Privacy Policy
Welcome to Tourism99 and our website at www.tourism99.com (our “website”). We want you to feel comfortable on our website and not have to worry about the security of your data. That is why data protection is an important part of our philosophy.
In this Privacy Policy you will find all the information about which Personal Data we collect and process and for what purpose. Equally we will also inform you of your data protection rights and how you can assert them.
GENERAL PRINCIPLES
What is Personal Data?
Personal Data is any information relating to an identified or identifiable natural person. This includes for example name or address data telephone number mobile number or online identifiers such as your device ID and your IP address.
What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party for data processing is LD-Classic-Center GmbH Dimpfelstr. 11 04347 Leipzig Germany (“Tourism99” “we” “us” “our”). If you have any questions or if you wish to exercise your rights please contact us by email using info@tourism99.com or write to us at the above address.
What law applies?
Our use of your Personal Data is subject to Germany`s Data Protection Act (Bundesdatenschutzgesetz) (“BDSG”) and the EU's General Data Protection Regulation (“GDPR”) and of course we process your Personal Data accordingly.
What are the Legal Bases for processing Personal Data?
In accordance with the BDSG and the GDPR we have to have at least one of the following legal bases to process your Personal Data:
- You have given your consent
- The data is necessary for the fulfillment of a contract / pre-contractual measures
- The data is necessary for the fulfillment of a legal obligation
- The data is necessary to protect our legitimate interests provided that your interests are not overridden
Who is the competent data protection authority?
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The State Commissioner for Data Protection of Saxony (LFD) is the state Data Protection Authority for the state of Saxony. You do however also have the right to lodge a complaint directly with the LFD their contact details can be found on their website (www.datenschutz.sachsen.de).
How long will you keep my data?
We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with Germany`s Commercial and Fiscal Rules and Regulations). Depending on the document and legal regulation the retention and documentation periods specified therein are five years (HGB) six years (A0) or ten years (HGB). Once the purpose has been achieved or the retention period has expired the corresponding data is routinely deleted.
WHAT PERSONAL DATA DO WE PROCESS?
Technical Data
When you access our website some access data is recorded automatically and stored in a log file on our website's server. This means if you browse and simply have a look at our website we process:
- The IP address of your device
- The date and time of your access
- The name and URL of the accessed file
- The browser used
- The amount of bytes transferred
- The status of the page request
- The session ID
- The referrer URL
The legal basis for processing is our legitimate interest.
Hosting of our website
We use the hosting services of 1&1 IONOS SE (Elgendorfer Str. 57 56410 Montabaur Germany) for the purpose of hosting and displaying our website. IONOS does so on the basis of processing on our behalf and that also means that all data collected on our website is processed on IONOS' servers. The basis for processing is our legitimate interest and the initiation and/or fulfillment of a contract.
Content Management System
We use the open source Content Management System (CMS) of WordPress.org to publish and maintain the created and edited Content and texts on our website. This means that all content and texts submitted to us by users for publication is transferred to our IONOS server. In addition to texts this also includes for example your data in our forms. The legal basis for this processing is our legitimate interest.
WooCommerce
To provide our ecommerce system we use the WooCommerce service developed and operated by Automattic Inc (60 29th Street Suite 343 San Francisco CA 94107 United States). Both your inventory data and your usage data are stored on WooCommerce's servers. The legal basis for processing is our legitimate interest.
Fonts
We use Google Fonts by Google LLC (1600 Amphitheatre Parkway Mountain View CA 94043 US and Google Ireland Limited Gordon House Barrow Street Dublin 4 Ireland) and Font Awesome of Fonticons Inc (307 S Main St Ste 202 Bentonville AR 72712-9214 United States) on our website to display external fonts. To enable the display of certain fonts on our website a connection to a Google/Font Awesome server is established when our website is accessed. The connection to Google/Font Awesome established when you call up our website enables Google/Font Awesome to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.
Google Maps
Our website uses Google Maps API to visually display geographical information. When using Google Maps Google LLC also collects processes and uses data about visitors' use of the map functions (You can find more information about data processing by Google in the Google privacy policy). The integration of Google Maps represents a legitimate interest.
Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. For further information on the cookies we use please refer to our Cookie Policy. The legal basis for the use of Cookies is depending on the specific cookie used our legitimate interest and/or your consent.
Cookie consent
Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website the following Personal Data is transferred to us:
- Your consent(s) or revocation of your consent(s)
- Your IP address
- Information about your browser
- Information about your device
- Time of your visit to our website
The basis for processing is our legitimate interest and your consent.
Links to other websites
Please note that if you use a link from our website to a third-party website that third-party may also set new cookies that are not covered by this or our cookie Notice. In such cases we recommend that you read the cookie Notice on the third-party website itself.
Economic analyses and market research
For business reasons we analyze the data we have on web and server traffic patterns website interactions browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics please refer to our Cookie Policy.
Contacting us
You can contact us in various ways and data is always collected in the process. You provide us with most of the data that we process when you contact us such as your name and email address. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted again provided that there is no legal obligation to retain it.
We also offer to contact us via the messaging services of WhatsApp (Meta Platforms Inc 1601 Willow Road Menlo Park CA 94025 and 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland). If you contact us via WhatsApp we store and use the mobile phone number you use and - if provided - your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request. The legal basis is both your consent and contract.
Data management and customer support
For optimal data management and customer support we store the data related to your contract with us in our customer relationship management system (“CRM”) Pipedrive provided by Pipedrive Inc (460 Park Ave South New York New York NY 10016 US and Mustamäe tee 3a 10615 Tallinn Estonia). This data processing is based on our legitimate interest in providing our customer service.
Registration of a user account
On our website we offer users the opportunity to register an account. The data is entered into our registration form and transmitted to us and stored. The data is not passed on to third parties. The following data is collected as part of the registration process:
- First name/ last name
- Email address
- Password
- Username
- The IP address of the user
- Date and time of registration
The legal basis for processing is consent and the fulfillment of a contract. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. As a user you have the option at any time to delete your registration with us. You can change your data stored with us at any time independently and / or delete or have deleted. If the data is necessary for the fulfillment of a contract or for the execution of pre-contractual measures an early deletion of the data is only possible as far as contractual or legal obligations do not oppose a deletion.
Use of our listing services
If you wish to use our listing services and its features we process the Personal Data you voluntarily provide for the purpose of providing our listing services. Depending on how you use our listing services you may provide images contact information company information location data etc. and upload content such as text photographs etc. This content will be made public and may be viewed and otherwise accessed by others. Some of the Personal Data you provide may be considered “special” or “sensitive”. By choosing to provide this data you consent to our processing of that data. You have choices about the data you provide and how you share it. It’s your choice whether to include Personal Data and to make that information available to us. Please do not share information that you would not want to be available. The legal basis for processing of your Personal Data and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent.
Information that we share on your behalf with others
You may share information with other users and on your behalf when you voluntarily disclose information on the service (including your profile and listing). The information shared publicly depends on your use of our services and typically includes your location and username. Please be careful with your information and make sure that you are comfortable with the details you share. As a safety measure we will never disclose your email address or full name and instead facilitate among an internal chat system a specific email form which does not display your email address. The legal basis for the data processing is the fulfillment of our contractual obligations and in individual cases the fulfillment of our legal obligations as well as your consent.
Payment Data
If you make a purchase your payment will be processed via our payment service providers WooPayments (Automattic Inc) and PayPal (Europe) (S.a.r.l. et Cie S.C.A 22-24 Boulevard Royal L-2449 Luxembourg). Payment data will solely be processed through WooPayments and PayPal and their associated payment methods and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.
Aggregated Data
We also collect use and share aggregated data such as statistical or demographic data for any purpose including improving our website. Aggregated data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you we treat the combined data as Personal Data which will be used in accordance with this privacy policy.
Promotional use of your data
We use your data (name and email address) within the legally permissible scope for marketing purposes e.g. to draw your attention to special promotions and discount offers. You can unsubscribe at any time via the link provided for this purpose in each email we send or by sending us an informal message. After unsubscribing your email address will be deleted immediately.
DATA SHARING
In certain cases it is necessary to transmit the processed Personal Data in the course of data processing. Personal Data is transferred to our service providers in the following instances:
- In the context of fulfilling our contract with you
- To use marketing services and to advertise our services online
- To communicate with you
- To provide our website and
- To state authorities and institutions as far as this is required or necessary.
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
SECURITY OF YOUR DATA
In order to protect the data stored with us in the best possible way against accidental or intentional manipulation loss destruction or access by unauthorized persons we use appropriate technical and organizational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.
Nevertheless internet-based data transmissions can always have security gaps so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
MARKETING
General
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
Affiliate Marketing
We also participate in Affiliate Marketing Programs. In general Affiliate Marketing Programs programs are designed to provide a means for website owners to earn advertising fees by advertising and linking. You will never be charged a fee through one of our affiliate links however you may get a discounted rate of the relevant affiliate's services and we will make a small commission. Our editorial content is not influenced by our affiliate partnerships.
SOCIAL MEDIA
General
We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Information collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
When you visit our profiles and interact with us and others
When you visit our social media profiles we as the operator of the profile process your actions and interactions with our profile (e.g. the content of your messages enquiries posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g. your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
ADVERTISING
We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.
We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers:
- HTTP header information (e.g. IP address web browser website URL date and time)
- Measuring pixel-specific data (e.g. pixel ID and cookie ID)
- Additional information about visits to our website
The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information please refer to our Cookie Policy.
YOUR RIGHTS AND PRIVILEGES
Privacy rights
Under the BDSG and GDPR you can exercise the following rights:
- The right to access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to object to processing
- The right to data portability
- The right to complaint to a supervisory authority
Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or request its rectification deletion or object to its processing please do so by contacting us.
Access Request
In the event you want to make a Data Subject Access Request please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you we will tell you why.
WHAT WE DO NOT DO
We do not request Personal Data from minors and children;
We do not process Special Category Data without specific and expressly given consent;
We do not use Automated decision-making including profiling; and
We do not sell your Personal Data.
CHANGES
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy we will revise the effective date.
EFFECTIVE DATE
Sunday 07th of July 2024
QUESTIONS
If you feel that the above is not sufficient or if you have any queries as regards the collection processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.