we process personal data?

We process personal data in accordance with the guidelines of the European General Data Protection Regulation (GDPR).

According to Article 6 of the GDPR, data may be processed on the basis of consent, for the fulfilment of contractual obligations or pre-contractual measures, due to statutory provisions, in the public interest or insofar as the processing is necessary to protect our legitimate interests or the legitimate interests of a third party, unless the interests and fundamental freedoms of the data subject, which require the protection of personal data, prevail.

3. Which data is collected and processed by us during visits to our website?

When you visit our website for information purposes, i.e. if you do not register or otherwise provide us with information, we will only collect the personal data that your browser transmits to our server (the so-called "server log files"). The following data is of technical importance to present our Internet pages to you:

The IP address, date and time of the request, the time zone difference to Greenwich Mean Time (GMT), the exact content of the request (the specific page), the access status/HTTP status code, the amount of data transmitted, the source/internet page which sent the request, the browser you are using, the operating system used and its surface as well as the language and version of your browser software.

The processing is carried out in accordance with Article 6 paragraph 1 f) of the GDPR to ensure a smooth connection setup of our Internet pages, to guarantee a comfortable use of our website, to evaluate the system security and stability as well as for further administrative purposes.

Under no circumstances do we use the data collected for the purpose of drawing conclusions about you personally.

4. What data is collected and processed by us when providing our services?

We process the data provided to us as part of the provision of our services. The legal basis for this can be found in Art. 6 para. 1 b), c) and f) GDPR.

In addition, the service providers we use (such as logistics companies, payment intermediaries) receive the necessary data on your person or the service to be provided for you.

As part of the operation of our company, we process your data using our IT systems. In some cases, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly inspected.

5. How is data processed by us in case of inquiries or messages by mail, fax, e-mail or via contact form?

If you send us inquiries and other communications by mail, by fax, by email or via a contact form, which relate to the provision of our services, we will store your request or message and our response within the framework of our legal obligations to preserve them as correspondence to each booking.

In case of other inquiries or messages by mail, fax, e-mail or via contact form, we use your personal data provided exclusively to answer your inquiry, but do not subsequently store your inquiry and personal data provided in the inquiry.

6. With whom do we share personal data?

When you visit our website, we use cookies and/or analysis services. We will provide you with a detailed explanation in the further course of our privacy policy.

As part of bookings we pass on your personal data as far as this is necessary for the execution of bookings. For the processing of payments, we pass on the required payment data to the credit institution commissioned with the payment and, if applicable, to the payment service provider commissioned by us.

7. How long will personal data be stored by us?

The storage period of personal data is determined by the respective legal obligation to preserve records. The legal basis for the corresponding use of data complies with Article 6 paragraph 1 c) of the GDPR.

After expiry of the respective legal retention period, the corresponding data will be routinely deleted, provided that they are no longer necessary for the contractual performance or contract initiation and/or there is no longer any legitimate interest on our part in the continuation of a storage.

8. What rights are available to persons who are involved in data processing?

The applicable data protection law grants our customers and visitors of our Internet presence the following rights with regard to personal data concerning them:

- Right of access pursuant to Article 15 of the GDPR

You have the right to request information from us about the existence and details of the processing of personal data concerning you under the conditions of Article 15 of the GDPR.

- Right to rectification pursuant to Article 16 of the GDPR

You have the right to request us to instantly correct any inaccurate personal data concerning you.

- Right to erasure pursuant to Article 17 of the GDPR

You have the right to request us to delete your personal data under the conditions of Article 17 paragraph 1 of the GDPR.

- Right to restriction of processing pursuant to Article 18 of the GDPR

Under the conditions of Article 18 of the GDPR you have the right to request us to restrict the processing of your personal data.

- Right to data portability pursuant to Article 20 of the GDPR:

Under the conditions of Article 20 of the GDPR, you have the right to receive the personal data, which you have provided us, in a structured, current and machine-readable format or to request the transmission to another person responsible.

- Right to revoke consents granted, pursuant to Article 7 paragraph 3 of the GDPR

You have the right to withdraw a consent to the processing of your personal data you have provided to us at any time.

- Right to lodge a complaint pursuant to Article 77 of the GDPR

You have the right to lodge a complaint to a competent supervisory authority, in particular in the Member State of your residence, place of work or place of suspected infringement, if you consider that the processing of your personal data is contrary to the General Data Protection Regulation.

9. What consents have been given to us?

Without appropriate information of certain personal data it is not possible to claim the services offered by us.

10. What consents have been given to us?

You may have given us consents for making contact for advertising purposes or for certain data uses (for example to submit a newsletter). If you have given us a consent, the corresponding texts are stored by us and can be recalled. To access these texts, simply contact us by e-mail at the address given in section 1 of this privacy policy. We will subsequently send you the requested information by e-mail.

11. Use of cookies

We use so-called cookies on various pages to make our website more attractive and to enable the use of certain features. Cookies are small text files which are stored on your terminal device (laptop, tablet, smartphone or the like) when you visit our website. Cookies are used to make our website more user-friendly and effective overall. Cookies do no damage to your terminal device, do not contain viruses, Trojans or other malware.

Some of the cookies we use are deleted at the end of the browser session, i.e. after closing your browser (so-called transient or session cookies).

Other cookies remain on your terminal device and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (so-called persistent cookies). If cookies are set, they collect and process certain user information such as browser and location data as well as IP address values to the individually defined extent. Persistent cookies are automatically deleted after a specified period, but the duration up to deletion may vary depending on the cookie.

If any personal data is collected by individual cookies used by us, it is processed in accordance with Article 6 paragraph 1 f) of the GDPR to safeguard our legitimate interests in the best possible functionality of our Internet presence and a customer-friendly and effective configuration of the site visit.

We may work with third-party providers who help us to make our website more appealing to you. For this purpose, third party cookies will also be stored on your terminal device when you visit our website. If we cooperate with the aforementioned third-party providers, you will be informed separately about the use of such cookies and the extent of the information collected in each case in the further course of our privacy policy.

Please note that you can adjust your browser so that you are informed about each setting of cookies. You can also configure your browser so that you can decide whether to accept cookies or to exclude the acceptance of cookies in certain cases or in general. There are various ways in which different browsers determine the cookie settings. Changing the settings regarding the acceptance or rejection of cookies is described in the help menu of each browser, which will show you how you can change your cookie settings. You may also request that the stored cookies be deleted at any time with regard to the browser you are using.

Please note that the functionality of our Internet pages may be limited if cookies are not accepted.

12. Data security

For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries), our website uses SSL or TLS encryption. Whether an individual page of our website is transmitted in encrypted form is indicated by the closed key or lock symbol in the lower status bar of the browser you are using.

Apart from that, we use suitable technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

13. No application of automated decision making

Hereby we assure that we do not conduct any automatic decision making including profiling.

14. Information on the right to object to processing pursuant to Article 21 of the GDPR

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is carried out by us on the basis of Article 6 paragraph 1 e) or f) of the GDPR.; this also applies to profiling based on these regulations.

We will then no longer process the personal data unless we can prove compelling reasons worthy of protection for the processing which outweigh the interests, rights and freedoms of the data subject or the processing serves to assert, exercise or defend legal claims.

If we process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing. If you object to the processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Please send your objection informally to the contact address given at the beginning of our privacy policy under section 1.