Your data protection is important for us
With the information provided to you below, we would like to give an overview of how your personal data are processed when you use our websites pages or our app as well as when you stay at one of our hotels, and to inform you of your rights under data protection legislation.
I. Information on processing of personal data
By way of introduction, we would like to draw your attention to our extensive information on creating transparency according to Articles 13 and 14 GDPR.
1. Controller for data processing
The controller for data processing on this website pursuant to Article 4 No 7 GDPR and the provider of the website (service provider) within the meaning of the German Tele Media Act (Telemediengesetz – TMG) is
Projekt 1 Hotel GmbH & Co.KG
D- 69115 Heidelberg
Telefon: +49 6221 651 7739
Fax: +49 6221 651 7765
Complete details pursuant to section 5 TMG (Imprint)
2. Contact details of the Data Protection Officer
You can reach our Data Protection Officer at
Projekt 1 Hotel GmbH & Co.KG
D- 69115 Heidelberg
Telefon: +49 6221 651 7739
Fax: +49 6221 651 7765
3. Purposes and legal basis for processing personal data
We process your personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR), the new German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG-new) as well as all other relevant legislation for the purposes and on the legal basis as set out below:
(a) For processing and managing reservation inquiries and reservations as well as for providing our services under the accommodation agreement, including execution of your hotel stay and payments processing (in particular also for tracking your use of our services (telephone, bar, spa, pay TV programmes, etc.), for performing check-in and managing access to the rooms) – the legal basis for this is the first sentence of Article 6(1)(b)) GDPR.
(b) For fulfilling a legal obligation to which our company is subject as controller (e.g. by reason of reporting legislation, tax laws, accounting obligations, etc.) – the legal basis for this is the first sentence of Article 6(1)(c)) GDPR.
(c) For sending our e-mail newsletter including managing your subscription to the newsletter – the legal basis for this is your consent pursuant to the first sentence of Article 6(1)(a)) GDPR.
(d) For executing and managing your participation in our loyalty programme – the legal basis for this is your consent pursuant to the first sentence of Article 6(1)(a)) GDPR.
(e) For maintaining, safeguarding and improving the quality of our products and services, in particular by performing and analysing satisfaction surveys and guest comments, by processing your personal data in our centralised guest database enabling us to recognise you as a returning guest, to better appreciate your expectations and wishes, to improve the quality and individual character of our communication with you and to create offerings tailored to you – the legal basis for this is the first sentence of Article 6(1)(f)) GDPR. Our overriding legitimate interests arise from the accommodation agreement entered into with you representing a relative and appropriate relationship within the meaning of Recital 47 of the GDPR, as well as from the fact that this type of data processing is standard industry practice with international hotel chains and is in keeping with the reasonable expectations of the majority of guests. As part of the group of undertakings to which the companies operating hotels under the umbrella brand Hotelo belong (in this regard cf. also item 4 below – Categories of recipients), our company moreover has a legitimate interest, pursuant to Recital 48 of the GDPR, in transmitting personal data of the guests within the group of undertakings for internal administrative purposes.
(f) For direct advertising of our offerings and services – the legal basis for this is the first sentence of Article 6(1)(f)) GDPR. Our overriding legitimate interest follows from Recital 47 of the GDPR.
(g) For ensuring compliance with house rules, for preventing and clarifying criminal acts (in particular also by video monitoring), for establishing and defending against legal claims and for safeguarding interests in legal disputes, for ensuring IT security and IT operation, for identifying credit risks – the legal basis for this is the first sentence of Article 6(1)(f) GDPR. Our overriding legitimate interests following from our obligation to ensure that our guests have a safe stay in the hotel as well as from our interest in enforcing our tangible and intangible claims and safeguarding our rights as well as defending against unjustified claims. Furthermore, the processing of personal data in the scope which is absolutely required to prevent fraud pursuant to Recital 47 of the GDPR likewise constitutes a legitimate interest of our company.
Minors may not send any personal data to us without the consent of their parents or guardians. Through our website, we do not process any personal data knowingly acquired from minors.
4. Categories of personal data recipients
If and to the extent required for the purposes as set out above under item 3, we also disclose your personal information to the following recipients or categories of recipients pursuant to Article 4 No 9 GDPR:
Within our company only those persons or entities are permitted to view or access your data (to the extent required in each case) who need such data for performance of our contractual and statutory duties.
The service providers (e.g. as part of contract processing pursuant to Article 28 GDPR) and agents engaged by us may receive personal data for these purposes. These are undertakings from the categories credit services and payments processing, IT services, cleaning services, logistics, printing services, telecommunications, collecting, advising and consulting as well as distribution and marketing. The respective service providers are found in the List of Service Providers/Processors, which is updated on a regular basis.
Furthermore, a disclosure of data may be made to public bodies and institutions if a statutory obligation to do so exists (e.g. financial authorities, criminal prosecution authorities).
Further data recipients may be those entities for which you have given us your consent to data transfer.
5. Transfer of personal data to a third country
A transfer of personal data to entities in countries outside the European Union (third countries) takes place if
(a) it is required to carry out your reservations or execute your hotel stay,
(b) it is prescribed by law, or
(c) you have given us your consent.
As can be seen from the List of Service Providers/Processors in detail, our company for certain tasks uses service providers which have their corporate seat in a third country or which belong to an international group with companies in third countries or which for their part work together with service providers having their seat in a third country. A transfer of personal data to such service providers is permissible if the European Commission has decided that the third country in question ensures an adequate level of protection (pursuant to Article 45 GDPR). If the Commission has not made such decision, our company or the service provider may transfer personal data to a third country or an international organisation only if appropriate safeguards are provided for and enforceable data rights and effective legal remedies are available (Article 46(1) GDPR).
Beyond the cases mentioned above, our company does not transfer personal data to entities in third countries or to international organisations.
6. Period of storage of personal data and criteria for defining such period
We process and store your personal data for as long as required for us to fulfil our contractual and legal duties. If the data are no longer required for fulfilment of contractual duties, they are normally deleted unless their further processing for a limited term is required by retention periods prescribed by commercial or tax legislation (including the German Commercial Code (Handelsgesetzbuch – HGB), German Tax Code (Abgabenordnung – AO)). The periods prescribed their for storage and/or documentation purposes range from two to ten years.
7. Your rights as a data subject
Every data subject whose personal data are processed has the right to obtain information from the controller about the personal data in question pursuant to Article 15 GDPR, the right to rectification pursuant to Article 16 GDPR, the right to erasure pursuant to Article 17 GDPR, the right to restriction of processing pursuant to Article 18 GDPR, the right to object to the processing pursuant to Article 21 GDPR as well as the right to data portability pursuant to Article 20 GDPR. The right to obtain information and the right to erasure are further subject to the restrictions pursuant to sections 34 and 35 BDSG-new.
Further information on your right to object to processing pursuant to Article 21 GDPR.
If the processing of your personal data is based on a consent granted to us, you have the right to revoke your consent at any time without the legality of the processing performed on the basis of such consent up to revocation being affected thereby.
Your also have the right to lodge a complaint with the competent data protection supervisory authority pursuant to Article 77 GDPR in conjunction with section 19 BDSG-new.
8. Obligation to provide data
As part of our contractual relationship, you are required provide such personal data which are required to establish and perform the accommodation agreement or which we are legally required to collect. Without such data, we will generally not be able to conclude the agreement with you or to execute the same. We are particularly required by section 30 (2) of the German Federal Registration Act (Bundesmeldegesetz – BMG) to record certain personal data about you on the registration card (Meldeschein). In the event you should not provide us with the necessary information, we might not be able to provide you with the requested services or might not be able to do so completely.
9. Automated decision-making and profiling
When establishing and executing our contractual relationship, you will not be subjected to a decision based solely on automated processing, including profiling, pursuant to Article 22 GDPR, which produces legal effects concerning you or similarly affects you in a serious way.
10. Additional information on your right to object pursuant to Article 21 GDPR
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning yourself which are based on the first sentence of Article 6(1)(e)) GDPR (data processing in the public interest) or the first sentence of Article 6(1)(f)) GDPR (data processing based on a balancing of interests), including profiling based on those provisions pursuant to Article 4(4) GDPR.
If you make an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override the your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
If your personal data are processed by us for direct marketing purposes, you have the right to object at any time to processing of personal data concerning yourself for such marketing, which includes profiling to the extent that it is related to such direct marketing.
The objection may be made without any particular form and should be directed to our Data Protection Officer under the contact details specified in item 2 above.
II. Additional information on data processing on this website
1. User account/account
You can register for a user account (account) on our website with your e-mail address and the allocation of a password. This registration can be done via the menu item “Registration” in the header or by adding a password when you make your booking and input your personal data.
Upon successful registration, a user account (account) will be created for you automatically, which is valid for the websites of all hotel brands, Hotelo hotels and resorts belonging to Projekt 1 Hotelo GmbH & Co.KG. By registering for the user account, you declare your agreement with the disclosure of the information you provided with the registration to the respective operators of the aforementioned websites.
In the user account you can see and edit (e.g. cancel or change) all the bookings you have transacted since your registration by providing your user data via one of the aforementioned websites or via the SHR App. You may delete your user account at any time.
The legal basis for processing your personal data in connection with the creation and use of your user account is your consent according to the first sentence of Article 6(1)(a)) GDPR.
2. E-mail newsletter
With the e-mail newsletter we keep you regularly informed about the offerings and services of the hotels Hotelo as about the offerings in accordance with the preferences stated by you.
If you wish to receive the e-mail newsletter, we will need a valid email address for you. For those registering for our newsletter, we use what is known as the double-opt-in procedure. That means that after your registration we send you an e-mail to the e-mail address specified in which we ask you to confirm that you wish to be sent the newsletter. If you do not confirm your registration within 2 weeks, your information is blocked and after one month automatically deleted. Moreover, we store in each case your IP addresses used and times of log-on and confirmation. The purpose of the procedure is to be able to prove your registration and where necessary to clarify any potential misuse of your personal data.
As a subscriber to the e-mail newsletter, you may at any time revoke your consent to the processing of your e-mail address for sending the newsletter. Consent may be revoked via the link provided for this purpose in each e-mail newsletter or by sending an e-mail with the subject “unsubscribe” to firstname.lastname@example.org.
Specifically, we use the following types of cookies:
Necessary cookies: These cookies are essential when it comes to helping improve your navigating and booking experience on our website. With them, fundamental functionalities and applications such as shopping carts or electronic invoicing processes are optimised and made easier to use. These cookies do not collect any information on you that can be used for marketing campaigns or statistical analyses.
Performance cookies: Performance cookies are used to collect anonymous statistical data on how Internet sites are used and at what places errors occur. They are supplemented by anonymised general data, such as information on visitor demographics or coverage. These cookies are essential when it comes to keeping Internet sites as performance-oriented as possible and make it possible to discover any errors or weaknesses.
Advertising cookies: With the help of these cookies, advertisements with content of relevant interest are supported. They are normally used by marketing networks with the operator’s consent and recognise users on different Internet sites of the participating organisations. These cookies are also used for services of third parties and make data available. We use targeted or advertising cookies for the link e.g. to Facebook in order to measure the effectiveness of our online and offline advertising.
The data processed by cookies are required for the aforementioned purposes of safeguarding our legitimate interests as well as those of third parties pursuant to the first sentence of Article 6(1)(f) GDPR.
In your browser settings you may allow cookies to be stored only if your give your consent. Most browsers accept cookies automatically. However, you may configure your browser in such a way that no cookies are stored on your computer or that a notice is always displayed before a new cookie is created. But completely deactivating cookies may mean that you cannot use all functions of our website. If you wish to use only Hotelo cookies but do not wish to accept cookies of partners, please select the option “Block cookies of third-party providers” in your browser. In the drop-down menu of your web browser, you will be displayed a help function showing you how to reject cookies and to disable cookies already received. In the case of shared-use computers that accept cookies and flash cookies, we recommend always logging off completely after the end of the session.
4. Analysis tools
The tracking measures used by use as specified below are performed on the basis of the first sentence of Article 6(1)(f) GDPR. With the tracking measures used we want to ensure that our website is designed to meet the needs of users and optimized on a continuous basis. We moreover use the tracking measures to statistically record the use of our website and to evaluate such use to optimize our offering for you. Such interests are to be deemed legitimate within the meaning of the aforementioned provision. The respective data processing purposes and data categories can be found in the relevant statements on such tracking tools.
This website also uses Google Analytics, a web analysis service of Google Inc. based in Mountain View, USA (“Google”). Google Analytics uses “cookies”. These are text files that are saved to your computer that allow your usage of the website to be analyzed. The information generated by the cookie about your use of this website will generally be transmitted to and stored by Google on a server in the United States.
Google provides IP anonymization (so-called IP masking) and this is activated on this website (by extending Google Analytics by the code “gat._anonymizeIp ();”); Google will therefore shorten and therefore anonymize your IP address within the European Union or in another member state of the European Economic Area. Only in exceptional cases will a full IP address be transmitted to a Google server in the USA and be shortened there.
On behalf of the operator of this website, Google will use the information collected through Google Analytics to analyses your use of the website, to compile reports on website activities and to render other services related to the use of the website and of the Internet in general to the website operator. The IP address transmitted by your browser in the context of Google Analytics will not be mixed with other Google data.
You may prevent the setting of cookies by Google Analytics by configuring your browser software accordingly; however, please note that in this case you may not be able to make full use of all functions of this website. In addition, you may prevent collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google and processing of these data by Google by downloading and installing the browser plug-in available under the following link (http://tools.google.com/dlpage/gaoptout?hl=de).
Furthermore, you can prevent Google Analytics from recording your use of the website by setting an “opt-out cookie” that will prevent your data from being collected during any future visits to this website. The opt-out cookie will be set if you click on the following link: Please click here to complete your objection.
The operator of this website also uses Google Analytics to analyses the data from AdWords and the DoubleClick cookie for statistical purposes. If you wish to opt out, please deactivate this function via the ads settings manager (http://www.google.com/settings/ads?hl=de).
You will find more information on the terms and conditions of usage and data protection of Google Analytics at http://www.google.com/analytics/terms/de.html and https://www.google.de/intl/de/policies/.
5. Inclusion of third-party services and content (e.g. YouTube and Google Maps)
Third-party content such as videos from YouTube or maps from Google Maps (hereafter referred to as “Third Party Providers”) are included in this website. To use such content, the user’s IP address for technical reasons must be sent to the respective Third Party Provider, since without the IP address the Third Party Providers would not be able to send the content included in the Website to the browser of the respective user. We do not have any control over whether a Third Party Provider stores the IP address e.g. for statistical purposes or otherwise.
6. Social media plug-ins
The plug-in provider stores the data collected about you in the form of a user profile and uses the data for advertising and market research and/or to make any required changes in the design of its website. Such evaluation is performed particularly (also for users not logged in) enable ads tailored to user demand and to inform other users of the social network about your activities on our website. You have a right to object to the creation of such user profiles. To exercise such right, you must contact the plug-in provider by following the procedure as set out below. Through plug-ins we offer you the possibility of interacting with social networks and other users. In that way we can improve our offering and make it more attractive for you as a user. The legal basis for the user of plug-ins is the first sentence of Article 6(1)(f) GDPR.
Data are disclosed regardless of whether you have an account with the plug-in provider and have logged in there. If you are logged in to the plug-in provider, your data collected from us are allocated directly to the account you hold with the plug-in provider. If you click on the activated button and e.g. link the page, the plug-in provider also stores this information in your user account and publicly discloses it to your contacts. As a rule, we recommend logging off after using a social network, especially, though, before activating the button, since that allows you to avoid your data being allocated with your profile with the plug-in provider.
The website uses social plug-ins (hereafter referred to as “plug-ins”) for the social network facebook.com, which is run by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereafter referred to as “Facebook”). The plug-ins display one of the Facebook logos (white “f” on blue tile or “thumbs up” symbol) or are designated with the comment “Facebook social plug-in”. A list and display of Facebook social plug-ins is available here: https://developers.facebook.com/docs/plugins/.
When a user accesses a page of our website that contains such a plug-in, his/her browser establishes a direct link to the servers of Facebook. The content of the plug-in will be transmitted from Facebook directly to the user’s browser, which will integrate it into the web page. The provider therefore has no control over the extent of data which Facebook collects through this plug-in. Based on the Provider’s most recent knowledge, Facebook proceeds as follows:
By imbedding of the plug-ins, Facebook receives the information that a user has accessed the respective web page of the Provider’s website. If the User is logged in to Facebook, Facebook may allocate the visit to the user’s Facebook account. If users interact with the plug-ins, for instance by clicking the “Like” button or leaving a comment, this information will be sent from the user’s browser directly to Facebook where it will be stored. If a user is not a Facebook member, there is still a possibility that Facebook will register and store this user’s IP address. According to Facebook, in Germany only anonymised IP addresses are stored.
For details on the purpose and scope of the data collection and further processing and use of the data by Facebook and users’ rights and configuration options to protect their privacy, users are advised to refer to the privacy information of Facebook at https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not wish Facebook to collect data about him/her via the Provider’s website and to link this to the user’s member data stored at Facebook, the user must log out of Facebook before visiting the provider’s website.
Likewise, it is possible to block the Facebook social plug-in with add-ons for the user’s browser, e.g. the “Facebook blocker”.
The website uses plug-ins of Instagram, which is operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”). The plug-ins are designated with an Instagram logo, e.g. in form of an Instagram camera.
When you access a page of this website which contains such a plug-in, your browser will establish a direct connection to the servers of Instagram. The content of the plug-in will be transmitted from Instagram directly to your browser, which will integrate it in the web page. Through this embedding, Instagram is provided with the information that your browser has accessed the respective page of our website, even if you do not have an Instagram profile or are not logged in to Instagram at the time. This information (including your IP address) will be transmitted directly to an Instagram server in the USA by your browser, and will be stored there.
If you are logged in to Instagram, Instagram may directly allocate the visit to our website to your Instagram account. If you interact with the plug-ins, e.g. click the “Instagram” button, this information will likewise be transmitted directly to an Instagram server and be stored there. This information will also be published in your Instagram account and be displayed alongside your contacts.
For details on the purpose and scope of the data collection and further processing and use of the data by Instagram and your rights as a user and configuration options to protect your privacy, please refer to the privacy information of Instagram: https://help.instagram.com/155833707900388/
If you do not wish Instagram to allocate the data collected through our website directly to your Instagram account you must log out of Instagram before you access our website. You may also completely prevent the loading of Instagram plug-ins by using add-ons for your browser, e.g. the script blocker “NoScript” (http://noscript.net/).
Current version and updating of this Private Policy
This Private Policy shall apply with effect from 1 May 2018.
We will update this Private Policy from time to time to reflect relevant changes to our website, changes in the processing of personal data or amendments to legislation. The revised version shall apply as of the published effective date. In the event of any material amendments to this Private Policy, we will inform you in good time prior to the effective date of such amendments by posting a notice on our website. Where applicable, we will also inform our guests of the amendments by e-mail or other means.