Company: Silverscreen Tours GmbH
Address: Grasweg 13, 90556 Seukendorf, Germany
Managing Partner: Per Egil Roksvaag
E-mail: contact @ silverscreen.tours
Phone: +49 911 98068843
Registration court: Amtsgericht Fürth, Germany
Registration number: HRB 16627
What kind of data do we process?
- Travel and tour information (e.g. names, addresses)
- Contact information (e.g. e-mail, phone numbers).
- Content data (e.g. text, photographs, videos).
- Contract data (e.g. subject, term, customer category).
- Payment data (e.g. bank details, payment history).
- Usage data (e.g. visited web pages, interest in content, access times).
- Meta / communication data (e.g. device information, IP addresses).
Processing of special categories of data (Art. 9 (1) GDPR):
We do not process any data that belong to special categories of personal data.
Categories of data subjects:
- Providers of travels and tours
- Participants of travels and tours
- Owner of copyrights and usage rights
- Customers, prospects, visitors and users of the online offer
- Business partners
In the following, we also refer to the data subjects as “users”.
Purpose of processing:
- Providing the online offer, its contents and features.
- Provision of contractual services and customer care.
- Answering contact requests and communicating with users.
- Marketing, advertising and market research.
- Safety measures.
As of June 2018
1.1. „personal data“ means any information relating to an identified or identifiable natural person („data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.2. „processing“ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term goes far and includes virtually every handling of data.
1.3. „controller“ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
2. Legal basis for data processing
4. Security measures
4.1. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons. These measures include in particular the safeguarding of confidentiality, integrity and availability of data by controlling physical access to the data, and as well as data access, input, disclosure, availability and separation. We have also set up procedures to ensure the rights of data subjects, the erasure of data and response reactions to possible data risks. We consider data protection during development, selection of hard- and software as well as the implementation of data protection by design and by default (Art. 25 GDPR).
4.2. The security measures include in particular the encrypted transfer of data between your browser and our server.
5. Disclosure and transmission of data
5.1. If, in the context of our processing, we disclose, transmit or otherwise grant access to data to other persons and companies (data processors or third parties), we only do so on the basis your consent, on the basis of a legal obligation, on the basis of a legal permission (e.g. transmission of data to a payment service provider, pursuant to Art. 6 (1) b GDPR) or on the basis of our legitimate interests (e.g. the use of agents, hosting providers, tax and legal advisers, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual, administrative and other duties).
5.2 In case we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
6. Transmission of data 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 this occurs through the use of third party services or through disclosure or transmission of data to third parties, we only do so to fulfill our (pre) contractual duties 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 data processed in a third country only in the presence of the special conditions of Art. 44 ff. GDPR. The data may be processed on the basis of specific guarantees, such as an officially confirmed suitable level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard data protection clauses”).
7. Rights of data subjects
7.1. You have the right to obtain a confirmation as to whether or not personal data concerning you are being processed and where that is the case, access to the personal data and further information in accordance with Art. 15 GDPR.
7.2. In accordance with Art. 16 GDPR you have the right to obtain the rectification of inaccurate personal data or the completion of incomplete personal data.
7.3. In accordance with Art. 17 GDPR you have the right to obtain the erasure of personal data concerning you without undue delay or alternatively you have the right to obtain restriction of processing in accordance with Art. 18 GDPR.
7.4. In accordance with Art. 20 GDPR you have the right to receive the personal data concerning you, which you have provided to us, and to transmit those data to another controller.
7.5.In accordance with Art. 77 GDPR you have the right to file a complaint with a supervisory authority.
8. Right to withdraw
You have the right to withdraw your consent at any time in accordance with Art. 7 (3) GDPR with effect for the future.
9. Right to object
You have the right to object to future processing of personal data at any time in accordance with Art. 21 GDPR. The objection may be lodged in particular against processing for direct marketing purposes.
10. Cookies and right to object to direct marketing
10.1. “Cookies” are small files that are stored on users’ devices. Various information can be stored in cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, also called “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or the login status are stored. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for performance measurement or marketing purposes. A third-party cookie is a cookie from an online service other than the one a user is visiting (cookies from the visited online service are called first-party cookies).
10.2. We use temporary and permanent cookies. If you do not want cookies to be stored on your device, we ask you to disable cookies in your browser’s system settings. Stored cookies can be deleted in the browser settings. Disabling cookies may lead to functional restrictions of our online offer.
11. Erasure of data
11.2. German law requires the storage of data for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual reports, trade letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (commercial books, records, management reports, accounting documents, commercial and business letters, documents relevant to taxation, etc.).
12. Order processing in the online shop and customer account
12.1. We process the data of our customers as part of the ordering process in our online shop to allow them to select and order the selected products and services, as well as their payment and delivery.
12.2. The processed data includes travel and tour information, contact information, contract data, payment data and data subjects of our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the context of an online shop with billing, delivery and customer service. Here we use session cookies for storing the shopping cart contents and permanent cookies for storing the login status.
12.3. Processing is based on Art. 6 (1) b (performance of a contract) and c (legal obligations) GDPR. The information marked as required for the performance and fulfillment of the contract is required. We disclose the data to third parties only in the context of delivery, payment or in the context of legal permissions or obligations to legal advisors and authorities. The data will be processed in third countries only if necessary for the fulfillment of the contract (e.g. on customer’s request upon delivery or payment).
12.4. Users can optionally create a user account, in particular to view their orders. As part of the registration, the necessary mandatory information will be communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their account, their data will be deleted with regard to the user account, subject to the provisions of commercial or tax law obligations in accordance with Art. 6 (1) c GDPR. Information in the user account remains until its deletion with subsequent archiving in case of a legal obligation. It is the responsibility of the users to secure their data before termination.
12.5. As part of the registration and login as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with Art. 6 (1) c GDPR.
12.6. The deletion takes place after legal warranty and comparable obligations have expired. The necessity of keeping the data is checked every three years. In the case of legal storage obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); Information in the user account remains until its deletion.
13. Business analysis and market research
13.1. In order to operate our business economically and to recognize market trends as well as customer and user wishes, we analyze the available data of business transactions, contracts, requests, etc. We process travel and tour information, contact information, contract data, payment data, usage data and metadata on the basis of Art. 6 (1) f GDPR. The data subjects include customers, prospects, business partners, visitors and users of our online offer. The analyzes are carried out for the purpose of business analysis, marketing and market research. In doing so, we can consider the profiles of the registered users with indications e.g. to their purchase history. The analyzes serve us to increase the user-friendliness, the optimization of our offer and our business. The analyzes are for us alone and will not be disclosed externally unless they are anonymous, aggregated analyzes.
13.2. If these analyzes or profiles contain personal data, they will be deleted or anonymised upon termination by the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analyzes and general trend provisions are created anonymously if possible.
14. Contact and customer service
14.1. When contacting us (via contact form or e-mail), the information provided by the user is processed in accordance with Art. 6 (1) b GDPR.
14.2. User information may be stored in our Customer Relationship Management System (“CRM System”) or similar system.
14.3. We delete the requests when they are no longer required and check the necessity every two years. Requests from customers who have a user account are stored permanently and we refer to the deletion of the user account. Furthermore, legal storing obligations apply.
15. Collection of access data and log files
15.1. Based on our legitimate interests within the meaning of Art. 6 (1) f. GDPR we store data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page or file, date and time of retrieval, amount of data transferred, status about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
15.2. Log file data is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of seven days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the deletion until final clarification of the incident.
16. Online presence in social media
16.1. Based on our legitimate interests within the meaning of Art. 6 (1) f GDPR we maintain online presences within social networks and platforms in order to communicate with active customers, prospects and users and to inform them about our services. When you visit the respective networks and platforms, the terms, conditions and privacy policies of the respective providers apply.
16.3. We use Google Analytics to display ads from Google and its affiliate marketing services only to those users who have shown an interest in our online offer or who have certain characteristics (e.g. interests in specific topics or products) that we submit to Google (so-called “remarketing” or “Google Analytics Audience”). With Remarketing Audiences, we also want to make sure that our ads are in line with the potential interest of users and not annoying.
17. Google Analytics
17.2. 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).
17.3. 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 this online offer and to provide us with further services related to the use of this online offer and the internet usage of affiliate services. In this case, pseudonymous usage profiles of the users can be created from the processed data.
17.4. We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within the 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 US and be shortened there.
17.5. 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 Google’s collection of the data generated by the cookie and their use of the online offer as well as the processing of this data by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout or opt out here: [gadwp_useroptout html_tag=”button”]Google Analytics Opt-out[/gadwp_useroptout].
17.6. For more information about Google’s data usage, settings and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“How Google uses information from sites or apps that use our services”), https://policies.google.com/technologies/ads (“Advertising”), https://adssettings.google.com/authenticated (“Make the ads you see more useful to you”).
18. Google Re/Marketing Services
18.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) f GDPR) we use the marketing and remarketing services (“Google Marketing Services “) provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (” Google “).
18.2. 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).
18.3. Google Marketing Services allow us to better target ads for and on our online offer, so that we only display ads to users that potentially match their interests. If a user is getting ads for products he has shown interest for on other websites, it is called remarketing. For these purposes, when you visit our online offer and other websites using Google Marketing Services, Google directly executes its own code and integrates so-called (re) marketing tags (invisible graphics or code, also known as “web beacons”) into the website. With their help individual cookies (instead of cookies, comparable technologies may also be used) are stored on your device. The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. The cookies contain information about which web pages the user visited, for what content the user is interested in and what offers the user has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer. The user IP address is also recorded, whereby in the context of Google Analytics we instruct Google to shorten the IP adress within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases to submit the full IP address to a Google server in the US and to shorten it there. The IP address will not be merged with other user data within other Google offers. Google may merge the information above with such information from other sources. When users then visits other websites, the websites may be displayed according to the user interests and the ads may be tailored to the user.
18.4. The user data are processed as pseudonyms in the context of Google Marketing Services. Google e.g. does not store and process the name or e-mail address of the users, but processes the relevant data related to cookies within pseudonymous user profiles. From the perspective of Google, the ads are not managed and displayed to a specific identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without pseudonymization. The user information collected through Google Marketing Services is transmitted to Google and stored on Google’s servers in the US.
18.5. The Google Marketing Services we use include the online advertising program “Google AdWords“. In the case of Google AdWords, each advertiser receives a different “conversion cookie”. Cookies can therefore not be tracked through other 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 that personally identifies users.
18.8. We may also use the service “Google Optimizer“. Google Optimizer allows us to understand how various changes to a website (such as changes to the input fields, the design, etc.) can take place in so-called “A/B testings”. Cookies are stored on users’ devices for these purposes. Only pseudonymous data of the users are processed.
18.9. In addition, we may use the “Google Tag Manager” to integrate and manage the Google Analytics and Marketing Services on our website.
18.11. If you wish to opt-out of interest-based advertising through Google Marketing Services, you can use Google’s ad settings and opt-out options: https://adssettings.google.com/authenticated.
19. Communication via mail, e-mail, or telephone
19.1 For business transactions and marketing purposes we use remote communication, such as mail, telephone or e-mail. We process travel and tour information, address and contact information as well as contract data of customers, participants, prospects and communication partners.
19.2 Processing is based on Art. 6 (1) a, Art. 7 GDPR, Art. 6 (1) f GDPR in connection with legal requirements for marketing communications. The contact takes place only with the consent of the contact partners or within the scope of legal permissions and the processed data are deleted as soon as they are not required and otherwise with objection, withdrawal or elimination of the permission basis or legal storing obligations.
20.1. With the following information we inform you about the contents of our newsletter as well as registration, distribution and statistical evaluation procedures as well as your right to object. By subscribing to our newsletter, you agree to the receipt and the procedures described here.
20.2. Newsletter contents: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Our newsletter contains travel and tour information, travel and tour reports as well as informations about products, offers, promotions and our company.
20.3. Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Changes to your data stored with the e-mail marketing service provider will also be logged.
20.5. Insofar as we use an e-mail marketing service provider, the provider may, according to its own information, use these data in pseudonymous form without assignment to a user, to optimize or improve its own services, e.g. for the technical optimization of the distribution and the presentation of the newsletters or for statistical purposes, to determine from which countries the recipients come. However, the provider does not use the data of our newsletter recipients to contact them on its own behalf or to pass them on to third parties.
20.6. Registration data: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give your name for personal address in the newsletter.
20.7. Performance measurement: The newsletters contain a so-called “web-beacon”, a pixel-sized file that is called from our server, or the server of our e-mail marketing service provider, when opening the newsletter. This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval. This information is used to improve the technical performance of services by evaluating technical data, the audience and their reading habits, their locations (which can be determined using the IP address) or access times. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor that of the e-mail marketing service provider to observe individual users. The evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
20.8. Newsletter distribution and performance measurement are made on the basis of a consent of the recipients in accordance with Art. 6 (1) a, Art. 7 GDPR in connection with § 7 (2) 3 UWG (German law against unfair competition) or on the basis of the legal permission according to § 7 (3) UWG.
20.9. The logging of the registration process is based on our legitimate interests within the meaning of Art. 6 (1) f GDPR and serves as proof of consent to receive the newsletter.
20.10. Newsletter recipients may terminate the receipt of our newsletter at any time, i.e. withdraw their consent. You will find a link to cancel your subscription at the end of each newsletter. At the same time, your consent to performance measurement expires. A separate withdrawal of the performance measurement is unfortunately not possible. In this case, the entire newsletter subscription must be terminated. By unsubscribing from the newsletter, the personal data will be deleted, unless their retention is legally required or justified, in which case their processing is limited only to these exceptional purposes. In particular, we may save the receiving e-mail addresses up to three years before deleting them based on our legitimate interests to provide evidence of prior consent. The processing of this data is limited to the purpose of a defense against possible claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of a consent is confirmed.
21. Integration of third party services and contents
21.1. Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) f GDPR) we make use of services and contents offered by third-party providers in order to integrate their services and contents, such as fonts, maps or videos (collectively referred to as “content”) in our online offer. This always presupposes that the third-party providers of this content perceive the user IP address, since they could not send the content to their browser without the IP address. The IP address is therefore required to display these contents. We endeavor to use only contents whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on your device and may include, but is not limited to, technical information about the browser and operating system, referring web sites, visit time, and other information regarding the use of our online offer and may be merged with further information from external sources.
21.2. With the following information we provide an overview of third-party providers and their contents, as well as links to their privacy policies, which contain further information on their data processing and, if available, revocation possibilities (so-called opt-out).
– If our customers use third party payment services (e.g. PayPal), the terms and conditions and the privacy policies of the respective third party service provider apply. These are available within the respective websites or applications.