Privacy Policy

With this Privacy Policy, we inform you about the personal data we process in connection with our activities and operations, including our website. We particularly explain why, how, and where we process which personal data. We also inform about the rights of individuals whose data we process.

For specific or additional activities and operations, further privacy policies and other legal documents, such as Terms and Conditions (T&Cs), Usage Terms, or Participation Terms, may apply.

We are subject to Swiss data protection law and, if applicable, foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. Contact Addresses

Responsible for the processing of personal data:

Graubünden Ferien
Alexanderstrasse 24
7001 Chur

We indicate when, in individual cases, there are other parties responsible for the processing of personal data.

1.1 Data Protection Officer or Data Protection Advisor

We have the following data protection officer or the following data protection advisor as a point of contact for affected individuals and authorities for inquiries related to data protection:

Manuela Ruinatscha
Graubünden Ferien
Alexanderstrasse 24
7001 Chur

1.2 Data Protection Representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 GDPR:

VGS Datenschutz­partner GmbH
Am Kaiserkai 69
20457 Hamburg

The data protection representation serves as an additional point of contact for affected individuals and authorities in the European Union (EU) and in the rest of the European Economic Area (EEA) for inquiries related to the GDPR.

2. Terms and Legal Bases

2.1 Terms

Personal data are all details that relate to a specific or identifiable natural person. An affected person is a person whose personal data we process.

Processing includes every handling of personal data, regardless of the means and methods used, such as querying, comparing, adjusting, archiving, storing, reading out, disclosing, obtaining, capturing, collecting, deleting, disclosing, arranging, organizing, saving, altering, distributing, linking, destroying, and using personal data.

The European Economic Area (EEA) includes the Member States of the European Union (EU) as well as Liechtenstein, Iceland, and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

2.2 Legal Bases

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

We process – insofar as and to the extent the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:

  • Art. 6 Para. 1 lit. b GDPR for the necessary processing of personal data for the fulfillment of a contract with the data subject and for carrying out pre-contractual measures.
  • Art. 6 Para. 1 lit. f GDPR for the necessary processing of personal data to safeguard the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are particularly our interest in being able to carry out our activities and tasks in a sustainable, user-friendly, secure, and reliable manner, ensuring information security, protection against misuse, enforcing our own legal claims, and compliance with Swiss law.
  • Art. 6 Para. 1 lit. c GDPR for the necessary processing of personal data to meet a legal obligation to which we may be subject under any applicable law of member states in the European Economic Area (EEA).
  • Art. 6 Para. 1 lit. e GDPR for the necessary processing of personal data to perform a task in the public interest.
  • Art. 6 Para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 Para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

3. Nature, Scope, and Purpose

We process those personal data that are necessary to be able to carry out our activities and tasks sustainably, user-friendly, securely, and reliably. Such personal data can, in particular, fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data, usage data, location data, sales data, and contract and payment data.

We process personal data for the duration necessary for the respective purpose or purposes or as required by law. Personal data that are no longer necessary are anonymized or deleted.

We may have personal data processed by third parties. We can process personal data together with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also ensure data protection with such third parties.

We process personal data fundamentally only with the consent of the persons concerned. If and to the extent that processing is permitted for other legal reasons, we may waive obtaining consent. For example, we can process personal data without consent to fulfill a contract, to meet legal obligations, or to safeguard overriding interests.

In this context, we process, in particular, information that a person concerned voluntarily provides to us when contacting us – for example, by regular mail, email, instant messaging, contact form, social media, or telephone – or when registering for a user account. We can store such details, for example, in an address book, a customer relationship management system (CRM system), or with comparable tools. When we receive data about other people, the sending parties are obliged to ensure data protection towards these people and to ensure the accuracy of this personal data.

We also process personal data that we obtain from third parties, obtain from publicly accessible sources, or collect during the exercise of our activities and tasks, provided and insofar as such processing is legally permissible.

4. Personal Data Abroad

We process personal data primarily in Switzerland and within the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, particularly to process or have them processed there.

We can export personal data to any country and territory on Earth and elsewhere in the Universe, as long as the local laws are in accordance with the decision of the Swiss Federal Council to ensure adequate data protection and – if and when the General Data Protection Regulation (GDPR) applies – in accordance with the decision of the European Commission ensuring adequate data protection.

We may transfer personal data to countries whose laws do not ensure adequate data protection, as long as data protection is guaranteed for other reasons, particularly based on standard data protection clauses or other suitable guarantees. In exceptional cases, we may export personal data to countries without adequate or suitable data protection if specific data protection requirements are met, such as the explicit consent of the affected individuals or a direct connection with the conclusion or execution of a contract. Upon request, we will inform affected individuals about potential guarantees or provide a copy of any such guarantees.

5. Rights of Affected Individuals

5.1 Data Protection Rights

We grant all rights to affected individuals in accordance with applicable data protection laws. Affected individuals have, in particular, the following rights:

  • Access: Affected individuals can request information on whether we process their personal data and, if so, which personal data are involved. They will also receive the necessary information to assert their data protection rights and ensure transparency. This includes the processed personal data as such, but also, among other things, details about the purpose of the processing, the retention period, any disclosure or potential export of data to other countries, and the source of the personal data.
  • Correction and Restriction: Affected individuals can correct inaccurate personal data, complete incomplete data, and request the restriction of their data processing.
  • Deletion and Objection: Affected individuals can request the deletion of personal data (the "right to be forgotten") and object to the processing of their data with future effect.
  • Data Release and Transfer: Affected individuals can request the release of personal data or the transfer of their data to another controller.

We may postpone, limit, or deny the exercise of rights of affected individuals within the legally permissible framework. We may point out to affected individuals any requirements that may need to be met for the exercise of their data protection rights. For instance, we might deny access by citing business secrets or the protection of other individuals either wholly or partially. Similarly, we might refuse the deletion of personal data entirely or in part by referring to statutory retention obligations.

We may, exceptionally, charge costs for the exercise of rights. We will inform affected individuals in advance about any potential costs.

We are obligated to identify affected individuals who request information or assert other rights with appropriate measures. Affected individuals have a duty to cooperate.

5.2 Right to Lodge a Complaint

Affected individuals have the right to enforce their data protection rights through legal channels or to file a complaint with a competent data protection supervisory authority.

The supervisory authority for data protection for private entities and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

Affected individuals have – if and when the General Data Protection Regulation (GDPR) applies – the right to lodge a complaint with a competent European data protection supervisory authority.

6. Data Security

We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. However, we cannot guarantee absolute data security.

Access to our website is via transport encryption (SSL/TLS, especially with the Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication is subject to – as is fundamentally all digital communication – mass surveillance without reason or suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the corresponding processing of personal data by intelligence services, police departments, and other security agencies.

7. Use of the Website

7.1 Cookies

We may use cookies. Cookies – both our own cookies (First-Party-Cookies) and cookies from third parties whose services we use (Third-Party-Cookies) – are data stored in the browser. Such stored data is not limited to traditional text-form cookies.

Cookies can be stored temporarily in the browser as "session cookies" or for a specific period as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies, in particular, allow a browser to be recognized on a subsequent visit to our website, thus, for instance, measuring our website's reach. However, permanent cookies can also be used for online marketing.

Cookies can be deactivated or deleted in the browser settings at any time, either entirely or in part. Our website might not be fully functional without cookies. We request – at least if and as far as necessary – explicit consent for the use of cookies.

For cookies used for success and reach measurement or for advertising, a general objection (an "opt-out") is possible for numerous services through AdChoices (Digital Advertising Alliance), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

7.2 Server Log Files

We can record the following details for each access to our website, provided they are transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including timezone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, accessed sub-page of our website including the amount of data transferred, the last webpage accessed in the same browser window (referer or referrer).

We store such details, which can also represent personal data, in server log files. These details are necessary to offer our website continuously, user-friendly, and reliably, and to ensure data security and thus particularly the protection of personal data – even through third parties or with the help of third parties.

7.3 Tracking Pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are small, typically invisible images that are automatically retrieved when visiting our website. With tracking pixels, the same information as in server log files can be captured.

8. Notifications and Communications

We send notifications and communications via email and other communication channels such as instant messaging or SMS.

8.1 Success and Reach Measurement

Notifications and communications can contain web links or tracking pixels that record whether a particular message was opened and which web links were clicked on. Such web links and tracking pixels can also record the use of notifications and communications in a personal manner. We need this statistical recording of use for success and reach measurement to send notifications and communications effectively and user-friendly based on the needs and reading habits of the recipients, and to do so continuously, securely, and reliably.

8.2 Consent and Objection

You must basically explicitly consent to the use of your email address and your other contact addresses unless the use is permitted for other legal reasons. For any consent, we preferably use the "double opt-in" procedure, meaning you will receive an email with a web link that you must click to confirm so that no misuse can be made by unauthorized third parties. We may log such consents including the Internet Protocol (IP) address as well as date and time for evidential and security reasons.

You can basically object to receiving notifications and communications, such as newsletters, at any time. With such an objection, you can simultaneously object to the statistical recording of the use for success and reach measurement. Reserved are necessary notifications and communications related to our activities and operations.

8.3 Service Providers for Notifications and Communications

We send notifications and communications with the help of specialized service providers.

We use in particular:

9. Social Media

We have a presence on social media platforms and other online platforms to communicate with interested parties and to inform them about our activities and services. In relation to these platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The general terms and conditions (GTC), terms of use, data protection declarations, and other provisions of the individual platform operators also apply. These provisions provide information about the rights of affected individuals directly with the respective platform, such as the right to access.

For our Facebook social media presence, including the so-called Page Insights, we – to the extent and if the General Data Protection Regulation (GDPR) is applicable – share responsibility with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including those in the USA). Page Insights provide insights into how visitors interact with our Facebook presence. We use Page Insights to effectively and user-friendlyly manage our Facebook presence.

Further details about the type, scope, and purpose of data processing, information on the rights of affected persons, and the contact details of Facebook and the Facebook data protection officer can be found in the Facebook Privacy Policy. We have concluded the so-called "Addendum for Controllers" with Facebook and have especially agreed that Facebook is responsible for ensuring the rights of affected individuals. Information on Page Insights can be found on the "Page Insights Information" page, including "Page Insights Data Information".

10. Third-Party Services

We use services from specialized third parties to permanently, user-friendly, safely, and reliably carry out our activities and services. With such services, we can embed functions and content into our website. When embedding, the services used technically necessarily capture at least temporarily the Internet Protocol (IP) addresses of users for a short period.

For required security-relevant, statistical, and technical purposes, third parties whose services we use can process data related to our activities and services in an aggregated, anonymized, or pseudonymized manner. These are, for example, performance or usage data to offer the respective service.

We especially use:

10.1 Digital Infrastructure

We use services from specialized third parties to access the required digital infrastructure in relation to our activities and tasks. This includes, for example, hosting and storage services from selected providers.

We specifically use:

10.2 Automation and Integration of Apps and Services

We use specialized platforms to integrate and connect existing third-party apps and services. With such "No-Code" platforms, we can also automate processes and tasks with third-party apps and services.

We specifically use:

10.3 Contact Options

We use services from selected providers to better communicate with third parties, such as potential and existing customers.

We specifically use:

10.4 Audio and Video Conferencing

We use specialized services for audio and video conferencing to communicate online. For example, we can hold virtual meetings or conduct online classes and webinars. The legal texts of the individual services, such as privacy statements and terms of use, additionally apply to participation in audio and video conferences.

We recommend, depending on the situation, to mute the microphone by default when participating in audio or video conferences, to blur the background, or to use a virtual background.

We specifically use:

10.5 Online Collaboration

We use third-party services to enable online collaboration. In addition to this privacy policy, the directly visible conditions of the used services, such as terms of use or privacy statements, also apply.

We specifically use:

10.6 Social Media Features and Social Media Content

We use third-party services and plugins to embed features and content from social media platforms and to enable sharing content on social media platforms and in other ways.

We specifically use:

10.7 Map Material

We use third-party services to embed maps into our website.

We specifically use:

10.8 Digital Audio and Video Content

We use services from specialized third parties to enable the direct playback of digital audio and video content, such as music or podcasts.

We specifically use:

10.9 Advertising

We use the opportunity to display targeted advertising for our activities and tasks on third parties, such as social media platforms and search engines.

With such advertising, we particularly want to reach people who are already interested in our activities and tasks or could be interested in them (Remarketing and Targeting). For this, we can transmit corresponding - possibly also personal - information to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e., in particular, whether it leads to visits to our website (Conversion Tracking).

Third parties, where we advertise and where you are registered as a user, may possibly associate the use of our website with your profile there.

We specifically use:

11. Extensions for the Website

We use extensions for our website to access additional features.

12. Performance and Reach Measurement

We strive to determine how our online offer is used. In this context, we can, for instance, measure the success and reach of our activities and operations as well as the impact of third-party links on our website. We can also test and compare how different sections or versions of our online offer are used ("A/B test" method). Based on the results of the performance and reach measurement, we can particularly fix errors, strengthen popular content, or make improvements to our online offering.

For performance and reach measurement, the Internet Protocol (IP) addresses of individual users are usually stored. In this case, IP addresses are fundamentally shortened ("IP-masking") to adhere to the principle of data minimization through appropriate pseudonymization.

During the performance and reach measurement, cookies may be used, and user profiles can be created. Any created user profiles might include, for example, the individual pages visited or content viewed on our website, information about the size of the screen or browser window, and the - at least approximate - location. Fundamentally, any user profiles are exclusively created in a pseudonymized manner and are not used to identify individual users. Some third-party services, where users are logged in, might associate the use of our online offer with the user account or user profile on the respective service.

We particularly use:

13. Final Provisions

We created this privacy policy with the Data Protection Generator from Datenschutzpartner.

We can adjust and supplement this privacy policy at any time. We will inform about such adjustments and supplements in an appropriate form, especially by publishing the current privacy policy on our website.