Privacy Statement
PNMB Brands GmbH, Lehargasse 7, A-1060 Vienna (“we”, “us”, “Controller”) is committed to ensuring adequate protection for your personal data. We thus comply with the applicable regulations, in particular the General Data Protection Regulation (GDPR), the Austrian Data Protection Act (DSG), and the Telecommunications Act of 2021 (TKG) in the interests of protecting, properly handling, and maintaining confidentiality with regard to personal data and for data security. This statement explains what information we collect, process, and use, when (i) you visit and use the website www.panam-hotels.com (“the website”):
1. PARTY RESPONSIBLE FOR DATA PROCESSING (CONTROLLER)
The Controller of the processed data is PNMB Brands GmbH, Lehargasse 7, A-1060 Vienna .
2. WHAT ARE PERSONAL DATA?
Personal data are information about natural persons (“data subjects”) by means of which a person’s identity is determined or at least can be determined. This includes, for example, your name, IP address, or your e-mail address.
3. WHAT DATA DO WE COLLECT FROM YOU?
Usage data: When you visit our website, we record the IP address of your device, the Internet browser being used, the browser language, your operating system, the files requested on our website, your Java settings, the screen resolution, the colour depth, your click behaviour on the website (time of access, clicks), and the website from which you are visiting (referrer URL).
Social media plugins: Some pages contain buttons from social media networks (for example, Facebook or Twitter), with which you can recommend our website to others. These plugins are indicated by icons (e.g. “Facebook”, “Twitter”, and “Pinterest” buttons). When you click on such a button, the following data can be transferred to the operator of the social media in question: IP address, browser information and operating system, screen resolution, installed browser plugins, origin of the visitor, and URL of the current page. Using this, the social media in question can also link your usage behaviour to your personal social media account. For more details, see Point 7.
We only transfer your personal data from the use of social media plugins on the basis of your consent. You may withdraw this consent at any time with effect for the future.
4. HOW DO WE COLLECT YOUR DATA?
The data generated during your visit to our website are collected automatically using cookies (for more details, see Point 7). Otherwise, we only collect the data on the basis of your entries on our website.
5. FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS DO WE USE YOUR DATA?
Usage data: We use your personal data to (i) improve our services and our website and enhance user-friendliness, and (ii) to personalise services for website users by temporarily saving search parameters. The access data collected during use of the website are only used for statistical analysis in aggregated form, in the interests of website operation, security, and optimisation (legitimate interests pursuant to Article 6 (1) point f of the GDPR).
As discussed in more detail below in this privacy statement, we use the services of third-party providers (Google, Facebook, LinkedIn, etc.). Transfer of your personal data to these third-party providers for the purposes listed below only occurs on the basis of your consent, if such is legally necessary (consent pursuant to Article 6 (1) point a of the GDPR).
Insofar as these third-party providers are domiciled outside of the EEA, we only transfer your data to the third country in question on the basis of your explicit consent pursuant to Article 49 of the GDPR.
6. ARE YOUR PERSONAL DATA TRANSFERRED TO THIRD PARTIES?
We transfer your personal data to the extent necessary to the following external service providers (processors):
All of our data processors only process your data on our behalf and on the basis of our instructions for the performance of the above services. Furthermore, we transfer your personal data to the extent necessary to the following recipients:
If the afore mentioned recipients of your personal data are located outside of the EEA and if the EU Commission has not determined that the country in question provides an adequate level of data protection, we ensure that the transfer occurs on the basis of standard contractual clauses (currently 2021/914/EC) or is otherwise in accordance with Articles 46, 47, or 49 of the GDPR.
7. Data processing in relation to newsletter subscriptions
We use a double opt-in process for you to be able to subscribe to our newsletter. This means that when registering for the newsletter you must first expressly confirm that you wish to receive our newsletter and that you consent to the related processing of your personal data. Subsequent to this, you receive a notification e-mail with a link, using which you reconfirm your registration for the newsletter.
8. HOW ARE PERSONAL DATA PROTECTED?
We take appropriate technical and organisational security measures to protect your personal data against unintentional or unlawful erasure, alteration, damage, or loss and against unauthorised transfer or unauthorised access. Above and beyond this, we and our employees are required to maintain data confidentiality.
9. Does the website use cookies?
Yes, we use cookies. Cookies are small text files which are temporarily stored on your computer and which your browser saves. Using cookies, the website can save important data. This makes it more comfortable for you to use the website.
Like most websites, insofar as you have given your consent, we use cookies for a variety of purposes to improve the use of the website for you. If you do not give your consent, we only record anonymous data, e.g. to be able to determine the total number of visitors on our website.
9.1 Google Analytics
Insofar as you give your consent, this website uses Google Analytics, a web analysis service of Google Inc. (“Google”). This analysis tool uses cookies to collect standard protocolling information and the visitor behaviour on our website in an aggregated form. The information on your usage of the website that is generated by this cookie is generally transferred to and saved on a Google server in the USA or in other countries outside of the EU.
The following information is collected by Google Analytics: browser, device type, device model, country, service provider, screen resolution (on mobile devices), dwell time, language, operating system, pages visited on the website. Google uses this information to analyse your usage of the website, in order to compile reports on website activities for us.
You can also reject the placement of cookies using your browser settings or download a browser plugin for this at http://tools.google.com/dlpage/gaoptout.
We use the technologies presented below of Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). The information on your usage of our website that is automatically collected by Google technologies is generally transferred and saved on a server of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. There is no adequacy decision of the European Commission for the USA. Our cooperation is based on the standard data protection clauses of the European Commission. Insofar as your IP address is recorded by Google technologies, prior to being saved on Google’s servers it is truncated by the activation of IP anonymisation. The full IP address is only transferred to a Google server and truncated there in exceptional cases. Insofar as no other information is indicated for the individual technologies, the data processing occurs on the basis of the agreement between joint controllers for the technology in question pursuant to Article 26 of the GDPR. For more information on data processing by Google, please see Google’s Privacy Policy.
Please note that – based on US laws such as the Cloud Act – the US authorities, such as intelligence services, may be able to access your personal data that are necessarily shared with Google when this service is used, on the basis of the Internet protocol (TCP).
Additional enrichment
In parallel with the use of Google Analytics, PNMB Brands GmbH also uses the service Leadfeeder, which is operated by Liidio Oy / Leadfeeder, Mikonkatu 17 C, 00100 Helsinki, Finland. Leadfeeder uses the list of IP addresses of website visitors provided by Google Analytics and links the list of IP addresses with information on the companies that use these IP addresses on the Internet. Due to truncation of the website visitors’ IP addresses already performed during use by Google Analytics, a direct link to persons is not established. A presumption of a personal link can result from the review of the related company information. For more information on Leadfeeder and the data collected, please see: www.leadfeeder.com/privacy/; for information on Leadfeeder and GDPR compliance, please see: help.leadfeeder.com/faqs-and-troubleshooting/is-leadfeeder-ready-for-gdpr.
GOOGLE ADS
For advertising purposes in the Google search results and on the websites of third parties, the so-called Google Remarketing cookie is placed upon visiting our website, which automatically enables interest-based advertising, by collecting and processing the data (IP address, time of visit, device and browser information, and information on your usage of our website) by a pseudonym cookie ID and on the basis of the pages you visited. Data processing going beyond this only occurs if you have activated the setting “Personalised advertising” in your Google account. In this case, if you are logged into Google when you visit our website, Google uses your data together with Google Analytics data to create and define target group lists for cross-device remarketing.
GOOGLE RECAPTCHA
For the purposes of protecting our web forms against abuse and spam from automated software (so-called bots), GOOGLE reCAPTCHA collects data (IP address, time of visit, browser information, and information on our usage of our website) and performs an analysis of your usage of our website via a so-called JavaScript and cookies. Additionally, other cookies saved by Google services in your browser are also analysed. The personal data from the entry fields of the form are not read or saved.
GOOGLE FONTS
In the interest of the uniform presentation of content on our website, data (IP address, time of visit, device and browser information) are collected by the script code “Google Fonts”, transferred to Google, and subsequently processed by Google. We have no control over this subsequent data processing.
YOUTUBE VIDEO PLUGIN
To link content of third parties, in the expanded data protection mode that we use, data (IP address, time of visit, device and browser information) are collected via the YouTube video plugin, transferred to Google, and subsequently processed by Google, only when you play a video.
9.2 Google Tag Manager
We use a Google service called “Google Tag Manager”. “Google” is a corporate group and consists of the companies Google Ireland Ltd. (provider of the service), Gordon House, Barrow Street, Dublin 4, Ireland and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, as well as other associated companies of Google LLC. We have concluded an order processing agreement with Google. Google Tag Manager is an auxiliary service and only processes personal data for technically necessary purposes. Google Tag Manager ensures the loading of other components, which may themselves collect data. Google Tag Manager does not access these data. For more information on Google Tag Manager, please see Google’s Privacy Policy. Please note that – based on US laws such as the Cloud Act – the US authorities, such as intelligence services, may be able to access your personal data that are necessarily shared with Google when this service is used, on the basis of the Internet protocol (TCP).
9.3 Google Remarketing
We also use the targeting technology of Google Remarketing of Google Inc., USA, on our website. This makes it possible to address Internet users who have visited our website with targeted product recommendations in the form of advertising banners on the websites of the Google partner network. Presentation of this advertising on our partners’ pages is based on cookies and an analysis of your previous usage behaviour. This analysis occurs under a pseudonym; no usage profiles are linked to your real name. You can refuse the collection of data by Google Inc. at any time using the following link: http://www.google.com/settings.
9.4 Facebook Pixel
This website uses Facebook Pixel from the social media network “Facebook” (Facebook Inc., 1601 S. California Ave, Palo Alto, California 94304, USA). This serves the purpose of presenting visitors to our website interest-based advertising when they visit the social media network Facebook. When visiting our website, a direct connection to the Facebook servers is established via Facebook Pixel. This transmits to the Facebook servers the fact that you have visited our website, and Facebook then links this information to your personal Facebook account. We would like to point out that as the provider of the website, we have no knowledge of the contents of the data transferred and their use by Facebook. For more information on the collection and use of data by Facebook and your related rights and opportunities to protect your privacy, please see Facebook’s privacy information at: https://www.facebook.com/about/privacy. Above and beyond this, we do not transfer any personal data of customers to Facebook. More information on your privacy rights and settings to protect your privacy can be found at: https://www.facebook.com/policy.php and https://www.facebook.com/help/186325668085084.
USE OF FACEBOOK PIXEL
We use Facebook Pixel within the framework of the technologies presented below of Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). Using Facebook Pixel, data (IP address, time of visit, device and browser information, and information on your usage of the website based on events that we predefine, such as visiting a website or newsletter subscription) are automatically collected and saved, on the basis of which user profiles are created using pseudonyms. To this end, upon visiting our website a cookie is automatically placed by Facebook Pixel, which automatically allows for recognition of your browser upon visiting other websites by way of a pseudonym cookie ID. Facebook collates this information with other data from your Facebook account and uses it to compile reports on website activities and to provide other services related to website and Internet usage, in particular personalised and group-based advertising.
The information on your usage of our website that is automatically collected by Facebook technologies is generally transferred and saved on a server of Facebook, Inc., 1601 Willow Road, Menlo Park, California 94025, USA. There is no adequacy decision of the European Commission for the USA. Insofar as data transfer to the USA falls under our scope of responsibility, our cooperation is based on the standard data protection clauses of the European Commission. More information on data processing by Facebook can be found in Facebook’s Privacy Policy.
FACEBOOK ANALYTICS
As part of Facebook Analytics, the data collected with Facebook Pixel on your usage of our website are used to prepare statistics on user activities on our website. Data processing occurs on the basis of an agreement on order processing by Facebook. The analysis of such data facilitates the optimal presentation and marketing of our website.
FACEBOOK ADS
We use Facebook Ads to advertise for this website on Facebook and on other platforms. We determine the parameters of the individual advertising campaigns. Facebook is responsible for the specific implementation, in particular the decision on placement of advertisements with individual users. Insofar as no other information is indicated for the individual technologies, the data processing occurs on the basis of an agreement between joint controllers pursuant to Article 26 of the GDPR. The joint control is limited to the collection of the data and their transfer to Facebook Ireland. Subsequent data processing by Facebook Ireland is not covered by this.
We use personalised advertising via Facebook Pixel Remarketing, on the basis of the pseudonym cookie ID placed by Facebook Pixel and the data collected on your user behaviour on our website.
We use Facebook Pixel Conversions to measure your subsequent user behaviour for web analysis and event tracking, in the event that you access our website from an advertisement by Facebook Ads. Data processing occurs on the basis of an agreement on order processing by Facebook.
9.5 LinkedIn Insight Tag
This website uses the Insight Tag from LinkedIn. The provider of this service is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Data processing with LinkedIn’s Insight Tag
Using LinkedIn Insight Tags, we receive information on the visitors to our website. If a website visitor is registered with LinkedIn, among other things, we can analyse key professional data (e.g. career level, company size, country, location, sector and career title) of our website visitors and thus better orient our page to the respective target groups. Furthermore, using LinkedIn Insight Tags, we can measure whether the visitors to our website make a purchase or take other action (conversion measurement). The conversion measurement can also occur on a cross-device basis (e.g. from PC to tablet). LinkedIn Insight Tags also offers a retargeting function, by way of which we can show our website visitors targeted advertising outside of the website, in the course of which no identification of the advertisement addressee occurs, according to LinkedIn.
Additionally, LinkedIn itself records so-called log files (URL, referrer URL, IP address, device and browser characteristics, and time of access). The IP addresses are truncated or (insofar as they are used to identify LinkedIn members on a cross-device basis) hashed (pseudonymised). Direct identifications of LinkedIn members are erased by LinkedIn after seven days. The remaining pseudonymised data are then erased within 180 days.
As the website operator, we cannot link the data collected by LinkedIn to specific individuals. LinkedIn saves the personal data on the website visitors that it collected on a server in the USA and uses them in the framework of its own advertising measures. For more information, please see LinkedIn’s privacy policy at: https://www.linkedin.com/legal/privacy-policy#choices-oblig.
Legal basis
The use of LinkedIn Insight occurs on the basis of Article 6 (1) point f of the GDPR. We have a legitimate interest in effective advertising measures, including social media. Insofar as consent has been obtained (e.g. consent to the use of cookies), processing takes place exclusively on the basis of Article 6 (1) point a of the GDPR; such consent may be withdrawn at any time. Data transfer to the USA is based on the standard contractual clauses of the European Commission. For more information, please see: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.
Opting out of the use of LinkedIn Insight Tag
You can opt out of the analysis of user behaviour and targeted advertising by LinkedIn using the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Members of LinkedIn can also control the use of their personal data for advertising purposes in the account settings. In order to prevent a linking of the data collected on our website by LinkedIn and your LinkedIn account, you must log out of your LinkedIn account before you visit our website.
9.6 Hotjar
Our website uses Hotjar to collect information on our users’ behaviour and their devices (e.g. IP address in anonymised form, device type, browser type, preferred language, etc.). Hotjar saves this information in a pseudonymised user profile. This information is not used for the identification of users. You can opt out of the storage of a user profile and information on your visit to our website and the placement of Hotjar tracking cookies by withdrawing the consent you have given. For more information on this, please see Hotjar’s privacy policy at: https://www.hotjar.com/legal/policies/privacy.
9.7 Adform pixel
We use Adform, a platform for digital media advertising, on our website. The service provider is the Danish company Adform A/S, Silkegade 3B, ST &1, 1113 Copenhagen, Denmark. For more information on the data that are processed by Adform, please see their privacy policy at: https://site.adform.com/de/privacy-center/platform/datenschutzrichtlinie-fuer-produkte-und-services/.
You can use this link to opt out of the placement of cookies: https://site.adform.com/de/privacy-center/website/datenschutz-opt-out/.
9.8 Teads Universal Pixel
We use Teads Universal Pixel (Teads Schweiz GmbH, Ausstellungsstrasse 50, 1020 Vienna) to track user behaviour. The installed Teads pixel sends a signal when a user visits our website. Teads can confirm whether it already knows this user or not. If Teads already knows the user, it is excluded from our campaign. If Teads does not know the user, Teads does nothing, as the pixel only reads users which already have the Teads cookie on their device and have thus consented to tracking. The only purpose of this pixel is to analyse whether the Teads cookie has already been installed on the user’s device. If it has been, the Teads cookie will then identify the Teads user which has visited our website and exclude it from our campaign.
The Teads pixel allows access to the following information and technical parameters of the device: current URL, Auctid parameter (optional parameter that Teads sends via the target URL), device, browser, and operating system. There is no transfer of personal data. The pixel is not used to collect or transfer personal data. Teads distributes the True Visits campaign using its own cookie pool and functions as a data processing controller for the provision of the Teads True Visits service. The cookies are placed on the websites of the Teads’ Publisher Network on the basis of consent and this consent can be proven by Teads at all times. The data are only analysed if such a cookie is already present on the user device prior to visiting the website. For more information, please see Teads’ privacy policy at: https://www.teads.com/privacy-policy/.
9.9 Borlabs Cookie
This website uses Borlabs Cookie, which places a technically necessary cookie (Borlabs cookie) to save your cookie settings.
The Borlabs cookie does not process any personal data.
The Borlabs cookie saves the consents that you give when you visit the website. If you wish to withdraw these consents, all you need to do is delete the cookie from your browser. When you visit/load the website again, you will be asked to give your consent for cookies again.
9.11 Vimeo
We use Vimeo as a real estate and broker plugin; for more information on Vimeo’s privacy policy, please see: https://vimeo.com/privacy.
10. Retention period
We only store your personal data as long as it is necessary to discharge our obligations to you. However, we generally store your personal data that is provided in relation to orders for a period of seven years following completion of contract, on the basis of storage obligations that apply to us.
11. What rights do you have?
As the subject of our data processing, you basically have the following rights vis-á-vis the respective data controller in relation to data processing as per (i) – (iii):
a) Right to information
You have the right to request information informally at any time in respect of what personal data on you that we process as a data controller, along with additional information such as the purposes of processing and recipients, information on the origin of the data, and information on automated decisions, including the logic involved. Furthermore, you also have the right to request information on whether your personal data are transferred to a third country or an international organisation, including the right of information on the appropriate safeguards pursuant to Article 46 of the GDPR.
b) Right to rectification and right to restriction of processing
You have the right to request the rectification or completion of incorrect or incomplete data. You have the right to request restriction of processing of the data, so that such data may only be processed with your consent or to assert, exercise, or defend legal claims or for the protection of the rights of other natural or legal persons or on the basis of important public interest, for example if the accuracy of the data is contested.
c) Right to data portability
You have the right to request that – insofar as such is technically feasible – you or a third party to be determined be provided with a copy of your personal data, insofar as such have been provided to us, in a structured, common, and machine-readable format.
d) Right to erasure
In certain circumstances, you can request the erasure of your data, for example if such data are not processed in accordance with the data protection regulations.
e) Right to object
You have the right to object to the processing of your personal data at any time, with a statement of the reasons. In this case, we will no longer process the relevant personal data, unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, or the processing serves to assert, exercise, or defend legal claims.
f) Right to withdraw consent
You have the right to withdraw your data protection consents at any time without the need to state the reasons, by e-mail at gs@jpi.at. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent before withdrawal. We will erase your data, insofar as there are no legal regulations requiring the storage of such.
g) Right to lodge a complaint
If you believe that the processing of your data violates your right to confidentiality or that your data protection claims have been violated in another way, you may lodge a complaint with the competent supervisory authority. In Austria, the competent authority is:
Austrian Data Protection Authority, Barichgasse 40–42, 1030 Vienna.
Without prejudice to this, you also have right to file suit with the regional court pursuant to § 29 (2) of the DSG and to seek other legal remedy.
12. Final provisions
We may update this privacy statement to take into consideration legal, technical, or business developments. If we update this privacy statement, we will take suitable measures to inform you of the changes that have been made.
This website contains links to the websites of third parties. We have no control over the content or data protection practices of these websites. Please read the respective data protection policies of the other websites that you visit.
Some of the personal data above are necessary for the proper provision of the website and the fulfilment of contractual and/or legal obligations which apply to us. If you refuse to provide us with the personal data that we must process for the provision of this website or to fulfil these obligations, it is possible that we will be unable to undertake processing for the afore mentioned purposes or provide some of the services listed.
(As of October 2024)