The Travel Data + Analytics GmbH is particularly concerned about data protection. Our efforts in particular to meet the requirements of the European Data Protection Regulation (GDPR) and the Federal Data Protection Act in its new version are primarily aimed at respecting your privacy and personal sphere.
For modern companies such as Travel Data + Analytics GmbH, the use of electronic data processing equipment (EDP) is indispensable nowadays. Of course, we will do our utmost to comply with the legal regulations.
The internet pages of Travel Data + Analytics GmbH can be used without any personal data. However, if a person concerned wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.
Under no circumstances will we sell or rent your personal information to third parties for their marketing or other purposes. If you do not agree with the provisions of the data protection regulations, please do not send any personal data to us.
1. general / definition of terms
This data protection declaration is based on terms of the GDPR and should be easy to read and understand for every person. For this reason, we would like to explain various terms in advance:
a) Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). A natural person shall be considered identifiable if he can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
b) Data Subject / Data Subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
Processing” means any operation or set of operations which is carried out with or without the aid of automated processes and which relates to personal data, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, qualification, erasure or destruction.
d) Limitation of processing
Limitation of processing is the marking of stored personal data with the aim of limiting their future processing.
Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movement of that natural person.
Pseudonymisation means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
g) Responsible person
The controller shall be the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the controller or controllers may be designated in accordance with Union law or with the law of the Member States on the basis of specific criteria.
h) Processor/processor of commissioned data
Processor / data processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not that person is a third party. However, authorities which may receive personal data in the course of a specific investigation task under Union law or the law of the Member States shall not be considered as recipients.
j) Third parties
Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or processor.
Consent shall mean any voluntary, informed and unambiguous expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, indicating that he or she consents to the processing of his or her personal data.
2. information on the collection of personal data
(1) In the following we inform you about the collection of personal data when using our website. Personal data are all data that can be related to you personally, e.g. name, address, e-mail addresses, user behaviour, etc..
(2) The person responsible pursuant to Art. 4 Para. 7 of the EU Basic Data Protection Regulation (GDPR) is
Travel Data + Analytics GmbH
Represented by the CEO Dr. Markus Heller
D-90408 Nuremberg, Germany
Tel.: +49 (0)911 951 510 00
(3) Our data protection officer is:
Mr. Sascha Weller, Attorney at Law, IDR – Institute for Data Protection Law
D-85049 Ingolstadt, Germany
Tel.: +49 (0)841 / 885 167 15
(4) When you contact us by e-mail or via a contact form, the data you provide us with (your e-mail address, possibly your name and telephone number) will be automatically stored by us in order to answer your questions. Such personal data transmitted on a voluntary basis by a data subject to the data controller will be stored exclusively for the purpose of processing or contacting the data subject. We delete the data arising in this connection after the storage is no longer necessary, or restrict the processing if there are legal storage obligations.
(5) If we wish to use contracted service providers for individual functions of our offer or to use your data for advertising purposes, we will inform you below in detail about the respective processes. We will also specify the criteria for the storage period.
(6) As the person responsible for processing, we have implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, each person concerned is free to transmit personal data to us by alternative means, such as telephone.
(7) As a responsible company, we refrain from automatic decision-making or profiling.
3. your rights
(1) You have the following rights against us with regard to the personal data concerning you:
– Right of access:
Every person affected by the processing of personal data has the right granted by the DS-GVO to obtain at any time free information from the controller about the personal data stored about him and a copy of this information. Furthermore, the European Directive and Regulation Body has granted the data subject access to the following information:
- the purposes of the processing
- the categories of personal data processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
- if possible, the planned duration for which the personal data will be stored or, if that is not possible, the criteria for determining that duration
- the existence of a right to the rectification or erasure of personal data concerning him or her or to the limitation of the processing carried out by the controller or of a right to object to such processing
- the existence of a right of appeal to a supervisory authority
- if the personal data are not collected from the data subject: All available information on the origin of the data
- the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the DS Block Exemption Regulation and, at least in these cases, meaningful information on the logic involved, the scope and the intended effects of such processing on the data subject
In addition, the data subject has the right to know whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.
If a data subject wishes to exercise this right of access, he or she may at any time contact an employee of the controller.
– Right to revoke consent under data protection law:
Every person affected by the processing of personal data has the right to revoke consent to the processing of personal data at any time.
If a data subject wishes to exercise this right to withdraw consent, he or she may do so at any time and by any means of communication by contacting an employee of the controller.
– Right to rectification:
The data subject shall have the right to request the controller to rectify without delay any inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to request the completion of incomplete personal data, including by means of a supplementary statement.
If a data subject wishes to exercise this right of access, he or she may at any time contact an employee of the controller.
– Right to deletion / right to be forgotten:
The data subject has the right to ask the controller to delete personal data relating to him or her without delay and the controller is obliged to delete personal data without delay if one of the following reasons applies:
- the personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
- the data subject withdraws the consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) and there is no other legal basis for the processing.
- the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate reasons for the processing or the data subject objects to the processing pursuant to Article 21(2).
- the personal data have been unlawfully processed.
- the erasure of the personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
- the personal data have been collected in relation to information society services offered in accordance with Article 8(1).
If a data subject wishes to exercise this right of cancellation/forgetfulness, he or she may at any time do so by contacting a member of staff of the controller.
If we have made the personal data public and if we are obliged to delete them pursuant to Art. 17 Para. 1 DS-GVO, we will take account of the available technology and the implications of the data protection act and will take all reasonable steps to ensure that the data is deleted.
– Right to limit the processing:
The data subject shall have the right to request the controller to restrict the processing if one of the following conditions is met:
- the accuracy of the personal data is contested by the data subject for a period of time which allows the controller to verify the accuracy of the personal data,
- the processing is unlawful and the data subject refuses to erase the personal data and instead requests the restriction of the use of the personal data;
- the controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the assertion, exercise or defence of legal rights, or
- the data subject has objected to the processing referred to in Article 21(1) before it has been established whether the controller’s legitimate reasons outweigh those of the data subject.
If a data subject wishes to exercise this right of limitation, he or she may at any time contact a member of staff of the controller.
– Right to object to the processing:
Any person data subject to the processing of personal data has the right under the DS-GVO to object at any time, on grounds relating to his/her particular situation, to the processing of personal data concerning him/her carried out pursuant to Article 6(1)(e) or (f) of the DS-GVO. This also applies to profiling based on these provisions.
In the event of objection, we will no longer process the personal data unless we can prove compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the person concerned, or the processing serves to assert, exercise or defend legal claims.
If we process personal data for the purpose of direct advertising, the data subject shall have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling as far as it is connected with such direct advertising. If the data subject objects to our processing for direct marketing purposes, we will no longer process the personal data for these purposes.
In addition, the data subject shall have the right to object to the processing of personal data relating to him or her by us for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) DS-GVO for reasons arising from his or her particular situation, unless such processing is necessary for the performance of a task in the public interest.
In order to exercise the right to object, the data subject may contact any employee directly. The data subject is also free to exercise his or her right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
– Right to data transfer:
The data subject shall have the right to obtain the personal data relating to him which he has provided to a controller in a structured, common and machine-readable format and shall have the right to communicate such data to another controller without being impeded by the controller to whom the personal data have been provided, provided that
- the processing is based on a consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b), and
- processing is carried out using automated procedures.
When exercising his/her right to data transferability pursuant to Art. 20 para. 1 DS-GVO, the data subject shall have the right to obtain that the personal data be transferred directly from one data controller to another data controller, insofar as this is technically feasible and the rights and freedoms of other persons are not impaired.
If a data subject wishes to exercise this right to data transfer, he or she may at any time contact an employee of the controller.
– Automated decision in individual cases including profiling
Any person data subject to the processing of personal data has the right under the DS-GVO not to be subject to a decision based solely on automated processing, including profiling, which has legal effect in relation to him or her, or to whom the processing of personal data may give rise, or to whom the processing of personal data may give rise, or to whom the processing of personal data may give rise, to the processing of personal data under the DS-GVO.
(1) is not necessary for the conclusion or performance of a contract between the data subject and the data controller, or
(2) is authorised by Union or national legislation to which the data controller is subject and contains appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, or
(3) with the express consent of the data subject.
Where the decision is necessary for the conclusion or performance of a contract between the data subject and the data controller or with the express consent of the data subject, we shall take reasonable steps to safeguard the rights and freedoms and the legitimate interests of the data subject, including at least the right to have the data subject intervene, to state his or her views and to challenge the decision.
If the data subject wishes to exercise rights relating to automated decisions, he or she may at any time do so by contacting an employee of the controller.
(2) You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us. The supervisory authority responsible for our company is as follows:
Bavarian State Office for Data Protection Supervision
D-91522 Ansbach, Germany
Tel.: +49 (0)981 / 53 1300
4. collection of personal data when visiting our website
(1) If you only use our website for information purposes, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to guarantee stability and security (legal basis is Art. 6 Para. 1 S. 1 lit. f DS-GVO):
– IP address
– Date and time of the request
– Time zone difference to Greenwich Mean Time (GMT)
– Internet service provider of the accessing system
– Contents of the request (concrete page)
– Access status/HTTP status code
– amount of data transferred in each case
– Website from which the request comes (referrer)
– Operating system and its interface
– Language and version of the browser software.
(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive assigned to the browser you are using and through which certain information flows to the location that sets the cookie (here by us). Cookies cannot execute programs or transmit viruses to your computer. They serve to make the website more user-friendly and effective.
a) This website uses the following types of cookies, the scope and function of which are explained below:
– Transient Cookies (see b)
– Persistent cookies (see c)
– Flash-Cookies (f).
b) Transient cookies are automatically deleted when you close your browser. These include in particular session cookies. They store a so-called session ID, which can be used to assign various requests from your browser to the shared session. This enables your computer to be recognised when you return to our website. The session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser.
d) You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. We would like to point out that you may not be able to use all the functions of this website.
f) The Flash cookies used are not recorded by your browser, but by your Flash plug-in. We also use HTML5 storage objects, which are stored on your end device. These objects store the required data regardless of the browser you are using and do not have an automatic expiration date. If you do not wish the Flash cookies to be processed, you must install an appropriate add-on, e.g. “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe-Flash-Killer-Cookie for Google Chrome. You can disable HTML5 storage objects with the incognito browser mode. We advise you to delete all cookies manually from the browser settings sometimes.
5. further functions and offers of our website
(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you must generally provide further personal data which we use to provide the respective service and to which the aforementioned data processing principles apply.
(2) 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 checked regularly.
(3) The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services which we use for the purpose of operating this online service.
We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f. GDPR in conjunction with Art. 28 GDPR.
(4) In addition, we may pass on your personal data to third parties if we offer participation in promotions, competitions, contracts or similar services together with partners. You will receive further information on this when you enter your personal data or in the description of the offer below.
(5) If our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the offer.
6. data protection for applications
The data controller collects and processes the personal data of applicants for the purpose of processing the application procedure. Processing may also be carried out electronically. This is particularly the case if an applicant submits the relevant application documents electronically, for example by e-mail or via a contact form on the website, to the controller. If the data controller concludes an employment contract with an applicant, the data transmitted shall be stored for the purpose of processing the employment contract in compliance with the statutory provisions. If the controller does not conclude an employment contract with the candidate, the application documents shall be automatically deleted, unless deletion conflicts with any other legitimate interests of the controller. Other legitimate interests in this sense include, for example, the duty to provide evidence in proceedings under the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz – AGG).
The processing of applicant data is carried out to fulfil our (pre)contractual obligations within the scope of the application procedure as defined by Art. 6 Para. 1 lit. b. GDPR Art. 6 Para. 1 lit. f. GDPR if the data processing e.g. in the context of legal proceedings for us becomes necessary (in Germany § 26 BDSG (Federal Data Protection Act) additionally applies).
7. objection or revocation against the processing of your data
(1) If you have given your consent to the processing of your data, you can revoke it at any time and by any means of communication. Such a revocation influences the permissibility of processing your personal data after you have given it to us.
(2) Insofar as we base the processing of your personal data on a weighing of interests, you may object to the processing. This is the case if the processing is in particular not necessary for the fulfilment of a contract with you, which is described by us in the following description of the functions. In the event of such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and either discontinue or adapt the data processing or point out our compelling reasons worthy of protection on the basis of which we will continue the processing.
(3) You may of course object to the processing of your personal data for advertising and data analysis purposes at any time. You can contact us about your advertising objection at the address given in section 2 (2).
8. legal or contractual regulations for the provision of personal data/ necessity for the conclusion of a contract/ consequences in the event of non-supply
(1) We would like to inform you that the provision of personal data is partly required by law. However, it is also possible that a data subject may be required to provide us with personal information in order for a contract to be performed. Failure to do so would result in the contract not being able to be concluded. Our employees will be happy to answer any questions you may have on a case-by-case basis.
(2) The data processed by us shall be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
According to legal requirements, the storage is carried out in particular for 10 years according to §§ 147 Para. 1 AO, 257 Para. 1 no. 1 and 4, Para. 4 HGB (German Commercial Code) (books, records, management reports, accounting records, commercial books, documents relevant for taxation, etc.) and 6 years according to § 257 Para. 1 no. 2 and 3, Para. 4 HGB (German Commercial Code) (commercial letters).
9. Web Analytics
1. Use of Jetpack/formerly Wordpress.com-Stats
(1) This website uses the web analysis service Jetpack (formerly: WordPress.com-Stats) in order to analyse and regularly improve the use of our website. The statistics obtained will enable us to improve our services and make them more interesting for you as a user. We also use the system for measures to protect the security of the website, such as detecting attacks or viruses. For the exceptional cases in which personal data is transferred to the USA, Automattic Inc. has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov. The legal basis for the use of Jetpack is Art. 6 (1) sentence 1 lit. f. GDPR.
(2) Cookies (see above for details) are stored on your computer for this evaluation. Each time one of the individual pages of this Internet site is accessed, operated by the data controller and on which a Jetpack component has been integrated, the Internet browser on the data subject's information technology system is automatically prompted by the respective Jetpack component to transmit data to Automattic for analysis purposes. As part of this technical process, Automattic obtains knowledge of data that is subsequently used to create an overview of Internet site visits. The data thus obtained shall be used to analyse the behaviour of the data subject who has accessed the website of the data controller and shall be evaluated with a view to optimising the website. The data collected through the Jetpack component will not be used to identify the data subject without the prior express consent of the data subject. The data will also be made known to Quantcast. Quantcast uses the data for the same purposes as Automattic. The information collected in this way is stored on a server in the USA.
If you prevent the storage of cookies, we would like to point out that you may not be able to use this website to its full extent. The prevention of the storage of cookies is possible by the setting in your browser or by clicking on the button "Click here to Opt-out" under http://www.quantcast.com/opt-out .
(3) This website uses Jetpack with an extension that shortens IP addresses immediately after they have been collected, so that they cannot be linked to a specific person.
(4) Information of the third party provider: Automattic Inc., 60 29 th Street #343, San Francisco, CA 94110–4929, USA, https://automattic.com/privacy, as well as the third party provider of tracking technology: Quantcast Inc., 201 3 rd St, Floor 2, San Francisco, CA 94103–3153, USA, https://www.quantcast.com/privacy.
10. Google Maps
1. Integration of Google Maps
(1) On this website we use the offer of Google Maps. This enables us to display interactive maps directly on the website and enables you to use the map function conveniently.
(2) By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. In addition, the data referred to in point 4 of this declaration will be transmitted. This occurs regardless of whether Google provides a user account that you are logged in to or whether there is no user account. When you're logged in to Google, your information will be directly associated with your account. If you do not want your profile to be associated with Google, you must log out before activating the button. Google stores your data as user profiles and uses them for the purposes of advertising, market research and/or the design of its website in line with requirements. Such evaluation is carried out in particular (even for users who are not logged in) in order to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.
11. Plugins and tools
1. Google Web Fonts
This page uses so-called web fonts provided by Google for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. For this purpose, the browser you are using must connect to Google's servers. This gives Google knowledge that our website has been accessed via your IP address. The use of Google WebFonts is in the interest of a uniform and appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 Para. 1 lit. f. GDPR.
If your browser does not support web fonts, a standard font will be used by your computer.
2. Use of Google reCaptcha
3. Use of ajax.googleapis.com and jQuery
On this page we use Ajax and jQuery technologies to optimize loading speeds. In this regard, program libraries are called from Google servers. The CDN (Content Delivery Network) from Google is used. If you have previously used jQuery on another Google CDN page, your browser will use the cached copy. If this is not the case, it will require downloading, whereby data from your browser will be sent to Google Inc. ("Google"). Your data will be transferred to the USA. You can find out more on the pages of the providers.
The legal basis for the processing of your data is Art. 6 Para. 1 pg. 1 lit. f. GDPR.