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Privacy Policy

With this Privacy Policy, we inform you about the personal data we process in connection with our activities and operations, including our thorenberg.ch website. We specifically inform you about the purposes, methods, and locations of the personal data processing. We also inform you about the rights of individuals whose data we process.

For individual or additional activities and operations, further privacy policies and other legal documents such as general terms and conditions (GTC), terms of use, or participation conditions may apply.

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

1. Contact Addresses

Responsible for the processing of personal data:

Hotel Restaurant Thorenberg
Thorenbergstrasse 5
CH-6014 Luzern-Littau

info@thorenberg.ch

In individual cases, there may be other responsible parties for the processing of personal data or joint responsibility with at least one other responsible party.

2. Terms and Legal Bases

2.1 Terms

Personal data refers to all information relating to an identified or identifiable natural person. An affected person is a person whose personal data we process.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading, disclosing, acquiring, recording, collecting, deleting, disclosing, organizing, storing, altering, disseminating, linking, destroying, and using personal data.

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

2.2 Legal Bases

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

We process – if and to the extent the General Data Protection Regulation (GDPR) is applicable – personal data based on at least one of the following legal grounds:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data to fulfill a contract with the affected person and to carry out pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to protect the legitimate interests of us or third parties, provided that the fundamental freedoms and rights as well as the interests of the affected person do not prevail. Legitimate interests include, in particular, our interest in being able to conduct our activities and operations permanently, user-friendly, securely, and reliably, as well as to communicate about them, ensuring information security, protection against misuse, enforcement of our legal claims, and compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under applicable law of member states in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data to perform a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the affected person.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the affected person or another natural person.

3. Type, Scope, and Purpose

We process the personal data that is necessary to conduct our activities and operations permanently, user-friendly, securely, and reliably. Such personal data may particularly fall into the categories of inventory and contact data, browser and device data, content data, meta or edge data, and usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration required for the respective purpose or purposes or as legally required. Personal data that is no longer necessary will be anonymized or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are particularly specialized providers whose services we use. We ensure data protection even with such third parties.

We generally process personal data only with the consent of the affected persons. If and to the extent that processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent to fulfill a contract, comply with legal obligations, or protect overriding interests.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect during the course of our activities and operations, provided that such processing is permissible for legal reasons.

4. Communication

We process personal data to communicate with third parties. In this context, we particularly process data that an affected person transmits when contacting us, for example, by postal mail or email. We may store such data in an address book or similar tools.

Third parties who transmit data about other persons are obliged to ensure data protection for such affected persons. This includes ensuring the accuracy of the transmitted personal data.

5. Applications

We process personal data about applicants to the extent necessary to assess suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data is derived, in particular, from the requested information, for example, in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example, in electronic and printed media or on job portals and job platforms.

We also process the personal data that applicants voluntarily provide or publish, particularly as part of cover letters, resumes, and other application documents, as well as online profiles.

We process – if and to the extent the General Data Protection Regulation (GDPR) is applicable – personal data about applicants particularly in accordance with Art. 9 para. 2 lit. b GDPR.

6. Data Security

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we particularly ensure the confidentiality, availability, traceability, and integrity of the processed personal data, although we cannot guarantee absolute data security.

Access to our website and our other online presence is via transport encryption (SSL / TLS, particularly with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

Our digital communication is subject – as generally all digital communication is – to mass surveillance without cause and suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities, and other security authorities. We also cannot rule out that individual affected persons are specifically monitored.

7. Personal Data Abroad

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

We may export personal data to all countries and territories on Earth and elsewhere in the universe, provided that the law there ensures adequate data protection according to a decision by the Swiss Federal Council and – if and to the extent the General Data Protection Regulation (GDPR) is applicable – according to a decision by the European Commission.

We may transmit personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, particularly based on standard data protection clauses or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, such as the explicit consent of the affected persons or a direct connection with the conclusion or execution of a contract. We are happy to provide affected persons with information about any guarantees or provide a copy of any guarantees upon request.

8. Rights of Affected Persons

8.1 Data Protection Claims

We grant affected persons all claims in accordance with the applicable data protection law. Affected persons have the following rights in particular:

  • Information: Affected persons can request information about whether we process personal data about them, and if so, which personal data is involved. Affected persons also receive the information necessary to assert their data protection claims and ensure transparency. This includes the processed personal data itself, but also, among other things, information about the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
  • Correction and Restriction: Affected persons can correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
  • Deletion and Objection: Affected persons can have personal data deleted («right to be forgotten») and object to the processing of their data with effect for the future.
  • Data Release and Data Transfer: Affected persons can request the release of personal data or the transfer of their data to another responsible party.

We may defer, restrict, or deny the exercise of the rights of affected persons within the legally permissible framework. We may point out any prerequisites that may need to be met for the exercise of their data protection claims. For example, we may refuse to provide information in whole or in part by referring to business secrets or the protection of other persons. We may also refuse to delete personal data in whole or in part by referring to legal retention obligations.

We may exceptionally charge costs for the exercise of rights. We will inform affected persons in advance of any costs.

We are obliged to identify affected persons who request information or assert other rights with appropriate measures. Affected persons are obliged to cooperate.

8.2 Legal Protection

Affected persons have the right to assert their data protection claims through legal channels or to file a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for complaints from affected persons against private responsible parties and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities for complaints from affected persons – if and to the extent the General Data Protection Regulation (GDPR) is applicable – are organized as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany.

9. Use of the Website

9.1 Cookies

We may use cookies. Cookies – both first-party cookies and third-party cookies whose services we use – are data stored in the browser. Such stored data does not necessarily have to be limited to traditional text-form cookies.

Cookies can be stored in the browser temporarily as «session cookies» or for a certain period as so-called permanent cookies. «Session cookies» are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies enable, in particular, the recognition of a browser on the next visit to our website and thereby, for example, the measurement of the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be deactivated or deleted at any time, in whole or in part, in the browser settings. Without cookies, our website may no longer be fully available. We request – at least if and to the extent necessary – active explicit consent for the use of cookies.

For cookies used for success and reach measurement or for advertising, a general objection («opt-out») is possible for many services via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

9.2 Logging

We may log at least the following information for each access to our website and our other online presence, provided this information is transmitted to our digital infrastructure during such access: date and time, including time zone, IP address, access status (HTTP status code), operating system, including user interface and version, browser, including language and version, accessed individual sub-page of our website, including transmitted data volume, last webpage accessed in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. The information is necessary to provide our online presence permanently, user-friendly, and reliably. The information is also necessary to ensure data security – even by third parties or with the help of third parties.

9.3 Counting Pixels

We may incorporate counting pixels into our online presence. Counting pixels are also referred to as web beacons. Counting pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when accessing our online presence. Counting pixels can capture at least the same information as log files.

10. Notifications and Communications

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

10.1 Success and Reach Measurement

Notifications and communications may contain web links or counting pixels that capture whether an individual message was opened and which web links were clicked. Such web links and counting pixels can also capture the use of notifications and communications on a personal basis. We need this statistical capture of usage for success and reach measurement to send notifications and communications effectively, user-friendly, and permanently, securely, and reliably based on the needs and reading habits of the recipients.

10.2 Consent and Objection

You must generally consent to the use of your email address and other contact addresses unless the use is permissible for other legal reasons. For obtaining a double-confirmed consent, we may use the «Double Opt-in» procedure. In this case, you will receive a message with instructions for double confirmation. We may log obtained consents, including IP address and timestamp, for evidence and security reasons.

You can generally object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical capture of usage for success and reach measurement. Necessary notifications and communications related to our activities and operations remain reserved.

10.3 Service Providers for Notifications and Communications

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

We particularly use:

11. Social Media

We are present on social media platforms and other online platforms to communicate with interested parties and inform about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The general terms and conditions (GTC) and terms of use as well as privacy policies and other provisions of the individual operators of such platforms apply. These provisions particularly inform about the rights of affected persons directly against the respective platform, including the right to information.

For our social media presence on Facebook, including the so-called page insights, we – if and to the extent the General Data Protection Regulation (GDPR) is applicable – are jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including in the USA). Page insights provide information about how visitors interact with our Facebook presence. We use page insights to provide our social media presence on Facebook effectively and user-friendly.

Further information about the type, scope, and purpose of data processing, information about the rights of affected persons, and the contact details of Facebook and Facebook's data protection officer can be found in the Facebook Privacy Policy. We have concluded the so-called «Controller Addendum» with Facebook, agreeing that Facebook is responsible for ensuring the rights of affected persons. For the so-called page insights, the corresponding information can be found on the page «Information about Page Insights», including «Information about Page Insights Data».

12. Services from Third Parties

We use services from specialized third parties to conduct our activities and operations permanently, user-friendly, securely, and reliably. With such services, we can embed functions and content into our website. In such embedding, the services used must capture at least temporarily the IP addresses of users for technical reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized manner. This includes, for example, performance or usage data to be able to offer the respective service.

We particularly use:

12.1 Digital Infrastructure

We use services from specialized third parties to utilize the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We particularly use:

12.2 Audio and Video Conferences

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

We recommend muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences, depending on the life situation.

12.3 Online Collaboration

We use services from third parties to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the used services, such as terms of use or privacy policies, apply.

12.4 Map Material

We use services from third parties to embed maps into our website.

We particularly use:

12.5 Digital Audio and Video Content

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

We particularly use:

12.6 Fonts

We use services from third parties to embed selected fonts as well as icons, logos, and symbols into our website.

We particularly use:

12.7 Advertising

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

We particularly want to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties who enable such advertising. We can also determine whether our advertising is successful, that is, whether it leads to visits to our website (conversion tracking).

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

We particularly use:

13. Extensions for the Website

We use extensions for our website to utilize additional functions. We may use selected services from suitable providers or use such extensions on our own server infrastructure.

We particularly use:

14. Success and Reach Measurement

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

For success and reach measurement, the IP addresses of individual users are usually stored. IP addresses are generally shortened («IP masking») to follow the principle of data minimization through the corresponding pseudonymization.

Cookies may be used for success and reach measurement, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, information about the size of the screen or browser window, and the – at least approximate – location. Generally, any user profiles are created exclusively pseudonymized and not used to identify individual users. Individual services from third parties where users are registered may associate the use of our online offering with the user account or user profile of the respective service.

We particularly use:

15. Video Surveillance

We use video surveillance to prevent crimes and secure evidence in case of crimes, as well as to exercise our house rights. These are – if and to the extent the General Data Protection Regulation (GDPR) is applicable – overriding legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR.

We store recordings from our video surveillance for as long as they are necessary for securing evidence.

We may secure recordings based on legal obligations, to enforce our legal claims, and in case of suspicion of crimes, as well as transmit them to competent authorities, particularly judicial or law enforcement authorities.

16. Final Provisions

We have created this Privacy Policy with the Privacy Policy Generator from Datenschutzpartner.

We may adapt and supplement this Privacy Policy at any time. We will inform about such adaptations and supplements in an appropriate manner, particularly by publishing the current Privacy Policy on our website.