Privacy policy for prize competition

Privacy policy for a prize competition

We give great importance to the protection of your personal data and compliance with data protection laws. Below, we inform you in particular about which personal data is processed for which purposes and on which legal basis.

1. Who is responsible for data processing?

HolidayPirates GmbH, Neue Grünstrasse 18, 10179 Berlin, Germany is the data controller. The Data Protection Commissioner of the HolidayPirates GmbH can be contacted here: [email protected]

2. Which categories of personal data are being used?

We process the contact data (email address), in addition to the protocol data which arise with the use of our IT systems. Furthermore, we process the following types of contact data provided by the winner of the competition:

• Full Name

• Email-Address

• Address

• IBAN + BIC of winner's bank account

3. Where do these data come from?

The data comes directly from you as they have been collected in the course of participating in the prize draw.

4. For which purposes are my data being processed? Which is the legal basis that the company bases this on?

a. Art 6 para 1 b) GDPR

We process personal data within the framework of contractual negotiations and the performance of the contract for the prize draw that has been concluded between you and us.

Processing takes place for the provision of contractually guaranteed services like e.g. the fulfilment of a possible claim for the prize offered as part of the competition.

Legal basis is Art. 6 para. 1 b) GDPR. Within the scope of contract fulfilment and performance we process the data that you provide to us upon formation of the contract or in the course of the contractual relationship. This includes in particular your master information (name, surname, date of birth, address, e-mail address).

b. Art. 6 para 1 a) GDPR

If you have provided us with your consent to process data, we do so for the purposes informed about in the course of the declaration of consent. Consent that you have provided may be revoked at any time.

c. Art. 6 para 1 f) GDPR

We process your data in order to protect our own legitimate interest or those of third parties. This applies in particular to internal communication between affiliated companies and other administrative purposes.

5. Will data be transferred?

Within our company respectively the group of companies those employees receive access to your data who need the data in order to fulfill the contractual or legal responsibilities. Moreover, service providers that we use may also receive data for these purposes:

List of sponsored prize partners:

Landal GmbH

Max-Planck-Straße 12, 54296 Trier, Germany

WONDR Experience B.V.

Meeuwenlaan 88, 1021 JK, Amsterdam, Netherlands

Crystal Tours

Lindwurmstraße 80, 80337, München, Germany

TravelTrex GmbH

Bonner Str. 484-486

50968 Köln

OM Digital Solutions GmbH

Willy-Brandt-Strasse 23, 20457 Hamburg

Aldiana GmbH

Emil-von-Behring-Straße 6

60439 Frankfurt

Travel Partner GmbH,

Austrasse 2a, 6352 Ellmau

Robinson Club GmbH

Karl-Wiechert-Allee 23

30625 Hannover

Purpose: The purpose of this data transfer to all partners above is to give the contact details of our winners so the prize won can be carried out.

___________

Playable ApS

• Address & place of jurisdiction: Playable ApS, Tueager 1, Aarhus N, Jylland 8200 Denmark

• GDPR Compliance: https://playable.com/privacy-policy-for-playable-aps/

Purpose: Playable is used to facilitate gamified marketing campaigns aimed at expanding our newsletter subscriber base.

Disclosed Data: The tool collects and processes personal data only as necessary to track participation, manage participant rewards, and measure campaign effectiveness, such as first name, email and game statistics.

Playable ApS is used as our order processor pursuant to Art. 28 GDPR. For details please see our Data Protection Policy.

Iterable Inc.

The technical service provider Iterable Inc. is our processor for sending newsletters.

• Address & place of jurisdiction: Iterable Inc., 71 Stevenson Street, 3rd Floor, San Francisco, CA 94105, USA

• GDPR Compliance: https://iterable.com/trust/privacy-policy/

Purpose: For advertising campaigns and sending offers from our website

Disclosed Data: Email address (required), First and last name (voluntary), Subscription date (automatically collected), The country selected for the subscription (automatically collected)

In return for taking part in the competition, we ask for your consent to receive our newsletter by email in the future, featuring our best holiday deals and travel information. Your personal data will only be used for this purpose. You may withdraw your consent at any time. You can find more information in our privacy policy (LINK).

When you subscribe to the newsletter, your behaviour within the newsletter is recorded (such as whether you open emails and click on links). As soon as you open and/or click on a newsletter, pseudonymised data is stored. We use this information to optimise the content and offers on our website. To tailor the newsletter to your interests, we use cookies which may track your clicks where necessary (retargeting). This enables us to send you special offers and information that match your actual interests. By subscribing to our newsletter, you agree to this process. Of course, you may object to this at any time.

The legal basis for sending the newsletter is your consent in accordance with Art. 6 para. 1 (a) GDPR.

By registering, you also consent to your data being processed in the USA in accordance with Article 49 Paragraph 1 Sentence 1 Letter a GDPR. The USA is assessed by the European Court of Justice as a country that does not provide an adequate level of data protection according to EU standards. In particular, there is a risk that your data may be accessed by US authorities for monitoring and surveillance purposes, potentially without any legal remedies available to you.

You may unsubscribe from our newsletter at any time; a link to do so can be found at the end of every newsletter. Once you have unsubscribed, you will no longer receive any offers from us. Your personal data will no longer be used and will be immediately blocked. Your data will then be stored for a further three years before being deleted. The legal basis for this retention is our legitimate interest in proving that emails were sent with your consent, in order to defend against potential claims.

Bank

• Address: Commerzbank Aktiengesellschaft, Kaiserplatz, 60311 Frankfurt/Main

• GDPR Compliance: https://www.commerzbank.de/portal/de/angebot/garmin/garmin-1/footer-8/recht-7/recht.html

Bank details will be stored for internal communication purposes, for example, if they are sent to the finance department by email. This information will be deleted internally once the transfer has been completed.

We are required to retain bank statements for 10 years. This data is permanently deleted once the statutory tax and commercial retention periods have expired.

6. What are my rights?

Basically you have the following rights:

• right of access (Art. 15 GDPR)

• right to rectification (Art. 16 GDPR)

• right to object (Art. 21 GDPR)

• right to erasure (Art. 17 GDPR)

• right to restriction of processing (Art. 18 GDPR)

• right to data portability (Art. 20 GDPR)

Where we cite our legitimate interest (Art. 6 para 1 f) GDPR) as the legal basis, you have a right to objection pursuant to Art. 21 GDPR.

According to Art. 21 GDPR you have the right

to object to the processing of personal data at any time. We will then no longer process the personal data for direct marketing purposes or a related profiling.

We also do not process your personal data for other purposes after your objection unless we can demonstrate reasons that are binding and worthy of protection for the processing of the data which outweigh your interests, rights and freedoms, or the processing of your personal data serves to assert, exercise or defend legal claims (cf. Art. 21 para. 1, para. 6 GDPR, so-called "limited right of objection"). In this case, you must explain the reasons for the objection arising from your particular situation.

7. Do I have a right to complain?

Yes, you have the possibility to address your complaint directly to us or towards the competent data protection authority.

We attach great importance to transparency. Please do not hesitate to contact us if you have any questions.

8. How long will my data be saved?

We process and store your personal data for the period of the existing contract. We will regularly delete the data when data is not required for contractual or legal purposed anymore. However, we need to take into account legal retention periods (in particular § 257 HGB and § 147 AO). These are up to 10 years.

Insofar as data is to be retained to ensure enforcement of legal claims, the limitation periods can be up to 30 years, whereby the regular limitation period is three years.

If your data is used for advertising purposes, we will only process the data until you object to its use or have revoked your consent or until usage is no longer permitted by law.

9. Do I have to give you my data?

In the context of our contractual relationship, you must provide the personal data that is necessary for the performance and fulfilment of the contract or the processing of which we are legally bound. Failure to make them available would mean that we would regularly are unable to conclude the contract with you.