Privacy Agreement

What does the FREEONTOUR Privacy Policy apply to?
This Privacy Policy contains information on how we, Caravaning Customer Connect GmbH, process personal data of our users ('you') and which personal data is processed.
... further information

Who is responsible for processing my personal data?
Caravaning Customer Connect GmbH
... further information

Is there a data protection officer and how can I reach this officer?
privacy@freeontour.com; www.deutsche-datenschutzkanzlei.de
... further information

What does data protection mean?
Data protection means that we will only process your personal data if we have legal permission or your consent to do so.
... further information

For which purposes will my personal data be processed?
...to provide you with our FREEONTOUR services in accordance with our website and the FREEONTOUR customer card and to inform you about the products and services of Erwin Hymer Group AG&Co KG and its partners. 
... further information

Will we pass on your data to third parties?
... only with your consent, except for situations where such transfer is necessary for the performance of FREEONTOUR services. 
In all other respects, we will only process your data within the Erwin Hymer Group AG, provided that you do not object to such processing.
... further information

FREEONTOUR Privacy Policy

1. What does the FREEONTOUR Privacy Policy apply to?

This Privacy Policy contains information on how we, Caravaning Customer Connect GmbH, process personal data of our users ('you') and which data is processed when you visit our website either with or without registering, as well as when you apply for and use the FREEONTOUR customer card.

2. Who is responsible for processing my personal data?

Caravaning Customer Connect GmbH

Holzstraße 19
D-88339 Bad Waldsee/GERMANY
Email: service@freeontour.com
Web: www.freeontour.com
telephone: +49 (0) 7524 999 9533

is responsible for processing personal data on our website in accordance with Article 4(7) of the EU General Data Protection Regulation (GDPR) and when the FREEONTOUR customer card is used in accordance with this Privacy Policy (see also our publication details).

3. Is there a data protection officer and how can I reach this officer?

You can contact our data protection officer directly:

External Data Protection Officer for Caravaning Customer Connect GmbH 
as defined in Article 37 GDPR in conjunction with § 38 of the German Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG):

Stefan Fischerkeller
Deutsche Datenschutzkanzlei
Office Bodensee
www.deutsche-datenschutzkanzlei.de
Contact details for the data protection officer via email: privacy@freeontour.com or through the data protection website: www.deutsche-datenschutzkanzlei.de

4. What does data protection mean?

Data protection means that we will only process your personal data if we have legal permission or your consent to do so.

Some essential terms for data protection are explained below:

personal data is all data that can be related to you personally, e.g. name, address, email addresses, information about your use of our website (see point 6 below).

Processing is any operation related to personal data. Processing operations include collecting, recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing or destroying personal data.

A group of undertakings means a controlling undertaking and its controlled undertakings.

The main law for the protection of your personal data is the General Data Protection Regulation of the European Union (GDPR). All those responsible for processing personal data in the EU must comply with the GDPR.

5. For which purposes will my personal data be processed?

We basically process your personal data in order to provide our FREEONTOUR services in accordance with our website and the FREEONTOUR customer card for you, to protect our own legitimate interests, and to inform you about the products and services of the Erwin Hymer Group AG group of companies and the partner companies participating in the FREEONTOUR system(consisting of web portal and customer card). The purposes of and legal bases for processing the data differ depending on which of our services you use, namely

  • if you visit our website for information purposes without registering (see point 6 below),
  • if you use our FREEONTOUR web portal after registering (see point 7 below), 
  • when applying for and using the FREEONTOUR customer card (see point 8 below),
  • when accessing our newsletter (see point 9 below),
  • based on the integration of tracking and social media technologies (see point 10 below),
  • when you use the FREEONTOUR app (see point 11 below) and
  • due to the division of labour within the Erwin Hymer Group AG, to which we belong (see point 12 below).

6. Visiting our website without registering and contacting us by email

6.1 Informational use of our website

If you only use our website for information purposes, i.e. if you do not register or if you provide information to us in another way, we will only collect the personal data that your browser transmits to our server. If you would like to view our website, we will collect the following data:

  • IP address,
  • date and time of the request,
  • time zone difference to Greenwich Mean Time (GMT),
  • content of the request (specific page),
  • access status/HTTP status code,
  • the data volume transferred at any time,
  • the website from which the request has originated,
  • browser,
  • operating system and its interface,
  • language and version of the browser software, and
  • your approximate location data, which we derive from the data listed above.

Purpose and legal basis

The purpose of processing this data is to show you our website and to ensure stability and security. The legal basis is article 6(1), sentence 1 under f) of the GDPR. Accordingly, the processing of personal data in order to safeguard our legitimate interests is lawful unless the interests, fundamental rights or freedoms of the data subject prevail.

This personal data is only stored for the duration of your visit to our website.

6.2 Contacting us by email or using the contact form on our website ('Submit a request')

If you contact us by email or through a contact form, we will process 

  • the matter you have communicated to us and
  • your email address.

This data is processed in order to be able to answer your questions. Once it is no longer necessary to store this data, we will either delete it, or we will restrict its processing if we are legally obliged to keep the data. The legal basis for these processing operations is article 6(1), sentence 1 under f) of the GDPR, unless there are legal obligations as regards keeping the data, in which case the legal basis for storing the data is article 6(1), sentence 1 under c) GDPR; the latter states that processing is lawful if it is necessary for compliance with a legal obligation.

7. Registering for the FREEONTOUR web portal

7.1 If you would like to use our FREEONTOUR web portal, you will have to register by entering your name (with form of address), your email address, the vehicle information requested (whether you use a recreational vehicle and which type you use), a password of your own choice and your user name which you can select freely ( 'registration details'). You do not have to use your real name as your user name; a pseudonym is acceptable. Entering the registration details is mandatory; you can provide any other information voluntarily by using our portal.

7.2 We use the 'double opt-in' procedure for registration. This means that, after you have entered your registration details, we will send an email to the email address you have provided, asking you to confirm your registration. If you do not confirm your registration, your details will be blocked and deleted after the statutory storage periods have expired (at least before the limitation period for any claims has expired). In addition, we store the IP addresses you use and the times at which you enter your registration details and the confirmation. The purpose of the procedure is to prove that you have registered and, if necessary, to resolve any misuse of your personal data. The legal basis for this is article 6(1), sentence 1 under f) of the GDPR.

7.3 If you use our FREEONTOUR web portal, we will store your data that is necessary for us to perform the contract until you permanently delete your access. Furthermore, we will store any data that you provide voluntarily for the duration of your use of the portal, unless you delete it beforehand. You can manage and change all details in the protected customer area. The legal basis is article 6(1), sentence 1 under f) of the GDPR.

7.4 If you use the FREEONTOUR web portal, your data may become accessible to other participants of the portal in accordance with the performance of the contract. Non-registered members will not receive any information about you, unless you explicitly give consent. All registered members can see your user name and, if applicable, your photo, regardless of whether you have authorised them or not. Any content you make available to other users through other means than sending a private message can be viewed by third parties. If you post any contributions in public groups, such posts will be visible to anyone who visits the web pages of the FREEONTOUR web portal, even without registering.

7.5 In order to prevent unauthorised access by third parties to your personal data, the connection is encrypted using TLS technology.

7.6 You can make public comments about the content of the FREEONTOUR web portal. Your comment will be published, accompanied by your user name. We recommend using a pseudonym instead of your real name. Your user name and email address is required; any further information is voluntary. If you make a comment, we reserve the right to continue to store your IP address and we will delete it as soon as storing it is no longer required. Such storage is necessary for us to enable us to defend ourselves against liability claims should any unlawful content be published. We need your email address in order to contact you if a third party objects to your comment, claiming it to be unlawful. The legal bases are article 6(1), sentence 1 under b) and f) of the GDPR. Any comments will not be reviewed before publication. We reserve the right to delete comments if third parties object to them, claiming they are unlawful.

You will be informed when other users leave a comment on your post. You can unsubscribe from such notifications at any time by emailing service@freeontour.com. We will store your personal data, including email address, time of registration for the service and your IP address until you have unsubscribed from the notification service.

7.7 If you delete your user profile from the FREEONTOUR Internet portal, your public statements will remain visible to all readers, but your account will no longer be accessible. All other data will be deleted. 

7.8 Using Facebook to log in

You can simplify registration and subsequent login to the FREEONTOUR web portal by using your Facebook login data as your login. If you use this method, we will obtain the basic user data laid down in your Facebook user account (the data that is publicly visible in the social network www.facebook.com) as well as your Facebook user name, your email address, Facebook ID and the Avatar URL from Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, USA) or Facebook Ireland Limited (Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland) and we will use this data, to the extent necessary, to justify, implement and process the use of the portal in accordance with the FREEONTOUR Terms of Use and this Privacy Policy.

8. FREEONTOUR customer card

If you apply for the FREEONTOUR customer card, we will process the following data relating to you in order to provide you with the service associated with the customer card:

  • Your registration details pursuant to point 7.1 of the FREEONTOUR Privacy Policy together with your date of birth,
  • your postal address for sending you the customer card, 
  • your telephone number for quick clarification if we have any questions about your registration details, and
  • in relation to your vehicle, the make of your recreational vehicle, the model, its initial registration, your dealer, the chassis and serial numbers.

After entering and checking this data, we will send you your FREEONTOUR customer card in accordance with our FREEONTOUR Terms of Use. The FREEONTOUR customer card bears a card number linking it to your name and your data referred to above.

The card is used to record your purchases from partner companies participating in the FREEONTOUR customer card and the locations and dates of your respective purchases. This information is used to calculate a bonus amount which will be credited to your bonus balance for payment in accordance with the FREEONTOUR Terms of Use.

The data pursuant to this point 8 will hereinafter be referred to as 'card data'.

The legal basis for processing your card data is article 6(1), sentence 1 under b) and f) of the GDPR.

9. Newsletter

The FREEONTOUR web portal offers you the option of subscribing to our newsletter which provides up-to-date information about our company, products and services of the Erwin Hymer Group AG&CoKG and the partner companies participating in the FREEONTOUR web portal. To register for the newsletter, we use the double opt-in procedure as described in 7.2. 

Giving your consent to receive the newsletter is always voluntary. You can revoke your consent at any time. You can use all other functions of our website regardless of whether you consent to receiving the newsletter, including the functions relating to registration (see point 7 above) and the FREEONTOUR customer card (see point 8 above). 

In order for you to receive the newsletter, we only process your name, gender (for the form of address) and email address so that we can send you the newsletter and address you personally. The legal basis for this processing of your personal data is article 6(1), sentence 1 under a) of the GDPR. You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can state your revocation under the Profile settings in the FREEONTOUR portal or by emailing service@freeontour.com or by sending a message to the contact details listed in the publication details.

Newsletter tracking:

When sending our newsletter we analyse your user behaviour as follows: The emails sent contain small files, e.g. web beacons or tracking pixels (single-pixel image files). They are also stored on our website. For analysis purposes, we link the data mentioned in point 6 and the web beacons or tracking pixels to your email address and an individual ID. Links contained in the newsletter can also contain this ID. The data collected is always pseudonymised, i.e. the IDs are not linked to your other personal data; this rules out any possibility of directly linking the data or the IDs to any specific person. We will not remove the pseudonymisation. The legal basis for newsletter tracking is article 6(1), sentence 1 under f) of the GDPR.

You can object to this newsletter tracking at any time by emailing your objection to service@freeontour.com. The information is stored for as long as you continue to be a subscriber to the newsletter. After you have unsubscribed or indicated your objection to such tracking, we will only store the data anonymously for statistical purposes. Such tracking is not possible if you have deactivated the displaying of images in your email program by default. In this case, you will not see the entire newsletter and you may not be able to use all functions. If you get the images to display manually, the tracking will be performed.

10. Tracking and social media

To increase the ease of use of our website and the FREEONTOUR services, we use tracking technologies and have incorporated social media into our website. In this regard, your personal data will be processed regardless of whether you are using our website with or without registration. This means the following for your personal data:

10.1 Cookies

a) Cookies are stored on your computer when you use our website. Cookies are small text files that are assigned to the browser you are using and are stored on your hard drive. Cookies enable the party that places the cookie (in this case: us) to receive certain information. Cookies cannot execute programs or transmit viruses to your computer. They serve to generally make the use of websites more user-friendly and effective. The legal basis for this is your consent - which you can revoke at any time - pursuant to article 6(1), sentence 1 under a) of the GDPR which you give at the start of your visit to our website or pursuant to article 6(1), sentence 1 under f) of the GDPR.

b) The types of cookies listed below are used on this website; their scope and operation are explained below:

  • Transient cookies (see a)
  • Persistent cookies (see b).

aa) Transient cookies are deleted automatically when you close your browser. Session cookies are specific examples of such cookies. They store a 'session ID' which can be used to attribute various requests from your browser to the shared session. This enables your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close your browser.

bb) Persistent cookies are automatically deleted after a period of time specified by us, which may vary depending on the cookie in question. You can delete the cookies through the security settings of your browser at any time. By deleting a cookie, you simultaneously revoke your consent to the processing of such cookie.

c) You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. Please note that in this case you may not be able to use all the functions of our website.

10.2. Google Analytics

a) This website uses Google Analytics, a web analytics service provided by Google LLC ('Google'). Google Analytics uses 'cookies', i.e. text files that are placed on your computer and help to analyse how you use the website. As a rule, the information about your use of this website generated by the cookie will be transmitted to a Google server in the US and stored there. However, if IP anonymisation is enabled on this website, Google will first shorten IP addresses in member states of the European Union or other states which are party to the Agreement on the European Economic Area. The full IP address will only be transmitted in exceptional cases to a Google server in the US and shortened there. The operator of this website has commissioned Google to use this information to analyse your use of the website, to compile website activity reports and to provide other services relating to the use of the website and internet usage to the operator of the website.

b) The IP address transmitted by your browser for the purpose of Google Analytics will not be merged with other data by Google.

c) You can prevent the storing of cookies by setting your browser software accordingly; however, we would like to point out that this may mean that you will not be able to make full use of all the functions of this website. In addition, you can prevent Google from recording and processing data generated by the cookie relating to your use of the website (including your IP address) by downloading and installing the browser plug-in available under the following link: 
https://tools.google.com/dlpage/gaoptout?hl=en.

You can also prevent Google Analytics from recording data by clicking on the following link. The link will set an opt-out cookie that prevents the future recording of your data when you visit this website: Deactivate Google Analytics.

d) This website uses Google Analytics with the extension '_anonymizeIp()'. This means that IP addresses are further processed in a shortened form, thus excluding the possibility of their being linked to a particular individual. Any data collected about you that can be traced to you personally is excluded immediately and personal data is deleted immediately.

e) We use Google Analytics in order to be able to analyse and regularly improve the use of our website. We can use the statistics obtained to improve our website 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 subscribed to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for using Google Analytics is article 6(1), sentence 1 under f) of the GDPR.

f) Information about the third-party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, fax: +353 (1) 436 1001. User conditions: http://www.google.com/analytics/terms/us.html, summary of data protection: http://www.google.com/intl/us/policies/privacy, as well as the privacy statement: http://www.google.com/intl/us/policies/privacy.

10.3 Piwik

a) Our website also uses the Piwik Pro web analysis service in order to be able to analyse and regularly improve the use of our website. We can use the statistics obtained to improve our services and arrange them such that they are more interesting for you as a user. The legal basis for our use of Piwik is article 6(1), sentence 1 under f) of the GDPR.

b) Cookies (see point 11.1 above for further details) are stored on your computer to enable this analysis. The party responsible stores the information thus collected exclusively on their servers in Germany. You can stop the analysis by deleting existing cookies and preventing cookies from being stored on your computer. We would like to point out that, if you prevent cookies from being stored, you may not be able to make full use of this website. You can prevent cookies from being stored by adjusting the relevant settings in your browser. 

You can prevent the use of Piwik by removing the following checkmark and activating the Opt-out plug-in:

c) This website uses Piwik with the extension 'AnonymizeIP'. This means that IP addresses will be further processed in a shortened form so that the possibility of their being traced back to a specific individual is ruled out. The IP address transmitted by your browser by means of Piwik will not be merged with other data we collect unless you give explicit consent for this (see point 13 below).

d) The Piwik program is an open-source project. You can obtain information about data protection from the third party provider on http://piwik.org/privacy/policy.

10.4 Google Adwords Conversion

a) We use Google Adwords services to draw attention to our attractive products and services on external websites using means of advertising (i.e. Google Adwords). The data collected through these advertising campaigns enables us to determine how successful individual means of advertising are. We do this in order to show you advertising which is of interest for you, to arrange our website such that it is more interesting for you and to calculate our advertising costs equitably.

b) Google delivers these advertisements through 'Ad Servers'. To do so, we use Ad Server cookies, which can measure certain parameters to gauge success, such as the degree to which advertising is actually displayed or clicks by users. If you have reached our website via a Google ad, Google Adwords will store a cookie on your PC. As a rule, these cookies are only effective for 30 days and are not intended to identify you personally. The following analysis values are usually stored for this cookie: unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (indicating that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie.

c) These cookies enable Google to recognise your web browser. If a user visits certain pages of an AdWords customer's website and the cookie stored on their computer has not yet expired, Google and the customer can identify that the user clicked on the ad and was directed to the page in question. Since each Adwords customer is assigned a different cookie, cookies cannot be traced via the websites of Adwords customers. We do not collect or process any personal data as part of the advertising measures ourselves. We only receive statistical analyses from Google. We can use these analyses to identify which of the advertising measures used are particularly effective. We do not receive any further data from the use of the means of advertising and, in particular, we cannot identify users based on this information.

d) Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. Since we have no influence on the extent and further use of the data collected by Google by means of this tool, this information is based on the knowledge that is available to us: The integration of AdWords Conversion tells Google that you have accessed the relevant part of our website or clicked on an advertisement from us. If you have registered with a Google service, Google can attribute the visit to your account. Even if you have not registered with Google or have not logged in, there is a possibility that the provider may discover your IP address and save it.

e) There are several options for you to prevent participation in this tracking procedure: 

  • either by adjusting the relevant setting in your browser software, where the suppression of third-party cookies in particular will ensure that you will not receive advertisements from third parties; 
  • or by disabling conversion tracking cookies by setting your browser to block cookies from the "www.googleadservices.com" domain, https://www.google.de/settings/ads; this setting will be deleted when you delete your cookies; 
  • or by disabling the displaying of interest-based advertisements from providers that are part of the About Ads self-regulatory campaign via the link http://www.aboutads.info/choices; this setting will be deleted when you delete your cookies; 
  • or by permanent deactivation in your Firefox, Internet Explorer or Google Chrome browser under the link http://www.google.com/settings/ads/plugin. We would like to point out that this may mean that you will be unable to make full use of all the functions of this website.

f) The legal basis for processing your data is article 6(1), sentence 1 under f) of the GDPR. You can find further information about data protection by Google here: https://policies.google.com/privacy?hl=en and https://services.google.com/sitestats/en.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at https://www.networkadvertising.org/ Google has subscribed to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

10.5 Remarketing

Remarketing
Besides Adwords Conversion we use the Google Remarketing application. It is a technique we use to contact you again. This application enables our advertisements to be shown to you during your further use of the internet after you have visited our website. This is done by means of cookies stored in your browser, which Google uses to record and analyse your usage behaviour when you visit various websites. It enables Google to determine that you have previously visited our website. According to its own statements, Google does not merge the data collected for the purposes of remarketing with your personal data which may be stored by Google. In particular, according to Google, pseudonymisation is used for remarketing.

The legal basis for processing the data is article 6(1), sentence 1 under f) of the GDPR.

You can deactivate the storage of cookies in your browser settings and/or object to recording for the purpose of Google Remarketing by means of options made available by Google, see https://www.google.com/policies/technologies/ads/.

10.6 New Relic web analysis service

We use New Relic, a web analytics service provided by New Relic Inc ('New Relic'). Data is collected and stored to create user profiles using pseudonyms. These profiles are used to analyse user behaviour and to adapt the website of Caravaning Customer Connect GmbH to suit requirements. Cookies are used for this purpose. Cookies are small text files that are stored locally on the user's computer and thus enable recognition when the Caravaning Customer Connect GmbH website is visited again. The pseudonymised user profiles are not merged with personal data about the bearer of the pseudonym unless the user has separately given explicit consent for this.

The integration of the plug-in provides New Relic with the information that a user has accessed the corresponding page of the website. If the user has logged in to New Relic, New Relic can attribute the visit to the user’s account with New Relic. If a user is not a member of New Relic, it is still possible for New Relic to find out and store the user’s IP address.

The user can object to the collection and storage of data by New Relic at any time with effect for the future by deactivating the cookies in their browser settings. However, Caravaning Customer Connect GmbH would like to point out that, as a result, it may not be possible to make full use of all functions of this website. The legal basis for the processing of personal data is article 6(1), sentence 1 under f) of the GDPR.

Further information about New Relic can be found on www.newrelic.com. New Relic's Data Privacy Notice can be found on http://newrelic.com/privacy

10.7 Use of affilinet 

We have integrated components of the affilinet company with our website. Affilinet is a German affiliate network that offers affiliate marketing. Affilinet is provided by affilinet GmbH, Sapporobogen 6-8, 80637 Munich, Germany. Affiliate marketing is a web-based form of sales which enables commercial operators of websites, referred to as 'merchants' or 'advertisers', to display advertisements (which are usually paid for by click or sale commission) on third-party websites, i.e. websites of sales partners who are also referred to as 'affiliates' or 'publishers'. The merchant makes a means of advertising, i.e. an advertising banner or other suitable means of internet advertising, available via the affiliate network, after which an affiliate integrates the means of advertising into its own website or advertising takes place via other channels, such as keyword advertising or email marketing.

Affilinet places a cookie on the data subject’s IT system. An explanation of what cookies are has been given above. The Affilinet tracking cookie does not store any personal data. Only the identification number of the affiliate, i.e. the partner who has referred the potential customer, as well as the sequential number of the visitor to a website and the means of advertising that has been clicked are stored. This data is stored in order to handle commission payments between a merchant and the affiliate via the affiliate network, i.e. Affilinet.

The data subject can prevent our website from placing cookies as described above at any time by adjusting the relevant settings in the web browser they use and can thus permanently object to the placing of cookies. Such web browser settings would also prevent Affilinet from placing a cookie on the data subject’s IT system. In addition, cookies already placed by Affilinet can be deleted at any time by means of a web browser or other software programs.

Affilinet's current privacy policy can be found on https://www.awin.com/us/legal.

10.8 The use of images from Getty Images 

We have integrated components of the Getty Images company into our website. The Getty Images components are provided by Getty Images International, 1st Floor, The Herbert Building, The Park, Carrickmines, Dublin 18, Ireland. Getty Images is an American visual media company. A visual media company is a company which offers images and other visual material to the market. As a rule, visual media companies market photographs, illustrations and film footage. A variety of customers, in particular website operators, editorial offices of print and TV media and advertising agencies, obtain licenses for the images they use from visual media companies.

Getty Images allows the embedding of stock images (free of charge if relevant). Embedding is the integration of certain external content, for example text, video or image data, which is provided by an external website and then appears on the operator's own website. An 'embed code' is used for this embedding. An embed code is an HTML code that is integrated into a website by a website operator. If an embed code has been integrated by a website operator, the external content of the other website is displayed immediately by default as soon as a website is visited. To display the external content, it is loaded directly from the other website. Getty Images has made more information about embedding content available on http://www.gettyimages.com/resources/embed

The technical implementation of the embed code that enables images from Getty Images to be displayed transmits the IP address of the internet connection through which the data subject accesses our site to Getty Images. Getty Images also records our website, the type of browser used, the browser language, the time and the duration of access. In addition, Getty Images may collect navigation information, i.e. information about which pages of our website were visited by the data subject and which links the data subject clicked, and other interaction engaged in by the data subject while visiting our website. This data can be stored and analysed by Getty Images.

You can find more information and Getty Images' current privacy policy on http://www.gettyimages.com/enterprise/privacy-policy

10.9 Social Media

a) You can use social media functions on our website.

These services are provided by the following companies:

  • Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA,
  • Twitter Inc., 1355 Market St., Suite 900, San Francisco, CA 94103, USA,
  • Pinterest Europe Ltd., Palmerston House, 2nd Floor Fenian Street, Dublin 2, Ireland,
  • Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA,
  • YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
  • WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 (if you live in the European Union or in a member state of the European Economic Area; otherwise the service is provided by: WhatsApp Inc. 1601 Willow Road Menlo Park, California 94025 USA).

b) You can identify the provider of the plug-in you are currently using by the marking on the box via its initial letter or logo. We offer you the option of communicating directly with the provider of the plug-in via the button. The provider of the plug-in will only receive the information that you have accessed the corresponding website of our online offer if you click on the marked field, thereby activating it. 

c) If you use these functions, the data referred to in point 6 of this statement will be transmitted to the service providers (if you use the WhatsApp functionality: this will also apply to the data pursuant to point 13 of this privacy policy; according to WhatsApp, your location data and WhatsApp activities are also registered and analysed). In the case of Facebook and according to Facebook, IP addresses are anonymised immediately after being collected in Germany. By activating the plug-in, your personal data will be transmitted to the respective plug-in provider and stored there (in the USA for US providers). Since the provider of the plug-in mainly collects data via cookies, we recommend that you use your browser's security settings to delete all cookies before clicking on the social media plug-ins. 

d) We have no influence on the data collected and the data processing procedures, nor are we aware of the full scope of data collection, the purposes of processing or the storage periods. We have no information regarding the deletion of the data collected by the provider of the plug-in either. This also applies if you use WhatsApp functionality to communicate with others; the communication service is then provided solely by WhatsApp. This means that we have no means of influencing the reliability and security of the communication. Please contact the service provider in question for further information.

e) The provider of the plug-in stores the data collected about you as user profiles and uses these profiles for the purposes of advertising, market research and/or to design its website based on actual demand. Such an evaluation is carried out (even for users who have not logged in) in particular in order to display demand-oriented 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 and you should contact the respective provider of the plug-in if you wish to exercise this right. We offer you the opportunity to interact with social networks and other users through the plug-ins, enabling us to improve our website and make it more interesting for you as a user. The legal basis for the use of plug-ins is article 6(1), sentence 1 under f) of the GDPR.

f) Data is transferred regardless of whether you have an account with the provider of the plug-in provider or whether you have logged in there. If you have logged in with the provider of the plug-in, your data that we have collected will be directly attributed to your existing account with the provider of the plug-in. If you press the activated button and, for example, link the page, the provider of the plug-in will also store this information in your user account and share it publicly with your contacts. We recommend that you log out as a rule after using a social network, especially before activating the button, so as to enable you to avoid such attribution to your profile with the provider of the plug-in.

g) Further information on the purpose and scope of data collection and processing by the provider of the plug-in can be found in the privacy policies or data protection statements of these providers listed below. They will also provide you with further information about your rights in this regard and about optional settings to protect your privacy:

10.10 Integration of Google Maps

a) We use Google Maps on our website. This enables us to display interactive maps directly on the website and enables you to use the map function conveniently.

b) If you visit our website, Google LLC. (hereinafter:  Google) will be informed that you have accessed the corresponding page of our website. In addition, the data referred to in point 6 of this statement will be transmitted. This is done regardless of whether Google has made a user account available that you have logged in to or there is no user account. If you are logged in to Google, your data will be directly attributed to your account. If you do not want such attribution to your Google profile, log out before activating the button. Google stores your data as user profiles and uses these profiles for the purposes of advertising, market research and/or to design its website based on actual demand. Such an evaluation is carried out (even for users who have not logged in) in particular in order to provide demand-oriented 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 and you should contact Google if you wish to exercise this right.

c) Further information on the purpose and scope of data collection and processing by the provider of the plug-in can be found in the provider’s privacy policy. This will also provide you with further information about your rights in this regard and about optional settings to protect your privacy: https://policies.google.com/privacy. Google also processes your personal data in the USA and has subscribed to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

10.11 Use of RSS feeds

Our website uses RSS feeds to keep users continuously informed about current topics. 

RSS is the acronym of 'Really Simple Syndication'. This is an electronic message format. The user needs an 'RSS reader' to be able to use the feed. Various RSS readers are available for all operating systems. Some browsers allow the use of RSS feeds without the need to install any further programs.

11. The FREEONTOUR app

11.1 In addition to our online offer, we have a mobile app that you can download to your mobile device. Further information about the collection of personal data when using our mobile app is given below. 

11.2 When downloading the mobile app via an App Store, the necessary information is transferred to the App Store, i.e. specifically your user name, email address and customer number of your account, time of downloading and the individual device code number. We cannot influence the collecting of this data and are not responsible for it. We process the data only to the extent necessary for downloading the mobile app to your mobile device. 

11.3 While the mobile app is being used, we collect the personal data identified in point 6 in order to enable comfortable use of its functionality. 

We also need your device identification, the unique number of the end device (IMEI = International Mobile Equipment Identity), the unique number of the network subscriber (IMSI = International Mobile Subscriber Identity), your mobile phone number (MSISDN), your MAC address for wireless network use, the name of your mobile end device and your email address. The legal basis for this is article 6(1), sentence 1 under b) and f) of the GDPR.

11.4 Collection of your location data

We also offer 'Location Based Services' that enable us to suggest special offers to you, tailored to your respective location. You cannot use this functionality until you have indicated in a pop-up that you agree to our collecting your location data anonymously using GPS and your IP address for the purpose of providing this service. You can allow or revoke this functionality in the settings of the app or your operating system at any time by going to the 'Settings' menu and adjusting the relevant settings. Your location will only be transferred to us if you use any functionality of the app that we can only provide if we know your location, for example planning a tour or calibrating a map. The legal basis for this is your consent according to article 6(1), sentence 1 under a) of the GDPR.

11.5 We create user profiles using pseudonyms for the purposes of advertising, market research and in order to design our offer based on actual demand. This data will not be merged with other personal data without your explicit consent. You can object to this by clicking the button in the app settings. You are also welcome to contact our data protection officer or the address given in the publication details. The legal basis for this is article 6(1), sentence 1 under f) of the GDPR.

12. Will we pass on your data to third parties?

In principle, we do not transfer your data to third parties without your consent.

We make use to some extent of third-party support for electronic data processing. This support is provided by reliable service providers who we have carefully selected to process your data in accordance with our mandate. The legal basis for this is article 28 of the GDPR. Of course, our service providers are under an obligation to handle the data carefully, only in accordance with our instructions and in accordance with the applicable data protection legislation and regulations, and in particular not to use the data for their own purposes or to pass it on to third parties.

Data will also be passed on for the purpose of points 11 and 12 of this Privacy Policy and if you use any FREEONTOUR services for which the FREEONTOUR partner companies participating in the FREEONTOUR system (consisting of the FREEONTOUR web portal and the FREEONTOUR customer card) are required.

In addition, there may be situations where we are legally obliged to pass on your data in response to an order from the police or other authorities, if and to the extent that this is necessary for the purposes of criminal prosecution or to avert danger. The legal basis for passing on your data as referred to here is article 6(1) under c) of the GDPR.

Finally, there may be situations where your data is passed on to companies affiliated with Erwin Hymer Group AG under company law (subsidiaries or sister companies) due to how work is divided within the Erwin Hymer Group AG group of companies, our parent company. 

Your data is then passed on in order to perform the tasks that occur when pursuing entrepreneurial objectives within a group of companies in a structured manner and in accordance with how we have divided our work within our group of companies; the legal basis for this is article 6(1), sentence 1 under f) of the GDPR. 

In the context of this division of work, your personal data will also be processed for advertising purposes in accordance with points 7 and 8 of this Privacy Policy and to provide you with information in the FREEONTOUR web portal tailored to your anonymous user profile; we use the Google Analytics and Piwik Pro technologies for this. You can object to the use of your data for advertising purposes as set out below:

Option of objecting to the use of your data for advertising purposes 
(objection to advertising):

You can object to the use of your personal data for advertising purposes at any time: 

You can object to the use of your data by the following applications as follows:

  • you can object to cookies by adjusting your browser settings accordingly (see point 10.1 under c) above),
  • you can object to Google Analytics and Piwik Pro by installing the browser plug-in or the opt-out cookie as described above in point 10.2 under d) and in point 10.3 under b),
  • you can object to Google Adwords Conversion by the measures explained in point 10.4 under e) above,
  • you can object to remarketing by informing Google as explained in point 10.5 above,
  • you can object to New Relic and Affilinet by adjusting the appropriate browser settings as explained in points 10.6 and 10.7, and
  • you can object to the processing of your data by social media through the measures explained in point 10.9.

In all other cases (e.g. in connection with newsletter tracking as explained in point 9) please inform us of your objection after your registration by emailing to service@freeontour.com.

If your personal data is processed outside the countries of the European Economic Area ('EEA'), we will protect it by only passing it on and processing it within our group of companies in accordance with the standard contractual clauses stipulated by the EU Commission within the meaning of article 46(2) under c) of the GDPR. The standard contractual clauses can be found on https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_de.

13. Personalised analysis of your user behaviour pursuant to your consent

We will only process the data regarding your usage behaviour in the FREEONTOUR web portal and the data gathered from your use of the FREEONTOUR customer card to create a personalised user profile if you have given us your explicit and prior consent to do so. 

When you register for the FREEONTOUR web portal, we will assign you an ID, which will potentially also identify you when you visit our website again without having logged in. This data will be combined with your FREEONTOUR card data and the data that the Erwin Hymer Group AG companies have about you. In this context, these Erwin Hymer Group AG companies will also receive the data of your personalised user profile.

We use this data to provide you with information that matches your needs. The protection of your data is guaranteed by the strict technical and organisational measures that apply within the Erwin Hymer Group AG and its companies.

You can revoke your consent to personalised analysis of your user behaviour at any time without stating your reasons by emailing to service@freeontour.com. If you do this, your data that has been collected and processed for the purpose of the personalised analysis of your user behaviour will be deleted or anonymised.

14. Your rights

14.1 You have the following rights in respect of us with regard to your personal data:

  • the right to information as to whether we process any personal data that concerns you and which data we process,
  • the right of rectification or erasure of your data,
  • the right of restriction of processing,
  • the right to object to the processing if the legal basis of the processing is article 6(1), sentence 1 under f) of the GDPR and
  • the right to data portability.

14.2 You also have the right to complain to a data protection supervisory authority about our processing of your personal data.

14.3 You can revoke your consent at any time.

15. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time with future effect. An up-to-date version is available on our website. Please consult our website regularly for information on applicable provisions on privacy and data protection. 

 

Rev.: 08/06/2018

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