Privacy Policy

1 General information
1.1 Objective and Responsibility
1.2 Legal Bases
1.3 Data Subject Rights
1.4 Data Erasure and Duration of Storage
1.5 Security of Processing
1.6 Transfer of Data to Third Parties, Subcontractors and Third Party Providers

2 Concrete Data Processing
2.1 Collection of information for the use of the online offer
2.2 Contact form and contact via email
2.3 Links to other websites
2.4 Information about Google services
2.5 Google Tag Manager
2.6 Google Analytics
2.7 Consent Management (Clickskeks)
2.8 3D tour

3 Processing for the purpose of carrying out our business processes
3.1 Direct marketing
3.2 Existing customer advertising
3.3 Responding to Project Inquiries

4 Cookies
4.1 General Information
4.2 Cookie overview
4.3 Objection Options

5 Changes to the Data Privacy Policy

1 General information

1.1 Objective and Responsibility

This privacy policy informs you about the nature, scope and purpose of the processing of personal data in relation to our online offer and the associated websites, functions and content (hereinafter collectively referred to as “online offer” or “website”). Details on these processing activities can be found in section 2.
Details of data processing for the purpose of carrying out our business processes are described in section 3.
UBM Development AG (Laaer-Berg-Straße 43, 1100 Vienna, Austria) – hereinafter referred to as “Provider”, “we” or “us” – is the provider of the online offer and responsible for data protection.
Our online offer is provided by der interneX GmbH (Lagerstraße 15, 3950 Gmünd, Austria).
We have set up the following central point of contact for you, which you can contact if you have any questions about data protection or your rights as a data subject: datenschutz@ubm-development.com. No data protection officer has been appointed as there is no legal requirement.
The term ‘user’ encompasses all customers, interested people, employees and visitors of our online service.

1.2 Legal Bases

We collect and process personal data based on the following legal grounds:
a. Consent in accordance with article 6 paragraph 1 lit. a General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
b. Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to article 6 paragraph 1 lit. b GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
c. Processing to fulfil a legal obligation in accordance with article 6 paragraph 1 lit. c GDPR, meaning that e.g. the processing of data is required by law or other provisions.
d. Processing in order to protect legitimate interests in accordance with article 6 paragraph 1 lit. f GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.

1.3 Data Subject Rights

You have the following rights with regards to the processing of your data through us:
a. The right to lodge a complaint with a supervisory authority in accordance with article 13 paragraph 2 lit. d GDPR and article 14 paragraph 2 lit. e GDPR.
b. Right of access in accordance with article 15 GDPR
c. Right to rectification in accordance with article 16 GDPR
d. Right to erasure (‘right to be forgotten’) in accordance with article 17 GDPR
e. Right to restriction of processing in accordance with article 18 GDPR
f. Right to data portability in accordance with article 20 GDPR
g. Right to objection in accordance with article 21 GDPR
Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

1.4 Data Erasure and Duration of Storage

The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.

1.5 Security of Processing

We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
These security measures include in particular the encrypted transfer of data between your browser and our server.

1.6 Transfer of Data to Third Parties, Subcontractors and Third Party Providers

A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
If we use content, tools or other means from other companies (hereinafter collectively referred to as ‘third party providers’) whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.

2 Concrete Data Processing

2.1 Collection of information for the use of the online offer

When using the online offer, information is automatically transmitted to us by the user’s browser; this includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
The processing of this information is based on legitimate interests pursuant to Article 6 (1) (f) GDPR (e.g. optimization of the online offer) and to ensure the security of the processing pursuant to Article 5 (1) (f) GDPR (e.g. for the defense and reconnaissance of cyber attacks).
The information is automatically deleted 30 days after the end of the connection – i.e. use of the online offer – unless otherwise required by retention periods.
The collection of data and the storage of data in log files is absolutely necessary for the provision of the online offer. Therefore, there is no deletion, objection or correction option on the part of the user.

2.2 Contact form and contact via email

If you contact us, your data (name, contact details, if provided by you) and your message will be processed exclusively for the purpose of processing and processing your request. This data is processed by us on the basis of Art. 6 Paragraph 1 lit. a GDPR (consent) to process your request.
Any other use of the data takes place only on the basis of the user’s consent.

2.3 Links to other websites

While using some of our services, you will be automatically redirected to other websites.
Please note that this privacy policy does not apply there. The privacy policy of the linked website may differ considerably from this one.

2.4 Information about Google services

We use various services of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland on our website.
For more information on the individual concrete services of Google that we use on this website, please refer to the further privacy policy.
Through the integration of Google services, Google may collect information (including personal data) and process it. It cannot be ruled out that Google also transmits the information to a server in a third country.
The transmission to the USA depends on the function in which personal data is transmitted. As the responsible party, we ourselves may transfer data to Google in the USA for further use.
Currently, there is no adequacy decision pursuant to Art. 45 GDPR. However, the transfer can be based on standard contractual clauses. Google has committed to comply with the standard contractual clauses for the transfer of personal data to third countries (Standard Contractual Clauses – SCC).
More information about the Standard Contractual Clauses is available at
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractuals-clauses-scc_de
and at
https://policies.google.com/privacy/frameworks?hl=de
We ourselves cannot influence which data Google actually collects and processes. However, Google states that, in principle, the following information (including personal data) may be processed, among others:
– Log data (in particular the IP address)
– Location-related information
– Unique application numbers
– Cookies and similar technologies
Information on the types of cookies used by Google can be found at https://policies.google.com/technologies/types.
If you are logged into your Google account, Google may add the processed information to your account depending on your account settings and treat it as personal data.
Google states the following about this, among other things:
“If you are not signed into a Google Account, we store the data we collect with unique identifiers associated with the browser, app, or device you are using. This allows us to ensure, for example, that your language settings are maintained across all browser sessions.
If you are logged into a Google account, we also collect data that we store in your Google account and consider to be personal data.” (https://privacy.google.com/take-control.html)
You can prevent this data from being added directly by logging out of your Google account or also by making the appropriate account settings in your Google account. Furthermore, you can change your cookie settings (e.g. delete cookies, block cookies, etc.).
You can find more detailed information in the privacy notices of Google, which you can access here: https://www.google.com/policies/privacy/
You can find notes on Google’s privacy settings at https://privacy.google.com/take-control.html.

2.5 Google Tag Manager

We use the Google Tag Manager on our website. The Google Tag Manager is a service of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Through the Google Tag Manager, we can integrate various codes and services on our website in an orderly and simplified manner. The Google Tag Manager implements the tags or “triggers” the embedded tags. When a tag is triggered, Google may process information (including personal data) and process it. In doing so, it cannot be ruled out that Google also transmits the information to a server in a third country.
In particular, the following personal data is processed by the Google Tag Manager:
– Online identifiers (including cookie identifiers).
– IP address
In addition, you can find more detailed information about the Google Tag Manager on the websites https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/
as well as at
https://www.google.com/intl/de/policies/privacy/index.html (section “Data we receive based on your use of our services”).
Furthermore, we have concluded an order processing contract with Google for the use of the Google Tag Manager (Art. 28 GDPR). Google processes the data on our behalf in order to trigger the stored tags and display the services on our website. Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google.
If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation remains for all affected tracking tags that are integrated by the Google Tag Manager.
By integrating the Google Tag Manager, we pursue the purpose of being able to carry out a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services.
The legal basis for the processing of personal data described here as part of the measurement process is consent expressly granted by you in accordance with Art. 6 Para. 1 lit. a GDPR.
The legal basis for the processing of those data that are processed in the context of obtaining consent is our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. We have a legitimate interest in being able to prove that you have given your consent to the measurement procedure (Art. 7 (1) GDPR).

2.6 Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited (Gordon House Barclays Dublin Ireland – hereinafter “Google”), on the basis of your consent for the analysis, optimization and economic operation of our online offer pursuant to Article 6 (1) (a) GDPR. Google uses cookies and other technologies. The information generated by the service about the use of the online offer by users is transmitted to a Google server in the USA and processed there.
Google acts on our behalf within the framework of order processing pursuant to Article 28 GDPR. We have concluded a data protection agreement with Google that contains the EU standard data protection clauses.
We use Google Analytics with IP anonymization enabled.
Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you on future visits to the website. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/¬dlpage/gaoptout?hl=en.
The collected data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 14 months. Other data remains stored in aggregated form indefinitely.
Further information on data use by Google, settings and revocation options can be found on Google’s websites:
https://policies.google.com/technologies/partner-sites?hl=de (“Data use by Google when you use our partners’ websites or apps”).
https://policies.google.com/technologies/ads (“Data use for advertising purposes”).
https://adssettings.google.com/¬authenticated (“Managing information Google uses to serve ads to you”).

2.7 Consent Management (Clickskeks)

In order to obtain your consent to the storage of certain cookies on your end device and to document them in accordance with data protection regulations, we use within the scope of our legal obligation in accordance with Article 6 Paragraph 1 Clause 1 Letter c GDPR and thus also our legitimate interest in accordance with Article. 6 Paragraph 1 lit. f GDPR the Cookie Consent Manager “clickskeks”, the provider clickskeks GmbH & Co KG, Sechsschimmelgasse 14, 1090 Vienna / Austria.
The clickskeks cookie only sets technically necessary cookies. If our website is accessed, the following data is transmitted to clickskeks: your consent or the revocation of your consent to setting cookies, a cookie set by clickskeks in your browser, the cookie duration and version, domain and path of the WordPress website and the UID. The UID is a randomly generated ID and not personal information. clickskeks does not process any personal data.
If you would like to revoke your consent to the setting of certain cookies, simply delete the cookie in your browser. If you re-enter/reload the website, you will be asked again for your cookie consent.
Detailed information on the data protection regulations of the clickskeks can be found at: https://www.clickskeks.at/datenschutz

2.8 3D tour

On our website we offer the possibility of a virtual tour to get to know the Adler Lodge also contactless. The provider is WOOWSTUDIO s. r. o. (Černyševského 26, 851 01 Bratislava).
For details on data protection at WOOWSTUDIO, please refer to the provider’s privacy policy at https://product.woowstudio.com/privacy-policy/.
By using the service, the following services are loaded automatically:
– Google Fonts (fonts.googleapis.com)
– Cloudflare (cloudflare.com)
The legal basis for the processing is consent in accordance with Art. 6 para. 1 lit. a GDPR.

3 Processing for the purpose of carrying out our business processes

3.1 Direct marketing

If you have given us your consent, we will inform you regularly by e-mail about new offers. We will use your name and e-mail address for this purpose. The legal basis for data processing is Art. 6 para. 1 UAbs. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future, e.g. via the link at the end of each e-mail.
Our newsletter is only sent by e-mail with your prior express consent according to the double opt-in principle: after registering for the newsletter on our website, you will receive an e-mail asking you to confirm your newsletter registration. This ensures that no third party has misused your data.
When you register for the newsletter, we also obtain your consent to newsletter tracking for the purpose of personalised advertising and market research by us. With the help of so-called tracking pixels or web beacons and links, each of which is linked to an individual ID, we collect the following personal tracking information in connection with the use of our newsletter:
• Opening the newsletter, clicking on the links contained therein, submitting a form on our website after clicking on a link contained in the newsletter (along with the time of these actions).
• Type of terminal device used when you call up images in the newsletter or click on links
• Behaviour on our website when you access it via a link from our newsletter (along with the time of these actions)
• Location of access when you access images in the newsletter or click on links (by assigning your IP address, which we do not store).
We save this data to your user profile, which is assigned to the data entered when you registered for the newsletter. We use this data to evaluate and optimise our e-mail marketing and for the purposes of personalised advertising and market research. This enables us to send you personalised product, service and offer information in our newsletter that is of particular interest to you. You can revoke your consent to this data processing at any time with future effect by unsubscribing from the newsletter. An isolated deactivation of the newsletter tracking is (currently) technically not possible. We delete the tracking data when you unsubscribe from our newsletter. Data that has been stored by us for other purposes remains unaffected by this.

3.2 Existing customer advertising

Insofar as you have already made use of services from us against payment, we may inform you from time to time by e-mail or letter about similar services from us (in particular new offers), unless you have objected to this.
The legal basis for the data processing is Art. 6 para. 1 UAbs. 1 lit. f GDPR. Our legitimate interest lies in direct advertising (recital 47 GDPR). You can object to the use of your e-mail address and postal address for advertising purposes at any time without additional costs with effect for the future.

3.3 Responding to Project Inquiries

In the case of inquiries about projects from developers, we pass on the data provided in your inquiry to the developer or broker of the respective project, insofar as this is necessary or beneficial to answer your inquiry and/or to carry out contractual or pre-contractual measures.

4 Cookies

4.1 General Information

Cookies are information transmitted by our web server or third-party web servers to the users’ devices where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
In the case that users do not want that cookies are stored on their device, they will be asked to disable the corresponding option in their browser’s system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.

4.2 Cookie overview

Accept Cookies

4.3 Objection Options

Accept Video Cookies

5 Changes to the Data Privacy Policy

We reserve the right to change this Data Privacy Policy with regards to the data processing, in order to adapt it to changed legal situations, to changes of the online service or of the data processing.
If users’ consents are required or if elements of the Data Privacy Policy contain provisions in regards to the contractual relationship with the users, the changes will only be made with the consent of the users.
Users are requested to keep themselves informed about the content of this Data Privacy Policy on a regular basis.

Last revised: April 2023