Data Protection Policy

Table of contents

  1. Controller
  2. Extent of processing of personal data
  3. Types of processed data
  4. Purpose of processing
  5. Relevant legal bases
  6. Safety measures
  7. Cooperation with third parties and processors
  8. Transfers to third countries
  9. Rights of data subjects
  10. Withdrawal
  11. Right to object
  12. Deletion of data
  13. Hosting
  14. Collection of access data and log files
  15. Processing of reservations in the online shop
  16. Customer account
  17. Online shop – payment systems
  18. Settlement of reservation by third parties
  19. Administration, financial accounting, office organization, contact management
  20. Contacting SNOWELL
  21. Contacting third parties (such as ski rental shops, tourist offices, ski resorts, …)
  22. Newsletter
  23. Newsletter – mail carrier
  24. Newsletter – success measurement
  25. Deployment and use of affiliate programs in the Bonus Program
  26. Issuing coupons from the BONUS PROGRAM
  27. Competitions, discount codes
  28. User activity ticker
  29. Business analysis and market research
  30. Cookies and right to object in direct mail
  31. Google analytics
  32. Google re- / marketing services
  33. Google reCAPTCHA
  34. Google Maps
  35. Online presence in social media
  36. Use of Facebook social plugins
  37. Facebook pixels, Custom Audiences and Facebook conversion
  38. Google+
  39. Twitter
  40. Instagram
  41. Youtube
  42. Language used

The protection of your data is very important to us. The collection and processing of your personal data takes place in accordance with the applicable legislation for the protection of personal data according to the General Data Protection Regulation (GDPR).

This data protection policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offers and related websites, features and content, as well as external online presence, e.g. our social media profile (collectively referred to as “online offer”).

We will adjust the data protection policy as soon as the changes to the data processing carried out by us, require it. We will notify you as soon as the changes require your participation (e.g. consent) or if another individual notification is necessary.

Definitions of the terms used (e.g. personal data, processing, controller) you will find in art. 4 of the GDPR.

1. Controller

The controller within the meaning of the GDPR is:
SNOWELL International Aktiengesellschaft, Duxgass 25, 9494 Schaan, Liechtenstein
Data protection officer: Helena van Dooren Derkx
Telephone number: +423 239 61 81
Email address: info@snowell.com
Website: www.snowell.com

We will gladly provide you with information on the processing of personal data by Snowell International AG upon request. Please contact us in this regard.

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2. Extent of processing of personal data

Only those personal data will be collected, which are necessary for the performance and execution of our tasks and services or those you have voluntarily provided us.

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3. Types of processed data

- personal data (names, addresses, gender, date of birth, weight, height, shoe size, head circumference, skiing ability).
- contact details (email, telephone numbers).
- usage data (e.g. websites visited, interest in content, access times).
- meta-/communication data (e.g. device information, IP addresses).

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4. Purpose of processing

- providing the online offers, its functions and contents.
- use of our online services.
- subscribe/unsubscribe to newsletters.
- answering contact requests and communicating with users.
- safety measures.
- scope measurement/marketing.

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5. Relevant legal bases

In accordance with art. 13 of the GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection policy is mentioned, the following applies: The legal basis for obtaining consent is art. 6 (1) (a), and art. 7 of the GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is art. 6 (1) (b) of the GDPR, the legal basis for processing in order to fulfil our legal obligations is art. 6 (1) (c) of the GDPR, and the legal basis for processing in order to safeguard our legitimate interests is art. 6 (1) (f) of the GDPR. In the event that interests that are of vital importance for the data subject or another natural person require the processing of personal data, art. 6 (1) (d) of the GDPR is the legal basis.

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6. Safety measures

In order to best protect the data saved by us against accidental or intentional manipulation, loss, destruction or access by unauthorized persons, we implement appropriate technical and organizational security measures that are constantly reviewed and adapted to new security standards. Your personal data will only be processed on secure, industry-standard computers (such as firewalls, password protection, aso.).

The data exchange from and to our website takes place encrypted. As a transmission protocol, we offer HTTPS (Hypertext Transfer Protocol Secure) for our website. Data entered by you will be transmitted to us secured and then saved. We use a secure online transmission method, known as Secure Socket Layer (SSL) transmission. This transmission method is supported by most browsers. All information transmitted using this secure method is encrypted before being sent.

Within our company, access to personal data is only possible for authorized persons in the respective specialist departments who are responsible for technical, commercial or customer-oriented support.

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7. Cooperation with third parties and processors

We do not sell or lend user information.

Data, which is collected, processed and saved on this website will only be disclosed to third parties if this is necessary for business or reservation processing or if there is a legitimate interest; this applies in particular for payment services in context of our online shop, for distribution channels (e.g. affiliates), for sports dealer organizations, interest groups or for companies to make reservations for ski rental, ski schools, …. (art. 6 (1) (b) of the GDPR). Through this transmission, we can offer you an optimal service and a satisfactory support.

With processors we have completed appropriate service and order fulfilment contracts to ensure compliance with the requirements for data protection (art. 28 of the GDPR).

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8. Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfil our contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of art. 44 of the GDPR. This means that the processing is done e.g. on the basis of specific guarantees, such as the officially recognized level of data protection of the EU (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

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9. Rights of data subjects

You have the right to request a confirmation as to whether the data in question are being processed and, upon request, free information about this data as well as further information and a copy of the data in accordance with art. 15 of the GDPR.

According to art. 16 of the GDPR, you have the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with art. 17 of the GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with art. 18 of the GDPR.

You have the right to demand, that the data relating to you, which you have provided us, be obtained in accordance with art. 20 of the GDPR and request their transmission to other controllers.

Furthermore, according to art. 77 of the GDPR, you have the right to file a complaint with the competent supervisory authority.

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10. Withdrawal

You have the right to withdraw the granted consents in accordance with art. 7 (3) of the GDPR with effect for the future.

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11. Right to object

You can object at any time to the future processing of your data in accordance with art. 21 of the GDPR. The objection can in particular be filed against processing for direct marketing purposes.

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12. Deletion of data

We only save personal data of the data subject for the period required for the achievement of the storage purpose or if this is required by legal provisions (articles 17 and 18 of the GDPR).

If the storage purpose is omitted or if a legally prescribed storage/retention period expires, the personal data will be routinely and in accordance with the statutory provisions blocked or deleted, unless there is a need for further storage of data in order to carry out or conclude a contract.

According to the Liechtenstein Personal and Company Law, art. 1059 (1) one has the duty to keep the books of account, the accounting records and business correspondence for 10 years for the purpose of proper accounting. The Liechtenstein tax law also provides for a retention period of 10 years in art. 17.

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13. Hosting

The hosting services we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, disk space and database services, collateral and technical maintenance services which we use to operate these online offers.

Here we process, or our hosting providers, inventory data, contact data, contract data, usage data, meta and communication data of customers, interested parties and visitors of these online offers based on our legitimate interest in an efficient and secure posting of our online offer according to art. 6 (1) (f) of the GDPR in connection with art. 28 of the GDPR. Deleting the backups takes place after 4 weeks.

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14. Collection of access data and log files

We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of art. 6 (1) (f) of the GDPR. The access data include name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, user´s operation system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is saved for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and is then deleted. Data whose further retention is required for evidential purposes shall be exempted from the deletion until final clarification of the incident.

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15. Processing of reservations in the online shop

As an independent company, we operate a booking platform to allow users to pre-book various services/activities (e.g. ski rental, ski school, etc.). We work together with various partners (sports dealer organizations, interest groups as well as directly with ski schools, ski rental companies etc.) in order to be able to offer our users the widest possible and comprehensive range in the holiday resorts. The current partners can be viewed on https://en.snowell.com/all-ski-resorts/.

We process the data of our customers in the course of the reservation processes in our online shop, in order to enable them the selection and reservation of the chosen services, as well as their payment and purchase of the contractor´s service (e.g. ski rental shop, ski school, …). Here, we use cookies for the storage of the shopping carts contents.

The following customer data of the reservation with SNOWELL are transmitted purely for the preparation of the contract with the contracting party, for providing and assigning the right person to the contracting party/association: first name, name, address, country of origin, as well as the associated additional details for the reservation, such as first name, name, date of birth, height, shoe size, weight, skills, head circumference and selected products. Any other use of customer data is not allowed to the contractors.

The actual contract is concluded exclusively between the customer and the respective contractual partner and arises when using the booked service. From the moment of transmission and the realization of the actual contract, we have and cannot have any further influence on the use or processing of the data. The transmitted personal details are subject to the data protection policy of the respective contracting party from this point in time.

Processing is based on art. 6 (1) (b) (execution of order transactions) and f (legitimate interest) of the GDPR. For this the required information for drafting and executing the contract is necessary. The data only disclose the contract partners to third parties in the context of legal permissions and obligations towards legal advisers and authorities.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the storage of the data is checked every two years; in the case of legal archiving obligations, the deletion takes place after its expiration (end of commercial and taxation duty of 10 years).

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16. Customer account

In order to be able to make reservations via our online shop, each customer must set up a password-protected customer account. This includes an overview of reservations made during the current winter season. We assume no liability for password abuse, unless this was caused by us. By activating the button “pay booking” at the first reservation, you give the consent to open the customer account and to the processing and storage of your data.

As part of the registration, the required mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data relating to the user account will be deleted, unless storage is necessary for reasons of commercial or fiscal nature in accordance with art. 6 (1) (c) of the GDPR. Information in the customer account remains there until it is deleted or in case of a legal obligation is archived. It is the responsibility of the users to secure their data upon termination before the end of the contract.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of storage of the data is checked every two years; in case of legal archiving obligations, the deletion takes place after its expiration (end of commercial and taxation duty of 10 years).

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17. Online shop - payment systems

In our online shop you can pay the booked service on account (10 days before the start of the service) or with credit and debit cards and online payment methods.

When paying by invoice, the data will be saved as long as we are required to do so for legal reasons.

The remaining payment options are processed via an external payment provider. https://www.six-payment-services.com/en/services/legal/privacy-statement.html#country=ch

SNOWELL is a PCI DSS certified company and therefore does NOT save any payment data itself. In the case of any postponements or refunds, SNOWELL is entitled, in consultation with the customer, to charge or credit the resulting difference amounts.

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18. Settlement of reservation by third parties

SNOWELL cooperates directly or indirectly with third party providers (e.g. tour operators, other online portals). The collection of the personal data of these reservations take place at the third party providers.

To process these reservations as well as to prepare the contract with the contracting party (e.g. ski rental shop), the third party submits the following data to SNOWELL: first name, surname, address, country of origin and the associated additional details of the reservation, such as: first name, surname, date of birth, body size, shoe size, weight, (skiing) skills, head circumference and selected products. SNOWELL forwards this personal data to the contracting party. Art. 14 (2) (b) of the GDPR. Any other use of customer data is not permitted by SNOWELL and its contractual partners.

The actual contract is concluded exclusively between the customer and the respective contractual partner and arises when the booked service is used. From the time of transmission and after the actual contract has come to fruition, we cannot and do not have any further influence on the use or processing of the data. The transmitted personal data are subject to the data protection policy of the respective contracting party from this point in time.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the storage of the data is checked every two years; in case of legal archiving obligations, the deletion takes place after its expiration (end of commercial and taxation duty of 10 years).

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19. Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our operation and compliance with legal obligations, such as archiving. The processing principles are art. 6 (1) (c) of the GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and our interest in processing lies in administration, financial accounting, office organization, data archiving, so tasks that serve to maintain our business, perform our duties and provide our contractual services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the financial administration, consultants, such as auditors.

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20. Contacting SNOWELL

When contacting us (e.g. by contact form, email, telephone or via social media), the information of the user for the processing and settlement of the contact request is settled according to art. 5 (1) (b) of the GDPR. The user information can be saved in a Customer Relationship Management System (“CRM system”) or with a comparable application organization.

The requests are deleted if they are no longer required. We check the necessity every two years.

For customer support and as a helpful customer service, we offer our users on our website the live chat function of the provider Userlike UG, Probsteigasse 44-46, D-50670 Cologne. When you start the live chat, Userlike will start collecting your IP address for a short period of time in order to determine the country from which you start the live chat. This way we are able to offer you a customer service tailored to your needs.

In addition, Userlike stores the history of live chats. This is for the purpose of possibly saving you extensive explanations about the history of your request as well as the constant quality control of our live chat service. In the process, data such as chat transcripts, usage data and device information are recorded, processed and stored (art. 4 (2) of the GDPR). https://www.userlike.com/en/terms#privacy-policy

The saved live chats with the corresponding data are automatically deleted after 12 months.

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21. Contacting third parties (such as ski rental shops, tourist offices, ski resorts, …)

With a contact form, the user can contact third parties via email. The contact request goes directly to the third party and is answered by them. SNOWELL receives and saves no data due to this contact request.

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22. Newsletter

On our website and in the booking process, we offer you the opportunity to subscribe to our free newsletter. If you would like to subscribe to the newsletter, you must enter a valid email address and submit your consent via opt-in (art. 6 (1) (a), art. 7 of the GDPR). Registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the log on time (e.g. time of booking) as well as the IP address. Similarly, a change or deletion of your stored data in our CRM system or at the shipping service provider is logged.

We send newsletters via email with promotional information about our services and services or our cooperation and affiliate partners.

Termination/withdrawl – you may terminate the receipt of our newsletter at any time or withdraw your consent. A link to cancel the newsletter can be found at the end of each newsletter. An individual request for cancellation by post or email is possible at any time. We may save the submitted email address for up to one year on the basis of our legitimate interests, before we finally delete them for the purpose of providing prior consent. The processing of this data is limited to the purpose of a possible defence against claims.

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23. Newsletter – mail carrier

The newsletter is sent by the mail carrier SendGrid, 1801 California Street, Suite 500, Denver, Colorado 80202, USA.

The mail carrier is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. https://www.privacyshield.gov/participant?id=a2zt0000000TRktAAG&status=Active

The mail carrier may use the data of the recipients in pseudonymous form, this means without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of sending and presenting the newsletter or for statistical purposes. However, the mail carrier does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties. https://sendgrid.com/resource/general-data-protection-regulation/

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24. Newsletter – success measurement

The newsletters contain a so-called „web-beacon“, this means a pixel-sized file which is retrieved from the server of our mail carrier when the newsletter is opened. This way we can determine if a newsletter has been opened and which links have been clicked on. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type and operating system).

This data is for statistical analysis of newsletter campaigns only. The results of these analyses can be used to better tailor future newsletters to the interests of the recipient.

If you do not wish to be analysed by Sendgrid, you have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter message.

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25. Deployment and use of affiliate programs in the Bonus Program

SNOWELL has integrated hyperlinks from various affiliates as part of the bonus program at https://en.snowell.com/bonusprogram/. Based on this legitimate interest according to art. 6 (1) (f) of the GDPR, we use industry-standard tracking measures, as far as these are necessary for the operation of the bonus program.

The services offered by our contractual partners can also be advertised and linked to other websites (so-called affiliate links). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.

Summarizing, it is necessary for our bonus program and the issuance of the coupons that we can check whether users who are interested in the offers of our affiliates, also make use of the offers via the affiliate links. For this purpose, a cookie is placed on the information technology system of the user after calling the affiliate link. No personal data is saved, but purely tracking-specific values, such as Ad ID, affiliate ID, time and categorization. The purpose of the storage of the data is the processing of commission payments between SNOWELL and the contracting party as well as the subsequent issue of coupons to the user.

The user can prevent the setting of cookies at any time by means of a corresponding setting of the Internet browser and thus permanently preventing the creation of cookies, or reject the cookie consent after the approval page has appeared. With this objection, the user agrees not to participate in the Bonus Program.

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26. Issuing coupons from the BONUS PROGRAM

With the SNOWELL BONUS PROGRAM you can collect coupons all year round. Receipt of SNOWELL coupons requires the specification of salutation, surname, first name, email address, selection of bonus partners, information of their booking number, booking date, booking amount and the beginning and end of the booked service. On the basis of this information, we can compare your booking with the BONUS PARTNER and issue the SNOWELL coupon to the BONUS PARTNER at the end of the booked service. Processing is based on art. 6 (1) (a) of the GDPR.

The deletion of the vouchers and the associated data takes place after expiry of statutory warranty and comparable obligations; in case of legal archiving obligations, deletion takes place after its expiration (end of commercial and taxation retention requirements of 10 years).

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27. Competitions, discount codes

The handling of competitions and discount codes on Facebook takes place via the service provider Woobox LLC, 101 E 6th St 220, Vancouver, Washington 98660. https://woobox.com/privacy

The service provider is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. https://www.privacyshield.gov/participant?id=a2zt0000000TN86AAG&status=Active

The service provider may use the data of the users in pseudonymous form, this means without assignment to a user, to optimize or improve their own services.

Upon participation, we collect the following data: salutation, surname, first name, email address or a Facebook Like is required. Based on this information, we can draw prizes and contact the winners. Processing is based on art. 6 (1) (a) of the GDPR.

The deletion of the contact data takes place 24 months after the draw / termination of the competition.

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28. User activity ticker

On our website, the current movements of the users are shown in a ticker. With this ticker, we want to give users an overview of our offers and content. It is displayed on the basis of the IP address and the pages or information visited by the user. This data is processed live on the basis of art. 6 (1) (f) of the GDPR. The processed data is not saved.

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29. Business analysis and market research

In order to operate our business economically, to be able to recognize market trends, customer and user requirements, we analyse the data we have on business transactions, contracts, inquiries, etc. We process report data, communication data, contract data, payment data, user data, meta data on the basis of art. 6 (1) (f) of the GDPR where the persons affected include customers, prospects, business partners, visitors and users of the online offer.

The analyses are carried out for the purpose of business analysis, marketing and market research. This allows us to display the profiles of the registered users by, e.g. taking into account their reservation processes. The analyses helps us to increase the user-friendliness, the optimization of our offer and the business economics. The analyses are only of use to us.

If these analyses or profiles are personal, they will be deleted or anonymised upon termination of the users. Incidentally, the overall business analyses and general trend provisions are created anonymously if possible.

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30. Cookies and right to object in direct mail

“Cookies” are small files that are stored on users` computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is saved) during or after his visit to an online offer. Temporary cookies, e.g. “session cookies” or “transient cookies” are cookies that are deleted after a user leaves an online service and closes his browser. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. contents of the shopping cart are saved when users visit them after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for scope measurement or marketing purposes. A “third party cookie” refers to cookies that are stored by other providers, e.g. Google, Facebook, advertisers. For more information see the explanations of the respective provider.

We use temporary and permanent cookies. The legal basis for the data, processed by cookies, is art. 6 (1) (f) of the GDPR.

If users do not want cookies stored on their computer, they will be asked to deactivate the option in their browser`s system settings. Saved cookies can be deleted in the system settings of the browser or automatically deleted after expiration of the validity period of 90 days. The exclusion of cookies can lead to functional restrictions of our online offer.

A general objection regarding the use of cookies for online marketing purposes can be found in a variety of services, especially in the case of tracking, explained via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/.

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31. Google analytics

Based on our legitimate interests (this means in the analysis, optimization and economic operation of our online offer within the meaning of art. 6 (1) (f) of the GDPR) we use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within our online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there.

The IP address submitted by the user`s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; users may also prevent the storage of the data generated by the cookies and the use of the data from the online offer, as well as the processing of these data by Google, if they download and install the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

More information about the use of data by Google, options for settings and objection can be found in the privacy policy of Google https://policies.google.com/technologies/ads or in the Google Ads settings https://adssettings.google.com/authenticated.

The personal data of users will be deleted after 38 months.

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32. Google re- / marketing services

On the basis of our legitimate interests (e.g. interest in the analysis, optimization and economic operation of our online offer within the meaning of art. 6 (1) (f) of the GDPR, we use the marketing and remarketing services (“Google Marketing Services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, („Google“).

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. For example, if a user is shown advertisements for products for which he is interested on other websites, they refer to “remarketing”. For these purposes, when accessing Google and our other websites on which Google Marketing Services are active, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also called “Web Beacons”) are incorporated in the website. With their help, the user is provided with an individual cookie, this means that a small file is saved (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file is noted which web pages the user visited, in which content he is interested and what offers he has clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and other information on the use of the online offer. The IP address of the users is also registered, and in the context of Google Analytics we inform you that the IP address will be shortened according to the information provided by the member states of the European Union or other parties to the agreement on the European Economic Area and that only exceptionally, the data is transferred entirely to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers from Google. The above mentioned information may also be linked with information from other sources by Google. If the user visits other websites, then other ads, tailored to his interests, can be displayed.

The data of the users are pseudonym processed in the context of the Google Marketing Services. This means that e.g. Google does not save and process the name or email address of the user, but processes the relevant data cookie-related within pseudonymous user profiles. From the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who the cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without pseudonymization. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google`s servers in the United States.

Among the Google Marketing Services we use is among other things the online advertising program “Google AdWords”. In the case of Google AdWords, each advertiser receives a different “conversion cookie”. Cookies cannot be tracked through AdWords advertisers´ websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information which personally identifies users.

We can incorporate third-party ads based on the Google AdSense marketing service. AdSense uses cookies that enable Google and its affiliate sites to serve ads based on users` visits to this site or other sites on the Internet.

In addition, we may use the “Google Tag Manager” to integrate and manage the Google Analytics and Marketing Services on our website.

For more information about Google´s data usage for marketing, see the overview page: https://www.google.com/policies/technologies/ads, Google`s Privacy Policy is available on https://www.google.com/policies/privacy.

If you wish to opt-out of interest-based advertising by Google Marketing Services, you can use Google`s setting and opt-out options: http://www.google.com/ads/preferences.

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33. Google reCAPTCHA

We include the function to detect bots, e.g. when entering online forms (“ReCaptcha”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

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34. Google Maps

We include maps from the Google Maps service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the user, but these are not collected without their consent (usually as part of the settings of their mobile devices). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

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35. Online presence in social media

We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users who are active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guide lines for the respective operators apply.

Unless otherwise stated in our data protection policy, we process user´s data as long as they communicate with us via social networks and platforms, e.g. write posts on our online sites or send us messages.

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36. Use of Facebook social plugins

Based on our legitimate interests (this means in the analysis, optimization and economic operation of our online offer within the meaning of art. 6 (1) (f) of the GDPR) we use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can represent interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f) on blue tile, the terms “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

When a user calls a function of this website that contains a social plugin, his device will connect directly to the servers of Facebook. The content of the plugin is directly transmitted by Facebook to the device of the user and incorporated by him into the online offer. In the process, user profiles can be created from the processed data. Therefore, we have no influence on the amount of data that Facebook collects with the help of this plugin and inform the users according to our knowledge.

By integrating the plugins, Facebook receives information that a user has accessed the corresponding page of the online offer. If the user logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, e.g. press the “Like” button or leave a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymous IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and setting options for protecting the privacy of users, can be found in Facebook´s privacy policy: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Other settings and objections regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or the US-site http://www.aboutads.info/choices/ or the EU-site http://www.youronlinechoices.com/. The settings are platform independent, this means that they are adopted for all devices, such as desktop computers or mobile devices.

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37. Facebook pixels, Custom Audiences and Facebook conversion

Within our online offer, due to our legitimate interests, optimization and economic operation of our online offer and for these purposes, the so-called “Facebook pixels” of the social network Facebook, by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are used.

Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

With the help of the Facebook pixels, it is possible for Facebook, among other things, to label the visitors of our online offer as a target group for displaying advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook pixels to display the Facebook Ads we have been sent only to those Facebook users who have shown an interest in our online offer or who have certain features (e.g. interest in certain topics or products determined by the visited web pages) which we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixels, we also want to make sure that our Facebook ads are in line with the potential interest of the users and not annoying. With the help of the Facebook pixels, we can also understand the effectiveness of the Facebook ads for statistical and market research purposes, in which we see whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

The processing of the data by Facebook is part of Facebook`s data usage policy. Accordingly, general notes on how to display Facebook Ads can be found in Facebook`s Data Usage Policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook pixels and its functions, visit the help section of Facebook: https://www.facebook.com/business/help/651294705016616.

You may object to the capture of the Facebook pixels and use of your data to display Facebook Ads. To set which types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions for the usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform independent, which means they are adopted for all devices, such as desktop computers or mobile devices.

You can also deactivate the use of Cookies for scope measurement and promotional purposes via the deactivation page of the Network Advertising Initiative http://optout.networkadvertising.org/ and further via the US website http://www.aboutads.info/choices or the European website http://www.youronlinechoices.com/.

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38. Google+

Furthermore, this website uses the “+1” button of Google Plus. It is operated by Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA). If you visit a page that contains the “+1” button, a direct connection is created between your browser and the Google servers. The website operator therefore has no influence whatsoever on the nature and extent of the data transmitted by the plugin to the servers of Google Inc. If you click on the “+1” button while logged in to Google+, you share the content of the page on your public profile.

Personal data is not collected by Google Inc. until you click the button. Even with logged in Google users, among other things, the IP address is stored. If you would like to prevent Google Inc. from storing this data and linking it to your account, please log out before visiting this website.

For information on the “+1” button, see https://developers.google.com/+/web/buttons-policy.

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39. Twitter

Within our online offers, features and content of the Twitter service can be offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. This may include images, videos or texts and buttons that users use to promote their content and subscribe to the content of our messages. If the users are members of the Twitter platform, Twitter can link the content and function to the profiles of the users there. Twitter is certified under the Privacy Shield agreement, which provides a guarantee to comply with European privacy legislation https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

Privacy policy: https://twitter.com/en/privacy, Opt-Out: https://twitter.com/personalization.

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40. Instagram

Within our online offers, features and content of the Instagram service offered by die Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, may be incorporated. This may include images, videos or texts and buttons that users use to promote their content, subscribe to the content creators or subscribe to our posts. If the users are members of the platform Instagram, Instagram can link the contents and functions to the profiles of the users there. Instagram privacy policy: http://instagram.com/about/legal/privacy/.

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41. Youtube

On our website, we use components (videos) from the company YouTube, LLC 901 Cherry Ave., 94066 San Bruno, CA, USA, a company of Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA.

When you visit a page that has an embedded video, it will connect to the YouTube servers and display the content by notifying your browser on the website.

According to information provided by YouTube, in “-enhanced privacy mode-“ only data is transmitted to the YouTube server, in particular which of our web pages you have visited when watching the video. If you are logged in to YouTube at the same time, this information will be associated with your Membership Account on YouTube. You can prevent this by logging out of your member account before visiting our website.

Additional information about YouTube`s privacy policy is provided by Google at the following link: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

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42. Language used

The official language of this data protection policy is German. All translations into other languages are intended to inform our customers. The contractually binding version is in German.

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SNOWELL International AG
Duxgass 25 | FL-9494 Schaan
E-Mail: info@snowell.com
Telefone: +423 239 61 81

SNOWELL International AG, mai 2018

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Booking information: © SNOWELL International AG | Duxgass 25 | 9494 Schaan | Phone: +423 239 61 81 | Email: info@snowell.com