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Data Privacy
  1. ETI
  2. Data Privacy

Privacy policy

1) General information on the collection of personal data

a) The protection of your privacy when using our websites is very important to us; accordingly, we use your personal data in accordance with the statutory data protection regulations. Personal data is all data that can be related to you personally, e.g. name, address, e-mail address, user behavior. Below we inform you about how we handle your personal data.

 

b) The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is (Claudia Schramek, Karlsplatz 3, 1010 Vienna, datenschutz@eti.at). You can contact our data protection officer at (datenschutz@eti.at) or at our postal address ETI Austria, Karlsplatz 3, 1010 Vienna with the addition "To the data protection officer".

c) If you are under the age of 16, please obtain the permission of a parent/guardian before providing personal data.

 

2. collection of personal data when visiting our website

a) In principle, you can visit our website without telling us who you are. As is usual with almost all websites, the server on which our website is located (hereinafter referred to as "web server") automatically collects information from you when you visit us on the Internet. This data is technically necessary for us and ensures the stability and security of the website.

The web server automatically recognizes certain personal data such as your IP address, the date and time you visited our website, the pages you visited on our website, the website you visited previously, the browser you are using (e.g. Internet Explorer, Firefox, Safari), the operating system you are using (e.g. Windows, Linux, MAC OS) and the domain name and address of your internet provider (e.g. UPC, Telekom, A1, ...). Since our website uses cookies (as explained below), the web server also stores this information (legal basis is Art. 6 para. 1 sentence 1f GDPR).

We regularly evaluate these server logs anonymously for statistical purposes (click stream analyses) so that we can determine how our websites are used. We then use these findings to optimize our website.

Furthermore, in the event of system misuse, we may use this information in cooperation with your internet provider and/or local authorities to identify the perpetrator of this misuse.

b) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard disk and assigned to the browser you are using and through which certain information flows to the body that sets the cookie (in this case us). Cookies cannot execute programs or transfer viruses to your computer. They are used to make the website more user-friendly and effective overall.

aa) This website uses the following types of cookies, the scope and function of which are explained below:

- Transient cookies (see bb)

- Persistent cookies (see cc).

bb) Transient cookies are automatically deleted when you close the browser. These include session cookies in particular. These store a so-called session ID, with which various requests from your browser can be assigned to the joint session. This allows your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

cc) Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete the cookies at any time in the security settings of your browser.

dd) You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. We would like to point out that you may not be able to use all the functions of this website.

ff) The Flash cookies used are not recorded by your browser, but by your Flash plug-in. We also use HTML5 storage objects, which are stored on your end device. These objects store the required data independently of the browser you use and do not have an automatic expiration date. If you do not want Flash cookies to be processed, you must install an appropriate add-on, e.g. "Better Privacy" for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash Killer cookie for Google Chrome. You can prevent the use of HTML5 storage objects by setting your browser to private mode. We also recommend that you regularly delete your cookies and browser history manually.

c) Cookies from third parties on our websites

We allow third parties to place cookies on your computer via these web pages.

(1) This website uses Google Analytics, a web analysis service of Google Inc ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, your IP address will first be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

You can object to the collection and storage of data at any time with effect for the future. You can use the following link to do so: Deactivation of Google Analytics

(2) The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

(3) You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

(4) This website uses Google Analytics with the extension "_anonymizeIp()". This means that IP addresses are further processed in abbreviated form, so that they cannot be linked to a specific person. If the data collected about you is personally identifiable, it is immediately excluded and the personal data is deleted immediately.

(5) We use Google Analytics to analyze and regularly improve the use of our website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 para. 1 sentence 1 lit. f GDPR.

(6) Information from the third-party provider: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of use: http://www.google.com/analytics/terms/de.html, overview of data protection: http://www.google.com/intl/de/analytics/learn/privacy.html, as well as the privacy policy: http://www.google.de/intl/de/policies/privacy.

(7) This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. You can deactivate the cross-device analysis of your usage in your customer account under "My data", "Personal data".

d) Use of social media plug-ins

(1) We currently use the following social media plug-ins: Facebook, Pinterest, Twitter. We use the so-called two-click solution. This means that when you visit our website, no personal data is initially passed on to the providers of the plug-ins. You can recognize the provider of the plug-in by the marking on the box above its initial letter or the logo. We give you the option of communicating directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it will the plug-in provider receive the information that you have accessed the corresponding website of our online offering. In addition, the data mentioned under point 2 of this declaration is transmitted. In the case of Facebook, according to the respective providers in Austria, the IP address is anonymized immediately after collection. By activating the plug-in, your personal data is therefore transmitted to the respective plug-in provider and stored there (for US providers in the USA). As the plug-in provider collects data in particular via cookies, we recommend that you delete all cookies via your browser's security settings before clicking on the grayed-out box.

(2) We have no influence on the data collected and data processing procedures, nor are we aware of the full scope of data collection, the purposes of processing or the storage periods. We also have no information on the deletion of the data collected by the plug-in provider.

(3) The plug-in provider stores the data collected about you as usage profiles and uses these for the purposes of advertising, market research and/or the needs-based design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to display needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. We offer you the opportunity to interact with the social networks and other users via the plug-ins so that we can improve our offering and make it more interesting for you as a user. The legal basis for the use of the plug-ins is Art. 6 para. 1 sentence 1 lit. f GDPR.

(4) The data transfer takes place regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected by us will be assigned directly to your existing account with the plug-in provider. If you click the activated button and, for example, link the page, the plug-in provider also saves this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, but especially before activating the button, as this way you can avoid being assigned to your profile with the plug-in provider.

(5) Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policies of these providers. There you will also find further information on your rights in this regard and setting options to protect your privacy.

e) Integration of YouTube videos

(1) We have integrated YouTube videos into our online offering, which are stored on http://www.YouTube.com and can be played directly from our website. [These are all integrated in "extended data protection mode", i.e. no data about you as a user is transferred to YouTube if you do not play the videos. Only when you play the videos will the data mentioned in paragraph 2 be transmitted. We have no influence on this data transfer].

2) By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data mentioned under point 2 of this declaration will be transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be assigned directly to your account. If you do not wish your data to be associated with your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or the needs-based design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

(3) Further information on the purpose and scope of data collection and its processing by YouTube can be found in YouTube's privacy policy. There you will also find further information on your rights and setting options to protect your privacy.

f) Integration of Google Maps

(1) We use the Google Maps service on this website. This allows us to show you interactive maps directly on the website and enables you to use the map function conveniently.

2) By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. In addition, the data mentioned under point 2 of this declaration is transmitted. This takes place regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be assigned directly to your account. If you do not wish your data to be associated with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or the needs-based design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right.

(3) Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the provider's privacy policy. There you will also find further information on your rights in this regard and setting options to protect your privacy: http://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

g) Newsletter

In the regular ETI newsletter, we provide information about our products and services and provide up-to-date information on the subject of travel. We will only send you the ETI newsletter if you actively register for this service. If you register to receive our newsletter, the personal data you provide will be collected, stored and processed for the purpose of sending you the newsletter.

ETI Austria guarantees the confidential treatment of your data. If you wish, you can unsubscribe from the newsletter at any time in various ways: via direct contact with us and via the "Unsubscribe newsletter" link contained in every newsletter.

(1) Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people's e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

2) Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

(3) Notes on legal bases: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded based on our legitimate interests to demonstrate that it was carried out in accordance with the law.

Content: Information about us, our services, promotions and offers.

(4) Success measurement: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval Technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of access.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the shipping service provider to monitor individual users. Rather, the evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.

Unfortunately, it is not possible to revoke the success measurement separately; in this case, the entire newsletter subscription must be canceled or objected to.

Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
Affected persons: communication partners.
Purposes of processing: Direct marketing (e.g. by email or post).
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Option to object (opt-out): You can cancel your receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

(5) Services and service providers used:

Mailchimp: email marketing platform; Service provider: \"Mailchimp\" - Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/privacy/; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active

For this purpose, we pass on the following personal data to Mailchimp:

Email address
[First name]
[Last name]
[Phone number]

[Our email communications include a link that allows you to update your personal information.]

Mailchimp is the recipient of your personal data and acts as a processor for us when it comes to sending our newsletter. The processing of the data provided under this section is not required by law or contract. Without your consent and the transmission of your personal data, we cannot send a newsletter to you.

In addition, Mailchimp collects the following personal data using cookies and other tracking methods: information about your device (IP address, device information, operating system, browser ID, information about the application you use to read your emails and other information via hardware and internet connection. In addition, usage data is collected such as the date and time when you opened the email / campaign and browser activity (e.g. which emails / websites were opened). Mailchimp needs this data to ensure the security and reliability of the Systems to ensure compliance with the terms of use and the avoidance of misuse. This corresponds to the legitimate interest of Mailchimp (according to Art. 6 Para. 1 lit. f GDPR) and serves to implement the contract (according to Art. 6 Para. 1 lit. b GDPR). Mailchimp also evaluates performance data, such as email delivery statistics and other communication data. This information is used to compile usage and performance statistics of the Services.

Mailchimp additionally collects information about you from other sources. Within an unspecified period and scope, personal data is collected via social media and other third-party data providers. We have no influence on this process.

Further information on objection and removal options against Mailchimp can be found at: https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts

The legal basis for this processing is your consent in accordance with Article 6 (1) (a) GDPR. You can revoke your consent to the processing of your personal data at any time. There is a corresponding link in all mailings. You can also revoke your consent using the contact options provided. Declaring your revocation will not affect the lawfulness of the processing that has taken place so far.

Your data will be processed as long as you have given your consent. Apart from that, these will be deleted after the contract between us and Mailchimp has ended, unless legal requirements require further storage.

Mailchimp has implemented compliance measures for international data transfers. These apply to all global activities where Stripe processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs). For more information, see: https://mailchimp.com/legal/data-processing-addendum/

i) Contact

When you contact us by email or via a contact form, we will store the data you provide (your email address, if applicable your name and telephone number) in order to answer your questions. We delete the data arising in this context after storage is no longer necessary or restrict processing if there are statutory retention periods.

3. Legal basis for processing

We process your personal data on the basis of a booking, i.e. a legally binding contract between Express Travel International GmbH and you, the end customer.

Providing your personal data is necessary for the conclusion of the contract and is a contractual obligation. This means that you are obliged to provide us with your personal data as part of a travel booking. If you decide not to provide us with your personal data, this will have the following consequences: The travel booking cannot be carried out or completed.

No automated decision-making will be carried out, which is based solely on automated processing, including profiling, and which produces a legal effect or similarly affects you.

4. Your rights

According to the provisions of the GDPR, you can assert the following rights against us:

• Right to information

• Right to rectification

• Right to restriction of processing

• Right to erasure / right to be forgotten

• Right to data portability

• Right to object

If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time with future effect. The lawfulness of processing based on consent until its revocation remains unaffected.

To exercise any of your rights listed above, you can contact us at any time:

Express Travel International GmbH
Karlsplatz 3
1010 Vienna
datenschutz@eti.at

0043-1-512 42 16

If you are of the opinion that we are processing your personal data in an unlawful manner, please contact us at info@eti.at. You also have the right to contact the data protection supervisory authority.


The responsible supervisory authority is:

Austrian data protection authority
(formerly: Data Protection Commission)
Wickenburggasse 8
1080 Vienna

 

5. Storage period

Express Travel International GmbH stores your personal data for as long as there is a business relationship with you. After the business relationship has ended, your data will generally be retained for 10 years, unless there are statutory retention periods to the contrary or you do not provide us with it

Request deletion. We would like to point out that your right to delete data may be restricted by legal retention requirements that we must comply with.

 

6. Place of data processingy

Express Travel International GmbH processes your data exclusively in Austria.

7. Sharing your personal information

We only pass on your personal data to those bodies that need your data to carry out our tasks. This may require service providers to support us. It may also be necessary for your data to be passed on to other units in our group of companies. We comply with data protection regulations. Furthermore, courts, law enforcement authorities or other legally designated authorities can access data or request information on a legal basis. Your personal data may be passed on to the following recipients in particular:

• Agencies in the travel destinations

• Airlines

• Diving schools

• IT service providers, printing service providers

• Authorities, offices, banks.

The aforementioned recipients may be located in a country outside the EU. This country may not have an adequate level of data protection compared to the level of data protection within the European Union. This means that the data protection laws in the country to which we transfer your data may not provide the same protection as in Austria. In principle, your data will be passed on to third countries without an adequate level of data protection using the so-called EU standard contractual clauses. You can obtain a copy of these protective measures via datenschutz@eti.at.

8. Security measures

If we forward data to our service providers as part of the services described here, they are bound to contractual requirements with us on the subject of data protection in addition to the mandatory legal regulations.

We use security measures that we continuously optimize in accordance with technical and legal developments in order to best protect your data against accidental or intentional manipulation, loss, destruction or access by unauthorized third parties.

9. Links to Other Websites

Our online offering contains links to other websites. This privacy statement does not extend to other providers.

We have no influence on whether their operators comply with data protection regulations and therefore assume no responsibility for the accuracy, timeliness and completeness of the information provided there.

The Express Travel International GmbH website may contain hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies and they probably also use cookies. We recommend you check them out. The policies of these websites govern the use of personal data that you provide when you visit the website in question, which may also be collected through cookies. We accept no liability for such third-party websites and your use of such websites is therefore at your own risk.

10. Contact us

If you have any questions or comments about this privacy and cookies policy, please contact us using the controller's contact details provided in this statement (see section 1).

The rapid development of the Internet requires adjustments to our data protection regulations from time to time. You will be informed about the innovations here.

11. Push Notifications

You can sign up to receive our push notifications. To send our push notifications, we use the “CleverPush” shipping service, which is operated by CleverPush UG (limited liability), Nagelsweg 22, 20097 Hamburg (“CleverPush”).

You will receive regular information about the subject areas you have activated via our push notifications.

To register, you must confirm your browser's request to receive notifications. This process is documented and saved by CleverPush. This includes storing the time of registration as well as your browser ID or your device ID. The collection of this data is necessary so that we can understand the processes in the event of misuse and therefore serves our legal protection.

In order to be able to display push notifications to you, CleverPush collects and processes your browser ID on our behalf and, in the case of mobile access, your device ID.

By subscribing to our push notifications, you agree to receive them. The legal basis for processing your data after registering for our push notifications is Art. 6 Para. 1 lit. a GDPR, provided you have given your consent.

CleverPush also evaluates our push notifications statistically. This allows CleverPush to recognize whether and when our push notifications were displayed and clicked on by you.

You can revoke your consent to the storage and use of your personal data to receive our push notifications and the statistical survey described above at any time with future effect. For the purpose of revoking your consent, you can change the setting in your browser for receiving push notifications. If you use our push notifications on a desktop PC with the “Windows” operating system, you can also unsubscribe from our push notifications by right-clicking on the respective push notification in the settings that appear there.

Your data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. Your data will therefore be stored as long as your subscription to our push notifications is active.

Information about the cancellation process can be found at: cleverpush.com/en/faq

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