Privacy Policy
This Privacy Policy explains the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “Data”) in connection with the provision of our services, as well as within our online platform and its associated websites, features, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”). With regard to the terms used, such as “processing” or “controller,” please refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Person in Charge
SR Travel International S.L. Limited Partnership
8 C/Buenos Aires / Office 1B
35002 Las Palmas
Gran Canaria, Spain
Tax ID Number: D09715202
represented by its managing director: Jeanette Chediak, Jakub Indyk
Phone: +49(0)641 97259-279
FAX +49(0)641 97259-060
EMAIL contact@srt-international.es
Legal Notice: https://www.srt-international.es/Impressum.html
Disclosure Requirements Pursuant to Art. 13 of the EU GDPR: Information Requirements
Data Controller and Data Protection Officer: privacy@srt-international.es
Types of Data Processed
– Master data (e.g., personal master data, names, or addresses)
– Contact information (e.g., email, phone numbers)
– Content data (e.g., text entries, photographs, videos)
– Usage data (e.g., websites visited, interests in content, access times)
– Meta/communication data (e.g., device information, IP addresses)
Categories of Data Subjects
Visitors and users of the online service (hereinafter, we will collectively refer to these individuals as “users”).
Purpose of Processing
– To provide the online service, its features, and its content
– Responding to contact requests and communicating with users
– Safety Measures
– Reach Measurement/Marketing
Terminology Used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”); a natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie) or one or more specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
“Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually every aspect of data handling.
“Pseudonymization” 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 use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures that ensure the personal data cannot be attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to evaluate aspects concerning work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.
The term “controller” refers to the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor”: a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
Relevant Legal Bases
In accordance with Article 13 of the GDPR, we are providing you with information regarding the legal bases for our data processing activities. For users within the scope of the General Data Protection Regulation (GDPR)—that is, the EU and the EEC—the following applies unless the legal basis is specified in the privacy policy:
The legal basis for obtaining consent is Art. 6, para. 1(a). a and Art. 7 of the GDPR;
The legal basis for processing data to fulfill our services, carry out contractual obligations, and respond to inquiries is Article 6, paragraph 1(a). b GDPR;
The legal basis for processing data to fulfill our legal obligations is Article 6, paragraph 1(a). c DSGVO; Für den Fall, dass lebenswichtige Interessen der betroffenen Person oder einer anderen natürlichen Person eine Verarbeitung personenbezogener Daten erforderlich machen, dient Art. 6 Abs. 1(a). Article 5 of the GDPR as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6( 1(a). e GDPR.
The legal basis for processing to protect our legitimate interests is Article 6( 1(a). Article f of the GDPR.
The processing of data for purposes other than those for which it was collected is governed by the provisions of Article 6, paragraph Article 4 of the GDPR.
The processing of special categories of data (as defined in Article 9(1) of the GDPR) is governed by the provisions of Article 9( Article 2 of the GDPR.
Safety Measures
In accordance with legal requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access to, input of, and disclosure of the data, ensuring its availability, and maintaining its separation. In addition, we have established procedures to ensure that data subjects’ rights are upheld, that data is deleted, and that we respond to data breaches. Furthermore, we take the protection of personal data into account from the very beginning of the development and selection of hardware, software, and processes, in accordance with the principle of data protection through technology design and privacy-friendly default settings.
Cooperation with Data Processors, Joint Controllers, and Third Parties
If, in the course of our data processing, we disclose data to other individuals and companies (data processors, joint controllers, or third parties), transfer it to them, or otherwise grant them access to the data, this is done only on the basis of legal authorization (e.g., if transferring the data to third parties, such as payment service providers, is necessary to fulfill a contract), the user has given consent, a legal obligation requires it, or based on our legitimate interests (e.g., when using agents, web hosts, etc.).
To the extent that we disclose, transfer, or otherwise grant access to data to other companies within our corporate group, this is done, in particular, for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with legal requirements.
Transfers to Third Countries
If we process data in a third country (i.e., h. outside the European Union (EU), the European Economic Area (EEA), or the Swiss Confederation, or if this occurs in connection with the use of third-party services or the disclosure or transfer of data to other individuals or companies, this will only take place if it is necessary to fulfill our (pre)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to statutory or contractual authorizations, we process data in a third country—or have it processed there—only if the legal requirements are met. In other words, processing is carried out, for example, on the basis of specific safeguards, such as an officially recognized determination that a level of data protection equivalent to that of the EU exists (e.g., for the United States through the “Privacy Shield”) or compliance with officially recognized specific contractual obligations.
Rights of Data Subjects
You have the right to request confirmation as to whether the relevant data is being processed, as well as access to that data, additional information, and a copy of the data in accordance with legal requirements.
In accordance with legal requirements, you have the right to request that the data concerning you be completed or that any inaccurate data concerning you be corrected.
In accordance with legal requirements, you have the right to request that the relevant data be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with legal requirements.
You have the right to request that we provide you with the data concerning you that you have provided to us in accordance with legal requirements, and to request that we transfer that data to other data controllers.
Right of Withdrawal
You have the right to revoke any consent you have given, effective for the future.
Right to Object
You may object at any time to the future processing of your personal data in accordance with legal requirements. In particular, the objection may be raised against processing for direct marketing purposes.
Cookies and the Right to Object to Direct Marketing
“Cookies” are small files that are stored on users’ computers. Various types of information can be stored in cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or even after the user’s visit to a website. Temporary cookies—also known as “session cookies” or “transient cookies”—are cookies that are deleted after a user leaves a website and closes their browser. Such a cookie can be used, for example, to store the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent.” For example, this allows the login status to be saved so that users can log in again after several days. Similarly, such a cookie may store information about users’ interests, which is used for audience measurement or marketing purposes. “Third-party cookies” are cookies provided by parties other than the controller who operates the online service (otherwise, if only the controller’s cookies are used, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies, and we provide information about this in our Privacy Policy.
If users do not want cookies to be stored on their computers, they are asked to disable the corresponding option in their browser’s system settings. Stored cookies can be deleted in the browser’s system settings. Disabling cookies may result in limited functionality of this website.
A general objection to the use of cookies for online marketing purposes can be submitted for a wide range of services—especially in the case of tracking—via the U.S. website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. In addition, you can prevent cookies from being stored by disabling them in your browser settings. Please note that, in such cases, you may not be able to use all the features of this online service.
Deletion of Data
The data we process will be deleted or its processing restricted in accordance with legal requirements. Unless otherwise expressly stated in this Privacy Policy, the data we store will be deleted as soon as it is no longer necessary for its intended purpose and there are no legal retention requirements that prevent its deletion.
Unless the data is deleted because it is necessary for other, legally permissible purposes, its processing will be restricted. This means that the data is restricted and will not be processed for any other purposes. This applies, for example, to data that must be retained for commercial or tax purposes.
Changes and Updates to the Privacy Policy
We ask that you review the contents of our Privacy Policy on a regular basis. We will update the Privacy Policy as soon as changes to our data processing activities make it necessary to do so. We will notify you as soon as the changes require any action on your part (e.g., consent) or any other individual notification.
Business-Related Processing
In addition, we process
– Contract details (e.g., subject matter of the contract, term, customer category)
– Payment information (e.g., bank account information, payment history)
from our customers, prospective customers, and business partners for the purpose of providing contractual services, customer service, marketing, advertising, and market research.
Administration, Finanzbuchhaltung, Büroorganisation, Kontaktverwaltung
We process data in connection with administrative tasks, the organization of our operations, financial accounting, and compliance with legal obligations, such as record-keeping. In this context, we process the same data that we process in connection with the provision of our contractual services. The legal basis for processing is Art. 6, para. 1(a). c. GDPR, Art. 6, para. 1(a). f. GDPR. This data processing affects customers, prospective customers, business partners, and website visitors. The purpose of and our interest in processing data lie in administration, financial accounting, office organization, and data archiving—that is, tasks that serve to maintain our business operations, fulfill our responsibilities, and provide our services. The deletion of data related to contractual services and contractual communications is in accordance with the information provided regarding these processing activities.
In this context, we disclose or transfer data to tax authorities, advisors—such as tax advisors or certified public accountants—as well as other billing agencies and payment service providers.
In addition, based on our business interests, we store information about suppliers, event organizers, and other business partners, for example, to contact them at a later date. We generally store this data—most of which is business-related—on a permanent basis.
Privacy Notice Regarding the Application Process
We process applicant data solely for the purpose of and within the scope of the application process, in accordance with legal requirements. Applicant data is processed to fulfill our (pre)contractual obligations as part of the application process within the meaning of Article 6( 1(a). b. GDPR Art. 6, para. 1(a). f. GDPR, provided that data processing becomes necessary for us, for example, in the context of legal proceedings (in Germany, § 26 BDSG also applies).
The application process requires applicants to provide us with their application information. The required applicant information is indicated where we provide an online form; otherwise, it is specified in the job descriptions. Generally, this includes personal information, mailing and contact addresses, and the documents required for the application, such as a cover letter, resume, and transcripts. In addition, applicants may voluntarily provide us with additional information.
By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the manner and scope set forth in this Privacy Policy.
To the extent that, as part of the application process, specific categories of personal data within the meaning of Article 9(1) are voluntarily provided, 1 GDPR, their processing is additionally carried out in accordance with Art. 9, para. 2 lit. b GDPR (e.g., health-related data, such as severe disability status or ethnic origin). To the extent that, as part of the application process, special categories of personal data within the meaning of Article 9( 1. If personal data is requested from job applicants under the GDPR, such data is also processed in accordance with Article 9( 2 lit. a) GDPR (e.g., health data, if such data is necessary for the performance of professional duties).
If available, applicants can submit their applications to us using an online form on our website. The data is transmitted to us in encrypted form using state-of-the-art technology. In addition, applicants may submit their applications to us via email. Please note, however, that emails are generally not sent in encrypted form, and applicants must ensure encryption themselves. We therefore cannot assume any responsibility for the transmission of the application between the sender and our server, and we therefore recommend using an online form or sending the application by mail. This is because, in addition to applying via the online form and email, applicants still have the option of sending their application to us by mail.
The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if an application for a job opening is unsuccessful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to a valid revocation by the applicant, the data will be deleted after a period of six months has elapsed, so that we can answer any follow-up questions regarding the application and fulfill our obligations to provide evidence under the Equal Treatment Act. Invoices for any travel expense reimbursements are archived in accordance with tax regulations.
Registration Function
Users can create a user account. During the registration process, users are informed of the required information, and pursuant to Art. 6, para. 1(a). b) GDPR for the purpose of providing the user account. The data processed includes, in particular, login information (name, password, and email address). The data entered during registration will be used for the purposes of using the user account and for the purposes for which it was created.
Users may be notified via email about information relevant to their user accounts, such as technical changes. If users have canceled their user accounts, their data related to those accounts will be deleted, subject to any statutory retention requirements. It is the users’ responsibility to back up their data upon termination of the contract before it expires. We are entitled to permanently delete all of the user’s data stored during the term of the contract.
When you use our registration and login features, as well as your user account, we store your IP address and the time of each user action. Data is stored based on our legitimate interests, as well as the users’ interest in protection against misuse and other unauthorized use. As a general rule, this data is not disclosed to third parties, unless such disclosure is necessary to pursue our claims or there is a legal obligation to do so pursuant to Art. 6, para. 1(a). c. GDPR. IP addresses are anonymized or deleted no later than seven days after collection.
Contact Us
When you contact us (e.g., via the contact form, email, phone, or social media), the user’s information is collected to process the contact request and handle it in accordance with Art. 6, para. 1(a). b. (in the context of contractual or precontractual relationships), Art. 6, para. 1(a). f. (other inquiries) Processed in accordance with the GDPR. User information may be stored in a customer relationship management system (“CRM system”) or a comparable system for organizing inquiries.
We delete the requests once they are no longer needed. We review the necessity of retaining this information every two years; in addition, statutory archiving requirements apply.
Web Hosting and Email Services
The hosting services we use are intended to provide the following: infrastructure and platform services, computing capacity, storage space, and database services, email delivery, security services, and technical maintenance services, which we utilize for the purpose of operating this online offering.
In this context, we—or our hosting provider—process master data, contact information, content data, contract data, usage data, metadata, and communication data from customers, prospective customers, and visitors to this online service based on our legitimate interests in providing this online service efficiently and securely, in accordance with Art. 6, para. 1(a). Article 6 of the GDPR in conjunction with Article 28 of the GDPR (conclusion of a data processing agreement).
Collection of Access Data and Log Files
We—or rather, our hosting provider—collect data based on our legitimate interests within the meaning of Article 6( 1(a). f. GDPR data regarding every access to the server on which this service is located (so-called server log files). Access data includes the name of the webpage accessed, the file, the date and time of access, the amount of data transferred, a notification of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), IP address, and the requesting provider.
For security reasons (e.g., to investigate cases of misuse or fraud), log file information is stored for a maximum of seven days and then deleted. Data that must be retained for evidentiary purposes is exempt from deletion until the incident in question has been fully resolved.
Measuring Reach with Matomo
As part of Matomo’s audience analysis, the following data is processed based on our legitimate interests (i.e., our interest in analyzing, optimizing, and ensuring the economic operation of our online offering within the meaning of Article 6(1)(f) of the GDPR): the type and version of the browser you use, the operating system you use, your country of origin, the date and time of the server request, the number of visits, the duration of your visit to the website, and the external links you click on. Users’ IP addresses are anonymized before they are stored.
Matomo uses cookies that are stored on users’ computers and enable us to analyze how users interact with our website. Pseudonymous user profiles can be created from the processed data. The cookies are stored for one week. The information generated by the cookie regarding your use of this website is stored only on our server and is not shared with third parties.
Users may object to the anonymous collection of data by the Matomo program at any time, effective for the future, by clicking the link below. In this case, a so-called opt-out cookie will be stored in your browser, which means that Matomo will no longer collect any session data. However, if users delete their cookies, this results in the opt-out cookie being deleted as well, and users must therefore reactivate it.
Logs containing user data are deleted after six months at the latest.
Matomo Opt-Out.
Social Media Presence
We maintain an online presence on social media networks and platforms to communicate with customers, prospective customers, and users who are active there and to inform them about our services.
Please note that this may involve the processing of user data outside the European Union. This could pose risks to users because, for example, it could make it more difficult for them to enforce their rights. With regard to U.S. providers certified under the Privacy Shield, we would like to point out that they thereby commit to complying with the EU’s data protection standards.
In addition, user data is generally processed for market research and advertising purposes. For example, usage profiles can be created based on users’ usage behavior and the resulting interests. These usage profiles can, in turn, be used, for example, to display advertisements—both on and off the platforms—that are presumed to align with users’ interests. For these purposes, cookies are typically stored on users’ computers to record their usage behavior and interests. Furthermore, data may also be stored in the user profiles regardless of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is based on our legitimate interests in effectively informing users and communicating with them, in accordance with Article 6(1)(f) of the GDPR. If users are asked by the respective platform providers to consent to the data processing described above, the legal basis for the processing is Article 6(1)(a) and Article 7 of the GDPR.
For a detailed description of the respective processing activities and the options for opting out, please refer to the information provided by the providers via the links below.
We would also like to point out that requests for information and the exercise of user rights are most effectively handled by the service providers themselves. Only the service providers have access to user data in each case and can take appropriate action and provide information directly. If you still need help, please feel free to contact us.
– Facebook, Facebook Pages, Facebook Groups (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) based on an agreement regarding the joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/, specifically for Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data, opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
– Google/YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies.google.com/privacy, Opt-out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA) – Privacy Policy / Opt-Out: http://instagram.com/about/legal/privacy/.
– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA 94301, USA) – Privacy Policy / Opt-Out: https://about.pinterest.com/de/privacy-policy.
– LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) – Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
This always requires that the third-party providers of this content collect users’ IP addresses, since without the IP address they would not be able to send the content to the users’ browsers. The IP address is therefore required to display this content. We make every effort to use only content from providers who use the IP address solely for the purpose of delivering that content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. “Pixel tags” allow us to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on users’ devices and may include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details regarding the use of our online service, as well as be linked to such information from other sources.
Created using Datenschutz-Generator.de by Attorney Dr. Thomas Schwenke
As of September 5, 2022
