Dated: 22 September 2018
This policy is GDPR compliant and explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this policy is legally binding when you use our Services.
For the purpose of the General Data Protection Regulations (GDPR), Adrenalin Tours AG are the “data controller” of your information. We are a travel agency located at 23 Einsiedlerstrasse, Schindellegi 8834 in Switzerland. With your privacy questions please contact us on email@example.com
1. Information we may collect from you
Information you give us
You may give us information about you when you sign up to use our services, e.g. when you provide us with your personal details, such as your name and email address. This also includes information you provide through your use of our services, participate in discussions through our system, or 3rd party web applications like chat.io or other social media functions on our website and when you report a problem with our services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, personal description and photograph.
Information we collect about you
With regard to your use of our services we may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.
Information we receive from other sources
We are working closely with third parties and may receive information about you from them. For example: the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details; business partners may provide us with your name and address, as well as financial information, such as card payment information; advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our website; credit reference agencies do not provide us with any personal information about yourself, but may be used to corroborate the information you have provided to us.
2. Use your personal information
Access & use of websites
If you are only using the website for informational purposes, i.e., if you do not request for a quote or otherwise provide us with information, we will only collect the personally identifiable information that your browser transmits to our server. If you wish to view our website, we collect the following data that is technically necessary for us to display our website and ensure its stability and security. Only in the case of suspected misuse in connection with bookings would we use this link information to facilitate the identification of the person responsible. The legal basis for this is Article 6 (1) (f) GDPR:
–IP address, date and time of the inquiry, time difference to Greenwich Mean Time (GMT), content of the request (concrete page), access status/HTTP status code, amount of data transferred in each case, website that receives the request, browser, operating system and its interface, language, and browser software version.
Responding to your request for information or quotes & orders
When you contact us (online or offline) in connection with a request for information, to receive a quote or order a product or service, to provide you with support we collect information necessary to fulfill your request, to provide you the service, to provide you with support and to be able to contact you. For instance, we collect your name and contact information (e-mail address, phone number, postal / invoice address), details about your request (enquiry time, group size, destination, dates in destination, aquisition channel, country, message history) and your agreement with us and the fulfillment, delivery and invoicing of your order and we may include client satisfaction survey information. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you.
3. How do we protect your personal information
We are serious about guarding the security of your personal information and use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology.
We restrict access of your personal information to those employees of Adrenalin Tours AG who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorised access.
Cookies will be stored on your device during the use of our website. Cookies are small text files that are stored on your hard drive assigned to the browser you use, and through which the place where the cookie is set accrues certain information. Cookies cannot run any programmes or transmit any viruses to your device.
This website uses the following types of cookies, whose extent and function are explained in the following:
These cookies are automatically deleted when you close your browser. This includes session cookies in particular. These save a “session ID” with which different requests from your browser can be assigned to the joint session. This allows your device to be recognised again when you return to our website. Session cookies are deleted when you log out or close your browser.
These cookies are automatically deleted after a set duration that can vary depending on the cookie. You can delete cookies in your browser security settings at any time.
You can configure your browser settings as you wish and, for example, decline to accept third-party or all cookies. Please note that you may not be able to use all of the website’s functions in this case.
Legal bases and storage period
The legal bases for possible processing of personally identifiable information and its storage period vary and are described in the following sections.
For the purposes of analysing and optimising our websites, we use different services that are described in the following. This allows us to analyse, for example, how many users visit our site, which information is requested the most, and how users find the website. The data that we collect includes the websites from which a person in question arrives at a website (“referrer”), which sub-pages on the website are accessed and how often, and the length of time for which a sub-page is viewed. This helps us to develop and improve our website to be more user-friendly. The data collected does not serve to personally identify individual users. Anonymous or highly pseudonymous data will be collected. The legal basis for this is Article 6, par. 1f of the GDPR.
This website uses Google Analytics, a web analysis service of Google Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). This use covers the Universal Analytics operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID and thus analyse a user’s activities across devices.
Google Tag Manager
For transparency reasons, we would like to mention that we use Google Tag Manager. Google Tag Manager does not itself collect any personally identifiable information. Tag Manager makes it easier for us to incorporate and manage our tags. Tags are small elements of code that serve to measure traffic and user behaviour, record the effects of online advertising and social channels, establish re-marketing and focus on target groups, and test and optimise websites, among other things. If you have deactivated, this will be taken into account by Google Tag Manager. For more information about Google Tag Manager, see: http://google.com/analytics/tag-manager/use-policy/
Google AdWords & Conversion Tracking
To draw attention to our services, we place Google AdWords display ads and, within this context, use Google conversion tracking for the purposes of personalised online ads based on interests and location. The option to anonymise IP addresses is controlled through Google Tag Manager, via an internal setting that is not visible in the source of this page. This internal setting is set so that the anonymisation required by privacy laws covers IP addresses.
With the use of this technology, Google, and we as their customer, receive the information that a user has clicked on an ad and was redirected to our websites. The information acquired this way is solely used for statistical analysis related to ad optimisation. We do not receive any information that would allow us to personally identify a visitor. The statistics provided to us by Google include the total number of users who have clicked on one of our ads and, where applicable, whether they were redirected to a page on our website that has a conversion tag. These statistics allow us to track which search terms most often lead to our ads receiving clicks, and which ads lead to the user contacting us via the contact form.
If you do not want this, you can prevent the storage of the cookies required for this technology by, for example, using the settings in your browser. Should you do so, your visit will not be incorporated into user statistics.
However, we and Google will still receive statistical information about how many users visit this site and when. If you do not want to be included in these statistics either, you can prevent this by using additional programmes for your browser.
If you do not want to receive any user-based advertising, you can disable the placement of ads by using Google’s ad settings.
For more information about how Google cookies are used, please refer to Google’s privacy statement.
We use the “Facebook Pixel” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.
This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy http://facebook.com/about/privacy/. You an allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: http://facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (http://privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
5. Disclosure of your information
We may share your information with selected third parties including affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you; advertisers and advertising networks solely to select and serve relevant adverts to you and others; and analytics and search engine providers that assist us in the improvement and optimisation of our site
We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions; or to protect the rights, property, or safety of Adrenalin Tours AG, our customers, or others.
We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependant on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to You, you can request this by writing to firstname.lastname@example.org.
6. Where we store your personal information
The data that we collect from you are transferred to, and stored at our servers in Czech Republic. It may also be processed by staff operating inside the EAA or in EU who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing.
7. Sharing your personal information outside of the EEA
In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties (i.e. Google, Facebook) outlined in section 5.1 that are based outside of the European Economic Area. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical and organisational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
8. Data Retention
We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.
Your registration information will be retained for as long as needed to provide you services. If you wish to request that we no longer use your registration information to provide you services, contact us at email@example.com.
9. Your rights
You have the right to ask us not to contact you for marketing purposes by contacting us at firstname.lastname@example.org.
You have the right to correct any personal information. We hold on you that is inaccurate, incorrect, or out of date.
You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Adrenalin Tours AG is subject to.
10. Access to information
Subject to applicable laws, you may have the right to access information we held about you. Your right of access can be exercised in accordance with the relevant data protection legislation.