June, 2021

Privacy policy

Privacy Notice

1. Introduction

We would like to use the information below to provide you “data subject” with an overview of our processing of your personal data and your rights under data protection law. It is generally possible to use our website without entering personal data. However, if you wish to make use of special services offered by our company through our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we will generally obtain your consent.

Personal data, such as your name, address or email address, is always processed in accordance with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the “The Travel Consulting Group GmbH”. The aim of this Privacy Notice is to inform you about the scope and purpose of the personal data we collect, use and process.

As the data controller, we have implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps so that absolute protection cannot be guaranteed. For this reason, you are free to submit personal data on alternative ways, such as by phone or by post to us.

2. Data controller

The data controller, as defined by the GDPR, is:

The Travel Consulting Group GmbH

Gervinusstraße 5-7
60322 Frankfurt am Main

3. Data protection officer

You can reach the data protection officer as follows:

Jürgen Büchy
Prof. Dr. Adrian Freiherr von Dörnberg
Thomas Drexler
Gunther Holzschuh
Wolfgang John

The Travel Consulting Group GmbH
Gervinusstraße 5-7
60322 Frankfurt am Main

+49 (0)69 – 17326905
info@the-tcg.com

You may contact our data protection officer directly at any time if you have any questions or suggestions regarding data protection.

4. Definitions

This Privacy Notice is based on the terminology used by the European legislature and legislature in the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand, both for the public and for our customers and business partners. To ensure this, we would like to explain in advance the terminology used. Among other things, we use the following terms in this privacy policy.

We use the following terms in this Privacy Notice, among others:

  1. Personal data
    Personal data means any information relating to an identified or identifiable natural person. 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.
  2. Data subject
    A data subject is any identified or identifiable natural person whose personal data is processed by the data controller (our company).
  3. Processing
    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, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  4. Restriction to processing
    Restriction to processing means marking stored personal data with the aim of limiting its processing in future.
  5. Profiling
    Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  6. Pseudonymisation
    Pseudonymisation is the processing of personal data in such a way that the data can no longer be assigned to a specific data subject without additional information being provided, given that such additional information is kept separate and subject to appropriate technical and organisational measures that ensure that personal data cannot be attributed to an identified or identifiable natural person.
  7. Data processor
    The processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  8. Recipient
    Recipient means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
  9. Third parties
    Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
  10. Consent
    Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

5. Legal basis for processing

Article 6 Paragraph 1(a) GDPR serves as our company’s legal basis for processing operations in which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, processing is based on Article 6 Paragraph 1(b) GDPR. The same applies to those processing operations required to carry out pre-contractual measures, such as in cases of queries regarding our products or services.

If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfilment of tax obligations, processing is based on Article 6 Paragraph 1(c) GDPR.

In rare cases, processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if someone visiting our business were to be injured and their name, age, health insurance data or other vital information needed to be disclosed to a doctor, hospital or other third party. Processing would then be based on Article 6 Paragraph 1(d) GDPR.

Finally, processing operations could be based on Article 6 Paragraph 1(f) GDPR. Processing operations not based on any of the above-mentioned legal bases may be carried out on the basis of Article 6 Paragraph 1(f) GDPR if processing is necessary to safeguard the legitimate interests of our company or those of a third party, provided the interests and fundamental rights and freedoms of the data subject do not take precedence. We are permitted to engage in such processing operations in particular because they have been specifically mentioned in European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47 Sentence 2 GDPR).

6. Technology

6.1 SSL/TLS encryption

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login details or contact requests that you send to us as the website operator. You can recognise an encrypted connection by your browser’s address bar reading “https://” instead of “http://” and the lock symbol in the browser bar.

We use this technology to protect your transmitted data.

6.2 Data collection when visiting the website

If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (in what is known as “server log files”). Our website collects a range of general data and information each time you access a website or an automated system. This general data and information is stored in the server’s log files. It may be collected.

  1. the browser types and versions used,
  2. the operating system used by the accessing system,
  3. the website from which an accessing system accesses our website (called a referrer),
  4. the sub-pages accessed via an accessing system on our website,
  5. the date and time the website is accessed,
  6. an internet protocol address (IP address) and
  7. the accessing system’s internet service provider.

No conclusions are drawn about you when using this general data and information. Instead, this information is needed to

  1. properly deliver our website content,
  2. to optimise the content of the website as well as to advertise it,
  3. to ensure the continued functioning of our information technology systems and our website’s technology as well as to
  4. provide the information necessary for law enforcement authorities to prosecute in the event of a cyber-attack.

This collected data and information is therefore statistically analysed and further analysed by us with the aim of increasing data protection and data security within our company to ultimately ensure an optimum level of protection for the personal data being processed by us. The data from the server log files is stored separately from all personal data provided by a data subject.

The legal basis for data processing is Article 6 Paragraph 1 Sentence 1(f) GDPR. Our legitimate interest is based on the purposes listed above for the collection of data.

6.3 Data collection when visiting the website

If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (in what is known as “server log files”). Our website collects a range of general data and information each time you access a website or an automated system. This general data and information is stored in the server’s log files. It may be colltected

  1. the types and versions used,
  2. the operating system used by the accessing system,
  3. the website from which an accessing system accesses our website (called a referrer),
  4. the sub-pages accessed via an accessing system on our website,
  5. the date and time the website is accessed,
  6. a truncated internet protocol address (anonymised IP address) and
  7. the accessing system’s internet service provider.

No conclusions are drawn about you when using this general data and information. Instead, this information is needed

  1. to properly deliver our website content,
  2. to optimise the content of our website as well as to advertise it,
  3. to ensure the continued functioning of our IT systems and our website’s technology
  4. as well as to provide the information necessary for law enforcement authorities to prosecute in the event of a cyber attack.

This collected data and information is therefore statistically analysed and further analysed by us with the aim of increasing data protection and data security within our company to ultimately ensure an optimum level of protection for the personal data being processed by us. The anonymous data from the server log files is stored separately from all personal data provided by a data subject.

The legal basis for data processing is Article 6 Paragraph 1 Sentence 1(f) GDPR. Our legitimate interest is based on the purposes listed above for the collection of data.

6.4 Encrypted payment transactions

If, after concluding a paid contract, you need to provide us with your payment details (e.g. account number for direct debit authorisation), this data is required for payment processing.

Payment transactions via the usual means of payment (Visa/MasterCard, direct debit) are carried out exclusively via an encrypted SSL or TLS connection. You can recognise an encrypted connection by your browser’s address bar reading “https://” instead of “http://” and the lock symbol in the browser bar.

We use this technology to protect your transmitted data.

7. Cookies

7.1 General information about cookies

We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our website.

Information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity.

The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are erased automatically when you leave our website.

We also use temporary cookies to optimise user-friendliness. These cookies are stored on your device for a specific period of time. If you return to our website to use our services, cookies allow us to automatically recognise that you have visited our website previously and remember the inputs and settings you have made so that you do not have to enter them again.

We also use cookies to statistically record the use of our website and analyse it for the purpose of optimising our services. These cookies allow us to automatically recognise that you have already visited our website when you visit our website again. These cookies are automatically erased after a defined period of time.

7.2 Legal basis for the use of cookies

The data processed by cookies, which are required for the proper functioning of the website, are to safeguard our legitimate interests pursuant to Article 6 Paragraph 1 Sentence 1(f) GDPR.

For all other cookies you have given your consent to this through our opt-in cookie banner in accordance with Article 6 Paragraph 1(a) GDPR.

7.3 Cookie consent with Borlabs Cookie

Our website uses the cookie consent technology of Borlabs Cookie to obtain your consent to the storage of certain cookies in your browser and to document this in accordance with data protection law. The provider of this technology is Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg (hereinafter "Borlabs").

When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not shared with the Borlabs cookie provider.

The collected data will be stored until you request us to delete it or until you delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

Borlabs Cookie Consent Technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 p. 1 lit. c DSGVO.

 

8. Web analytics

8.1 Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited (https://www.google.com/about/) (Gordon House, Barrow Street, Dublin 4, Ireland; hereinafter referred to as “Google”), on our website. As part of this, pseudonymised user profiles are created and cookies (see the section on “Cookies”) are used. The information generated by the cookie about your use of this website, such as your browser

  1. browser type/version
  2. operating system
  3. referrer URL (website previously visited), host
  4. name of the accessing computer (IP address) and
  5. time of server request,

is transmitted to a Google server in the US and stored there. This information is used to evaluate your use of this website, to compile reports on the website activities, and to perform further services linked to website and internet use for market research purposes and to tailor the design of this website. This information may also be sent to third parties if this is legally required or if third parties process this data on behalf of Google. Under no circumstances will your IP address be associated with any other data. IP addresses are anonymised so that it is not possible to assign them to individuals (known as IP masking).

You may refuse the use of cookies by selecting the appropriate settings on your browser; however, we would point out that this may result in you not being able to use all the features of this website.

These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR.

You can also prevent the data generated by the cookie about your use of the website (including your IP address) from being sent to and processed by Google by downloading and installing the available browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from capturing data by clicking on the following link: Deactivate Google Analytics. This sets an opt-out cookie that prevents the future collection of your data when visiting this website. The opt-out cookie is only valid on this browser and only for our website and is stored on your device. If you erase the cookies stored for this browser, you will need to reset the opt-out cookie.

Additional information on data protection with respect to Google Analytics is available on the Google Analytics website in the help section (https://support.google.com/analytics/answer/6004245?hl=en).

8.2 Google Analytics Remarketing

We have integrated services by Google Remarketing on this website. Google Remarketing is a Google Ads feature that enables a company to display advertisements to internet users who have previously visited the company’s website. Integrating Google Remarketing therefore allows a company to create user-based advertisements and consequently to display advertisements of interest to that particular internet user.

Google Remarketing services are operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of Google Remarketing is to display advertisements that are relevant to your interests. Google Remarketing allows us to display advertisements that are tailored to the individual needs and interests of internet users through the Google advertising network or on other websites.

Google Remarketing places a cookie on your IT system. Setting cookies enables Google to recognise visitors to our website who subsequently visit websites that are also members of the Google advertising network. Every time you visit a website that has integrated Google Remarketing services, your browser automatically identifies itself to Google. As part of this technical process, Google obtains knowledge of personal data, such as your IP address or browsing behaviour, which Google uses, among other things, to display advertisements relevant to your interests.

Cookies are used to store personal information, such as the websites you visit. Each time you visit our website, this personal data, including your IP address, is transferred to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose personal data collected through this technical process to third parties.

As stated above, you can prevent cookies being placed by our website at any time by adjusting your web browser’s settings to permanently refuse cookies. Adjusting the browser’s settings in this way would also prevent Google from placing a cookie on your IT system. In addition, a cookie already placed by Google Analytics can be deleted at any time through a web browser or other software programs.

You also have the option to object to Google’s interest-based advertising. To do this, you must visit www.google.com/settings/ads from each of the web browsers you use and adjust the settings there as desired.

These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR.

Additional information and Google’s privacy policy can be found at https://www.google.com/policies/privacy/.

 

9. Plugins and other services

9.1 Google Maps

We use Google Maps (API) on our website, provided through Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Maps is a web service for displaying interactive maps to visually display geographic information. For example, by using this service, you can view our location and make it easier for you to reach us.

When you access sub-pages in which a Google Maps map is integrated, information about your use of our website (such as your IP address) is transferred to Google’s servers in the US and stored there. This occurs regardless of whether Google provides a user account that you are logged in to or whether you have no user account with them at all. When you are logged in to Google, your information will be directly associated with your account. If you do not want your profile associated with Google, you will need to log out of your Google account. Google stores your data (even for users who are not logged in) as usage profiles and analysis it. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.

If you do not agree with the future transmission of your data to Google as part of your use of Google Maps, you have the option of completely deactivating the Google Maps web service by switching off the JavaScript application in your browser. You will then be unable to use Google Maps and therefore the map displayed on this website.

These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR.

The Google terms of use can be found at https://www.google.com/policies/terms/regional.html, and the additional Google Maps terms of use can be found at https://www.google.com/help/terms_maps/.

Detailed information on data protection with respect to the use of Google Maps is available on Google’s website (“Google Privacy Policy”): https://www.google.com/policies/privacy.

9.2 Google reCAPTCHA

This website also uses the reCAPTCHA feature provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). This feature is primarily used to differentiate whether an entry is made by a natural person or whether the function is being misused through mechanical and automated processing. Use of the service also involves sending the IP address and any other data required by Google for the reCAPTCHA service to Google. These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR.

Further information about Google reCAPTCHA and Google’s privacy policy can be found at: https://www.google.com/policies/privacy/.

9.3 Google Tag Manager

This website uses Google Tag Manager, a cookie-free domain that does not collect personally identifiable information.

With this tool, “website tags” (i.e. keywords that are integrated into HTML elements) can be implemented and managed via an interface. By using the Google Tag Manager, we can automatically track which button, link or customised image you have actively clicked and then record which content on our website is of particular interest to you.

The tool also triggers other tags that may themselves collect data. Google Tag Manager does not access this data. If you have disabled it at the domain or cookie level, it will remain in place for all tracking tags implemented with Google Tag Manager.

These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR.

9.4 Google WebFonts

Our website uses web fonts provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for the uniform display of fonts. When you access a website, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.

To do this, the browser you are using must connect to Google’s servers. This gives Google information that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and appealing presentation of our website.

These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR.

More information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.

10. Your rights as a data subject

10.1 Right to confirmation

You have the right to request confirmation from us as to whether personal data relating to you will be processed.

10.2 Right to information (Article 15 GDPR)

You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us, in accordance with the statutory provisions.

10.3 Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

10.4 Erasure (Article 17 GDPR)

You have the right to demand that we erase the personal data relating to you be deleted without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required.

10.5 Restriction to processing (Article 18 GDPR)

You have the right to request that we restrict the processing of your data if one of the legal requirements is met.

10.6 Data transferability (Article 20 GDPR)

You have the right obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 Paragraph 1(a) GDPR or Article 9 Paragraph 2(a) GDPR or on a contract pursuant to Article 6 Paragraph 1(b) GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us.

Furthermore, when exercising your right to data transferability pursuant to Article 20 Paragraph 1 GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.

10.7 Objection (Article 21 GDPR)

You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1(e) (data processing in the public interest) or (f) (data processing on the basis of the weighing of legitimate interests) GDPR.

This also applies to profiling based on these provisions pursuant to Article 4 Number 4 GDPR.

Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims.

In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose.

In addition, you have the right to object to our processing of your personal data for scientific or historical research purposes or for statistical purposes pursuant to Article 89 Paragraph 1 GDPR for reasons arising from your particular situation, unless such processing is necessary for the performance of a task in the public interest.

You are free to exercise your right to lodge an objection in relation to the use of information society services, Directive 2002/58/EC notwithstanding, by means of automated procedures using technical specifications.

10.8 Revocation of consent regarding data protection

You have the right to revoke any consent to the processing of personal data at any time with future effect.

10.9 Lodging a complaint with a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

11. Routine storage, erasure and blocking of personal data

We process and store your personal data only for the period of time necessary to meet the storage purpose or as required by the legal provisions to which our company is subject.

If the storage purpose no longer applies or if a required retention period expires, personal data will be routinely blocked or erased in accordance with the statutory provisions.

12. Duration of storage of personal data

The criterion for the duration of the retention of personal data is the respective legal retention period. Once this period expires, the data in question will be routinely erased, provided it is no longer required for the fulfilment or initiation of the contract.

13. Version and amendments to the Privacy Notice

This Privacy Notice is currently valid and was last updated on November 2021.

It may be necessary for us to amend this Privacy Notice in the process of further developing our website and the services we offer through our website or due to changes in legal or regulatory requirements. You can view and print our current Privacy Notice on the website at any time by visiting “https://www.the-tcg.com/en/privacy-policy/”.

© The Travel Consulting Group GmbH. All rights reserved.