Perlissima

- La Perla del Lago di Garda -

Privacy Policy

This privacy policy applies to the online service available at: www.stayperlissima.com

Status: April 10, 2025

Table of Contents

Controller

Michael Schmitz
Perronstraße 6a
83684 Tegernsee, Germany

Email: perlissima.apartment@gmail.com

Overview of Processing Activities

The following overview summarizes the types of data processed, the purposes of their processing, and refers to the affected individuals.

Types of Data Processed

  • Inventory data
  • Payment data
  • Location data
  • Contact data
  • Content data
  • Contract data
  • Usage data
  • Meta, communication, and procedural data
  • Log data

Categories of Data Subjects

  • Service recipients and clients
  • Interested parties
  • Communication partners
  • Users
  • Contest and competition participants
  • Business and contractual partners

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations
  • Communication
  • Security measures
  • Direct marketing
  • Reach measurement
  • Tracking
  • Office and organizational procedures
  • Audience building
  • Affiliate tracking
  • Organizational and administrative procedures
  • Conducting contests and competitions
  • Feedback
  • Marketing
  • User-related profiles
  • Provision of our online services and user-friendliness
  • IT infrastructure
  • Public relations
  • Sales promotion
  • Business processes and economic procedures

Relevant Legal Bases

Applicable legal bases under the GDPR: Below is an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence. If more specific legal bases are relevant in individual cases, we will inform you of them in the privacy policy.

  • Consent (Art. 6 (1) lit. a GDPR): The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 (1) lit. b GDPR): Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 (1) lit. c GDPR): Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) lit. f GDPR): Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

National data protection laws in Germany: In addition to the GDPR, national data protection laws apply in Germany, including the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains specific provisions on access rights, deletion rights, the right to object, the processing of special categories of personal data, and the transfer of data, including profiling and automated decision-making.

Note on applicability of GDPR and Swiss DPA: This privacy policy is intended to comply with both the Swiss Data Protection Act (DPA) and the EU GDPR. For clarity and broader applicability, we use GDPR terminology, such as "processing" of "personal data", even though different terms may be used under the Swiss DPA. The legal interpretation under the Swiss DPA remains valid where applicable.

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.

These measures include safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, access to input, transfer, ensuring availability, and separation. We have procedures in place to ensure the exercise of data subject rights, deletion of data, and response to data threats. Additionally, we take the protection of personal data into account already during the development or selection of hardware, software, and procedures, according to the principle of data protection by design and by default.

Transfer of Personal Data

In the course of processing personal data, it may happen that this data is transferred to other entities, companies, legally independent organizational units, or individuals, or disclosed to them. Recipients of this data may include IT service providers or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and enter into appropriate contracts or agreements to protect your data with the recipients of the data.

International Data Transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or disclosure or transfer of data to other individuals, entities, or companies (as indicated, for example, by the provider’s postal address or an explicit note in this privacy policy), such processing is only carried out in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized by the European Commission on July 10, 2023, as a secure legal framework. Additionally, we have signed Standard Contractual Clauses (SCCs) with the relevant providers, which are approved by the EU Commission and set contractual obligations for protecting your data.

This dual-layer approach ensures comprehensive protection of your data: The DPF serves as the primary safeguard, while the SCCs act as a fallback mechanism in case of any changes to the DPF. This way, we ensure your data remains properly protected even in the event of political or legal shifts.

For each service provider mentioned in this privacy policy, we indicate whether they are certified under the DPF and whether SCCs are in place. You can find more information about the DPF and a list of certified companies on the U.S. Department of Commerce’s website: https://www.dataprivacyframework.gov/.

For data transfers to other third countries, similar safeguards apply, including SCCs, explicit consents, or legal obligations. Information on transfers and applicable adequacy decisions can be found on the European Commission’s website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

Storage and Deletion of Data

We delete personal data we process in accordance with legal requirements as soon as the underlying consents are revoked or there are no further legal grounds for processing. This applies when the original purpose of processing no longer applies or the data is no longer needed. Exceptions include legal obligations or special interests that require longer retention or archiving of the data.

For example, data that must be retained for commercial or tax reasons, or that must be preserved for legal prosecution or protection of the rights of others, will be archived accordingly.

Our privacy notices contain additional information on data retention and deletion that applies to specific processing operations.

Where multiple retention periods are given for specific data, the longest period applies.

If no specific start date is defined and the retention period is at least one year, it begins at the end of the calendar year in which the event triggering the period occurred. For ongoing contractual relationships, the trigger is the termination or other end of the relationship.

Data retained not for the original purpose but due to legal obligations is processed solely for the reasons justifying retention.

Rights of Data Subjects

Under the GDPR, data subjects have the following rights:

  • Right to object: You have the right to object at any time to the processing of your personal data based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. If your data is processed for direct marketing, you have the right to object at any time to such processing.
  • Right to withdraw consent: You may withdraw your consent at any time.
  • Right of access: You have the right to obtain confirmation whether your personal data is being processed, and to request information and a copy of such data.
  • Right to rectification: You may request the correction or completion of inaccurate or incomplete data.
  • Right to erasure and restriction: You have the right to request deletion or restriction of processing of your data, in accordance with legal requirements.
  • Right to data portability: You may request to receive your data in a structured, commonly used, and machine-readable format or to have it transmitted to another controller.
  • Right to lodge a complaint: Without prejudice to any other administrative or judicial remedy, you may file a complaint with a supervisory authority if you believe that the processing of your personal data violates the GDPR.

Business Services

We process data of our contractual and business partners (e.g., customers and interested parties—collectively “contracting parties”) in the context of contractual or similar legal relationships, including related communication (or pre-contractual communication).

We use this data to fulfill our contractual obligations. This includes providing agreed services, updating data, resolving issues, and performing administrative tasks related to those services. We also rely on our legitimate interests, such as secure and efficient business operations, fraud prevention, and maintaining our rights.

Data is shared with third parties only when necessary to fulfill our obligations or legal requirements (e.g., banks, IT service providers, tax authorities).

We inform partners of which data is necessary—typically in forms, labels (e.g., asterisks), or direct communication.

Data is deleted after statutory warranty or retention periods, typically four years, unless legally required to be stored longer (e.g., 10 years for tax purposes).

  • Data types: Identification data, payment details, contact information, contract data, usage data, communication/meta data.
  • Data subjects: Customers, clients, business partners.
  • Purposes: Fulfilling contracts, security, communication, administration, business operations.
  • Legal basis: Contract fulfillment (Art. 6(1)(b) GDPR), legal obligations (Art. 6(1)(c)), legitimate interests (Art. 6(1)(f)).

Provision of Online Services and Web Hosting

We process users’ data to provide them with our online services. This includes processing users’ IP addresses, which is necessary to deliver content and features to their browser or device.

  • Data types: Usage data (e.g., page views, time spent, click paths), meta/communication data (e.g., IP addresses, timestamps), log data (e.g., server logs).
  • Data subjects: Users (e.g., website visitors, online service users).
  • Purposes: Providing our online offering, improving user experience, IT infrastructure operation, security measures.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Additional Information:

  • Server Log Files: Access to our site is logged in the form of server log files. These logs may include requested URLs, file names, access times, browser versions, IP addresses, referrer URLs, and providers. They are used for security purposes (e.g., DDoS prevention) and performance monitoring. Log files are stored for up to 30 days and then deleted or anonymized, unless needed for investigation.

Use of Cookies

We use cookies and similar technologies to store and read information on users’ devices. These are used for functional, security, and analysis purposes. Where required by law, we obtain consent before placing cookies. If not required, we rely on legitimate interests, such as ensuring functionality and security.

Legal basis: Consent (Art. 6(1)(a) GDPR) or Legitimate Interests (Art. 6(1)(f) GDPR).

Cookie Duration:

  • Session Cookies: Automatically deleted when the user leaves the site or closes the browser.
  • Persistent Cookies: Remain stored even after the browser is closed, e.g., to save login status or preferences. These may remain for up to two years unless otherwise specified.

Users can manage their cookie preferences via browser settings or opt-out links.

Blogs and Publications

We use blogs or similar platforms for online communication and publication. Data is only processed to the extent necessary for displaying content, enabling communication, or ensuring security.

  • Data types: User data (e.g., names, contact info), content data (e.g., comments), usage data, communication/meta data.
  • Data subjects: Users (e.g., readers, commenters).
  • Purposes: Feedback, providing content, communication, security, internal administration.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Additional Information:

  • Comments: Users who post comments may have their IP address stored for security reasons (e.g., to prevent abuse or spam). We may also use cookies to prevent multiple votes or spam entries. Data from comments is stored until users request deletion.

Contact and Request Management

When users contact us (e.g., via post, contact form, email, phone, or social media), we process their data to respond to inquiries and requested actions. This also applies to ongoing business relationships.

  • Data types: Personal information (e.g., name, address, email), content data (e.g., messages), usage data (e.g., interaction history), metadata (e.g., IP address, time).
  • Data subjects: Communication partners.
  • Purposes: Communication, internal organization, user service, website functionality.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR), Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Additional Information:

  • Contact Form: When contacting us via form or email, the submitted data is used exclusively for handling the request and any necessary follow-up communication.

Newsletter and Electronic Notifications

We send newsletters and similar notifications only with the recipients’ consent or legal permission. These emails may contain updates about us, our services, promotions, or offers.

  • Data types: Contact data (e.g., email address), usage data (e.g., open rates, clicks), metadata (e.g., IP address, time).
  • Data subjects: Communication partners.
  • Purposes: Direct marketing.
  • Legal basis: Consent (Art. 6(1)(a) GDPR).

Unsubscribe: Users can unsubscribe at any time via a link in the newsletter or by contacting us directly.

Additional Information:

  • Tracking Open and Click Rates: Newsletters may contain tracking pixels that collect info about open and click behavior. This is used to optimize our content and offers.
  • Retention: Unsubscribed email addresses may be stored for up to 3 years for proof of prior consent. You can request deletion at any time.

Advertising Communication via Email, Post, Fax or Telephone

We process personal data for advertising communication across various channels in compliance with legal regulations. Users can withdraw their consent or object at any time.

  • Data types: Contact data (e.g., email, phone, address), communication content.
  • Data subjects: Communication partners.
  • Purposes: Direct marketing, promotions, customer engagement.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Retention: Contact data may be stored for up to 3 years after a withdrawal or objection for legal proof. A separate blocklist may also be used to prevent further contact.

Contests and Competitions

We process participants' personal data only as far as necessary for the provision, implementation, and handling of contests or competitions, or if participants have given consent, or the processing is in our legitimate interest (e.g., to prevent abuse).

If contest entries are published (e.g., as part of a vote or winner presentation), participant names may be made public. Participants can object at any time.

If the contest takes place on a platform (e.g., Instagram), their terms and privacy policies apply in addition to ours.

  • Data types: Personal details (name, address, contact), content data (e.g., uploaded photos, messages).
  • Data subjects: Contest participants.
  • Purposes: Organizing and conducting contests and competitions.
  • Legal basis: Contract performance (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Retention: Data will be deleted within 6 months after the contest ends, unless legally required or needed for follow-ups (e.g., warranties).

Web Analytics, Monitoring and Optimization

We use web analytics to understand visitor flows, interests, and user behavior. This may include demographic data (age, gender) and geographic location (if permitted). We may also use testing methods to improve our services.

We employ pseudonymous profiles that don’t include names or identifiable details. IP addresses are anonymized using IP masking techniques.

  • Data types: Usage data (page visits, clicks), technical metadata (IP address, browser, OS).
  • Data subjects: Users.
  • Purposes: Reach measurement, audience analysis, improving services.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Tool Example: Google Analytics — anonymized IPs, pseudonymous profiles, cookies up to 2 years.

Opt-out: Users can disable analytics tracking via browser settings or opt-out plugins.

Online Marketing

We process personal data for online marketing purposes, such as displaying personalized ads or tracking the success of marketing campaigns (conversion tracking).

This may involve creating pseudonymous user profiles based on visited pages, actions, used devices, or general interests. Cookies and similar technologies are used to store and evaluate this data.

  • Data types: Usage data, metadata (IP address, device type), location (if agreed).
  • Data subjects: Website users and interested parties.
  • Purposes: Advertising, profiling, campaign analysis, audience targeting.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Retention: Cookies may be stored for up to 2 years.

Opt-out options: Browser settings or services like:

Affiliate Programs and Affiliate Links

We integrate affiliate links and other references (e.g., search masks, widgets, discount codes) to third-party offers. If users follow these links and take up the offer, we may receive a commission ("affiliate commission").

To track whether users have followed an affiliate link and made a purchase or similar action, third-party providers need to know that the user clicked the affiliate link. This assignment is solely for billing and is removed once no longer necessary.

  • Data types: Contract data (e.g., product info, partner ID); usage data (e.g., clicks, page visits); metadata (e.g., IP address, timestamps).
  • Data subjects: Interested users and visitors.
  • Purposes: Affiliate tracking and commission billing.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Customer Reviews and Rating Systems

We participate in customer review and rating platforms to evaluate, improve, and promote our services. Reviews usually require registration with the platform provider. If needed, we transmit data (e.g., name, email, order number) to verify authenticity.

  • Data types: Contract data, usage data, metadata.
  • Data subjects: Clients and website users.
  • Purposes: Gathering feedback, reputation management, marketing.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Social Media Presences

We maintain online presences within social networks to communicate with users and provide information. User data may be processed outside the EU, which may limit enforcement of user rights.

Social networks may use user data for market research and advertising, including profiling and cross-device tracking using cookies. We recommend reviewing the privacy policies of the respective platforms.

  • Data types: Contact data, content data, usage data.
  • Data subjects: Users and followers on social media.
  • Purposes: Communication, public relations, user interaction.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Example: Instagram, operated by Meta Platforms Ireland Ltd. – Privacy Policy

Plugins and Embedded Functions and Content

We integrate functional and content elements into our website that are obtained from third-party servers (e.g., graphics, videos, maps). For this to work, third parties must process user IP addresses. We aim to use only those providers who process IP addresses solely to deliver the content.

These third parties may also use "pixel tags" (invisible graphics or "web beacons") for statistical or marketing purposes. Information such as visitor traffic can be analyzed. This information may be stored in cookies on user devices and combined with other data.

  • Data types: Usage data (e.g., page visits, interactions); metadata (e.g., IP address, time, user ID); location data (e.g., geographic coordinates).
  • Data subjects: Users of our online services.
  • Purposes: Providing online content; usability; marketing; tracking; audience targeting.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Google Fonts (served by Google)

We use Google Fonts for efficient and up-to-date font integration. When accessing our website, the user's browser sends HTTP requests to the Google Fonts Web API to load fonts and style sheets. No personal IPs are stored according to Google. Only technical data such as language settings and browser information are logged.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Privacy Policy: https://policies.google.com/privacy
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR)
More info: Google Fonts FAQ

Google Maps

We integrate maps using the Google Maps service to help users locate us easily. This includes IP address processing and may include location data if permitted by the user. Data may be transferred to the USA.

Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland
Privacy Policy: https://policies.google.com/privacy
Legal basis: Consent (Art. 6(1)(a) GDPR)

YouTube Videos

We embed videos via the YouTube platform. When visiting pages that contain a YouTube video, data such as the IP address, device details, and usage behavior are transmitted to Google. Google may use this information for profiling and personalized advertising.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Privacy Policy: https://policies.google.com/privacy
Legal basis: Consent (Art. 6(1)(a) GDPR)

Web Analytics, Monitoring and Optimization

We use web analytics to analyze visitor behavior, interests, and demographics. This allows us to understand which content is most popular, optimize our website, and tailor content to users' needs.

User profiles may be created, stored in cookies, and processed pseudonymously. IP addresses are shortened (IP masking) to protect user identity.

  • Data types: Usage data (e.g., visited pages, click paths, interaction duration), metadata (e.g., IP address, timestamps).
  • Data subjects: Users of our website and online services.
  • Purposes: Reach measurement, user experience optimization, creation of pseudonymous user profiles.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Google Analytics

We use Google Analytics to analyze website usage based on pseudonymous user IDs. Google anonymizes IPs of EU users and stores aggregated geographic data. Data may be stored in cookies and processed across sessions and devices.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Privacy Policy: https://policies.google.com/privacy
Opt-Out: Google Opt-Out Add-on
Legal basis: Consent (Art. 6(1)(a) GDPR)
Data Transfer: Based on EU-US Data Privacy Framework (DPF) and Standard Contractual Clauses.

Online Marketing

We use online marketing tools to show interest-based advertising and measure the success of campaigns. For this purpose, pseudonymous user profiles are created using cookies or similar tracking technologies.

Information may include visited pages, interactions, device and browser data, and usage times. IP addresses are masked. Data is often processed across multiple platforms and websites.

  • Data types: Usage data, metadata, profile data.
  • Data subjects: Website users.
  • Purposes: Marketing, remarketing, conversion tracking, audience targeting.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Opt-Out Resources:
• Europe: youronlinechoices.eu
• Canada: youradchoices.ca
• USA: aboutads.info
• Global: optout.aboutads.info

Affiliate Programs and Affiliate Links

We participate in affiliate programs and include affiliate links to partner websites. When you click on these links and perform an action (e.g., purchase), we may receive a commission.

Tracking is done through cookies or URL parameters. Only pseudonymous data is processed for commission tracking. No personal data is shared with affiliate partners unless explicitly stated.

  • Data types: Usage data, metadata (e.g., time of click, referrer page, device info).
  • Data subjects: Users who click affiliate links.
  • Purpose: Commission tracking for affiliate marketing.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Customer Reviews and Evaluation Procedures

We participate in review and evaluation procedures to assess, optimize, and promote our services. When users rate us via participating review platforms or procedures or otherwise provide feedback, the general terms and conditions and data protection information of the respective providers apply. As a rule, a rating also requires registration with the respective providers.

To ensure that the reviewing individuals have actually used our services, we transmit, with the customers’ consent, the necessary information regarding the customer and the service used to the respective review platform (including name, email address, and order or item number). These details are used solely for verification purposes.

  • Data Types Processed: Contract data; usage data; meta, communication, and procedural data.
  • Data Subjects: Customers and contracting parties; users.
  • Purposes: Feedback; marketing.
  • Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR).

Social Media Presence

We maintain online presences on social networks and process user data within these platforms to communicate with active users or provide information about us.

Please note that user data may be processed outside the European Union, which may pose risks (e.g., difficulties in enforcing user rights).

Generally, social networks process user data for market research and advertising. Usage profiles can be created from usage behavior and related interests. These profiles can be used to place advertisements both within and outside the platforms. Cookies are generally stored on users’ devices for this purpose. Additionally, data may also be stored in the profiles, regardless of the device used (especially if users are members and logged into the respective platforms).

For more details, refer to the privacy policies of the respective platforms.

  • Data Types Processed: Contact data; content data; usage data.
  • Data Subjects: Users.
  • Purposes: Communication; feedback; public relations.
  • Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further Information:

Plugins and Embedded Content

We incorporate function and content elements into our online offering that are obtained from the servers of their respective providers (referred to as "third-party providers"). These may include graphics, videos, or maps (collectively "content").

For such integration, it is necessary that the third-party providers process users' IP addresses, as they cannot display the content in users' browsers without this. The IP address is thus required for displaying such content. We strive to use only content whose providers use the IP address solely for content delivery.

Third-party providers may also use pixel tags ("web beacons") for statistical or marketing purposes. These can be used to analyze visitor traffic on the pages of this website. The pseudonymous information can be stored in cookies on users' devices and include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offering. This information may also be linked with data from other sources.

  • Data Types Processed: Usage data; meta, communication, and procedural data; location data.
  • Data Subjects: Users.
  • Purposes: Online service provision and usability; reach measurement; tracking; audience targeting; marketing.
  • Legal Bases: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Examples:

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