Global Brand Assets/Campaigns/WhatsApp 2022/beach-summer-friends-1200x630_mld00r_wdbxop

Privacy policy for prize competition

Privacy policy for prize competition

The protection of your personal data in compliance with data protection laws is extremely important to us. Below, you will find specific information about which type of personal data is processed for which purposes and on which legal basis.

1. Who is responsible for data processing?

HolidayPirates GmbH, Warschauer Platz 11-13, 10245 Berlin, Germany, is the data controller. The Data Protection Officer of HolidayPirates GmbH is Roman Maczkowsky. He can be contacted via [email protected]

2. Which categories of personal data are being processed?

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: first name, last name and email address.



IBAN + BIC of winners bank account

3. Where does the 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 is my data being processed? What is the legal basis?

a. Art 6 para 1 b) GDPR

We process personal data required to fulfill the contractual obligations of the competition.

Data is processed for the provision of contractually guaranteed services such as giving the prize to the winner of the competition.

The legal basis is Art. 6 para. 1 b) GDPR. In order to execute and fulfill the competition contract, we will process the data that you provide us upon formation of the contract or in the course of the contractual relationship. In particular, this includes your personal data and contact information (first name, last name, date of birth, address, email address).

b. Art. 6 para 1 a) GDPR

If you have given us your consent to process your data, we will do so for the purposes listed in the consent form. You may revoke your consent at any time.

c. Art. 6 para 1 f) GDPR

We process your data in order to protect our own legitimate interests or those of third parties. This applies in particular to internal communication between affiliated companies and data required for certain 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 fulfil the contractual or legal responsibilities. Moreover, service providers that we use may also receive data for these purposes:

Vonage B.V.

The WhatsApp newsletter is sent via the messenger service provider called Vonage B.V.

Address: Vonage B.V., Prins Bernhardplein 200, 1097 JB Amsterdam, Netherlands

GDPR Compliance:

Purpose: For direct communication and sending out offers from our website

Disclosed data- all pseudonymised data: Phone number, Profile Picture (optional), Name and Surname (optional), Messenger ID (automatically), Messages or Questions sent to us

Whatsapp Inc.

Address: WhatsApp, Inc., 1601 Willow Road, Menlo Park, California 94025, USA

GDPR Compliance:

To use our WhatsApp alert service, you must have an existing messaging account withWhatsApp, Inc., 1601 Willow Road, Menlo Park, California 94025, USA, whose privacy policy can be found here.

We would like to advise you that the respective provider receives personal data which are also processed on servers in the USA wherein no level of data protection can be guaranteed. You can find further information by visiting the data protection regulations of the respective messenger services provided above.

6. What are my rights?

In accordance with the GDPR, 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 your personal data being processed at any time. We will then no longer process your personal data for direct marketing purposes or related profiling.

After your objection we will not process your personal data for any other purposes, either - unless we are able to demonstrate that there are reasons to do so that clearly outweigh your interests, rights and freedoms, or unless processing 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 these cases, you are required to explain the reasons for your objection.

7. Do I have the right to complain?

Yes, you may address your complaint either to us or the relevant data protection authority.

Transparency is very important to us. Please do not hesitate to contact us if you have any further questions.

8. For how long will my data be stored?

We process and store your personal data for the period of the existing contract. We regularly delete data that is no longer required for contractual or legal purposes. However, we need to take into account legal retention periods (in particular § 257 HGB and § 147 AO), which can be up to 10 years.

When data is stored for the purpose of ensuring enforcement of legal claims, the limitation periods can be up to 30 years, but 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 revoke your consent or until usage is no longer permitted by law.

9. Do I have to give you my data?

In the course of the contractual relationship of the competition, you are required to provide your personal data that is either necessary for the execution and fulfillment of the contract or legally required in this context. Failure to make this data available would result in failure to conclude the contract with you.