Privacy Policy

Table of Contents

Introduction
1.1 Contact details
1.2 Scope of data processing, processing purposes and legal bases
1.3 Data processing outside the EEA
1.4 Storage duration
1.5 Rights of data subjects
1.6 Obligation to provide data
1.7 No automatic decision making in individual cases
1.8 Making contact
Data processing on our website
2.1 Notice for website visitors from Germany
2.2 Informative use of our website
2.3 Web hosting and provision of the website
2.4 Contact form
2.5 Vacant positions
2.6 Payment processors
2.7 Technically necessary cookies
2.8 Third parties
2.8.1 Microsoft Clarity
2.8.2 Elementor
2.8.3 WP rocket
2.8.4 Borlabs Cookie
2.8.5 Google Analytics
2.8.6 Google Tag Manager
2.8.7 Google reCAPTCHA
2.8.8 Microsoft Advertising (Bing Ads)
2.8.9 Wordfence
2.8.10 heyData
Operational Data Processing within the Framework of Hotel Operations (Without Reception)
3.1 Property & Booking Management (Apaleo & Guesty)
3.2 Online Check-in (likeMagic)
3.3 Guest Communication (WhatsApp Business)
3.4 Digital Telephone Support (Aircall & Sipgate)
3.5 Process Automation (Make.com)
3.6 Internal AI Infrastructure (Langdock)
3.7 Guest Feedback Systems (Typeform)
3.8 Digital Contract Management (Adobe Sign)
3.9 Finance, Invoicing & Procurement (DATEV, CANDIS, Pleo, lucanet, easybill)
3.10 IT Infrastructure & Cloud Storage (Microsoft 365 & Collaboration Tools)
Data processing on social media platforms
4.1 Facebook
4.2 Instagram
4.3 YouTube
4.4 LinkedIn
Changes to this privacy policy
Questions and comments

Introduction
In the following, we provide information about the collection of personal data when using
our website https://www.homaris.com/de/
our profiles in social media.
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
1.1 Contact details
The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Homaris AG, Invalidenstraße 112, Berlin, Germany, email: info@homaris.de. We are legally represented by Marc Pielke (Vorsitzender), Dennis Schenkel.
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5,
10117 Berlin, www.heydata.eu , E-Mail: datenschutz@heydata.eu.
1.2 Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.
1.3 Data processing outside the EEA
Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).
In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.
In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
1.4 Storage duration
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
1.5 Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:
Right of access,
Right to correction or deletion,
Right to limit processing,
Right to object to the processing,
Right to data transferability,
Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
1.6 Obligation to provide data
Within the scope of the business or other relationship, guests, prospective guests or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.
1.7 No automatic decision making in individual cases
As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.
1.8 Making contact
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
1. Data processing on our website
2.1 Notice for website visitors from Germany
Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.
This storage and access is based on the following provisions:
Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutzgesetz, “TDDDG”).
Otherwise, this storage or access takes place on the basis of the website visitor’s consent (Section 25 para. 1 TDDDG).
The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.
2.2 Informative use of our website
During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
These data are:
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
Amount of data transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.
This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.
2.3 Web hosting and provision of the website
Our website is hosted by Cloudways. The provider is Digitalocean LLC, 101 Avenue of the Americas 10th Floor New York, NY 10013, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider’s privacy policy at https://www.digitalocean.com/legal/privacy-policy.
It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
2.4 Contact form
When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
2.5 Vacant positions
We publish job advertisements on our website, on pages connected to the website, or on third-party websites. The data provided in the context of the application is processed for the purpose of conducting the application process. Insofar as this data is required for our decision to establish an employment relationship, the legal basis is Art. 88 Abs. 1 GDPR in conjunction with Section 26 Abs. 1 of the German Federal Data Protection Act (BDSG). We have marked the data required to carry out the application process accordingly or point it out. If applicants do not provide this data, we cannot process the application. Additional data is voluntary and not required for an application. If applicants provide further details, the basis is their consent (Art. 6 Abs. 1 S. 1 lit. a GDPR).
We ask applicants to refrain from providing information on political opinions, religious beliefs, and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide corresponding information, we cannot prevent its processing within the scope of processing the CV or cover letter. Its processing is then also based on the consent of the applicant (Art. 9 Abs. 2 lit. a GDPR). Finally, we process the data of applicants for further application processes (talent pool) if they have given us their consent to do so (Art.
6 Abs. 1 S. 1 lit. a GDPR).
For this purpose, we use join.com (Joint Marketing Services GmbH, Germany) for the multi-posting of job advertisements and as a digital applicant management
system, as well as kununu for managing employer reviews. For the internal administration of the personnel files of our permanent employees and to support the recruiting process, we use the HR system Personio (Personio SE & Co. KG, Germany). For the legally compliant employment, payroll accounting, and management of employees and freelancers abroad, we use the platforms Remote (Remote Technology, Inc., USA) and omnipresent (Omnipresent Group, United Kingdom). The legal basis for this is the performance of the employment relationship (Art. 88 Abs. 1 GDPR in conjunction with Section 26 Abs. 1 BDSG) or contract fulfillment in the case of external partners and freelancers (Art. 6 Abs. 1 S. 1 lit. b GDPR).
We forward the applicants’ data to the responsible employees of the HR department… If we enter into an employment relationship with the applicant following the application process, we will only delete the data after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant. If applicants have given us their consent to use their data for further application processes as well, we will not delete their data until one year after receiving the application.
2.6 Payment processors
For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our guests (Art. 6 para. 1 s. 1 lit. b GDPR).
These payment processors are:
Stripe Payments Europe, Ltd., Ireland
2.7 Technically necessary cookies
Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter “Technically Necessary Cookies”), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing guests and other site visitors with a functional website. Specifically, we set technically necessary cookies for the following purpose or purposes:
to apply language settings
2.8 Third parties
2.8.1 Microsoft Clarity
We use Microsoft Clarity for analytics, to identify opportunities. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses), usage data (e.g. web pages visited, interest in content, access times) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://privacy.microsoft.com/de-de/privacystatement.
2.8.2 Elementor
We use Elementor to create websites. The provider is Elementor LTD., Tuval St 40, Ramat Gan, Israel. The provider processes meta/communication data (e.g. device information, IP addresses), usage data (e.g. web pages visited, interest in content, access times) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://elementor.com/terms/.
2.8.3 WP rocket
We use WP rocket for the website performance. The provider is SAS WP MEDIA, 4 rue de la République, 69001 LYON, France. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in reducing the loading time on our website.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://wp-rocket.me/de/impressum/.
2.8.4 Borlabs Cookie
We use Borlabs Cookie to manage consents. The provider is Borlabs GmbH Hamburger Str. 11 22083 Hamburg Germany. The provider processes in the EU.
The legal basis for the processing is “-“. This website uses Borlabs Cookie, which sets a technically necessary cookie (borlabs-cookie) to store the cookie consents of site visitors. The legal basis of the processing is Art. 6 Abs. 1 p. 1 lit. f GDPR. The borlabs-cookie cookie stores page visitors’ consents that they gave when entering the website. If site visitors wish to revoke these consents, they can simply delete the cookie in their browser. When the website is reloaded, they will be asked again for their cookie consent.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://borlabs.io/privacy/.
2.8.5 Google Analytics
We use Google Analytics for analytics. The provider is Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The provider processes meta/communication data (e.g. device information, IP addresses), usage data (e.g. web pages visited, interest in content, access times)in the USA in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://business.safety.google/privacy/.
2.8.6 Google Tag Manager
We use Google Tag Manager for advertising, for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider
processes usage data (e.g. web pages visited, interest in content, access times)in the USA in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://business.safety.google/privacy/.
2.8.7 Google reCAPTCHA
We use Google reCAPTCHA to manage authentications. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses), usage data (e.g. web pages visited, interest in content, access times)in the USA in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://business.safety.google/privacy/.
2.8.8 Microsoft Advertising (Bing Ads)
We use Microsoft Advertising (Bing Ads) for conversion tracking, for analytics. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses), usage data (e.g. web pages visited, interest in content, access times)in the USA in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://privacy.microsoft.com/en-gb/privacystatement.
2.8.9 Wordfence
We use Wordfence for application security. The provider is DEFIANT INC., 1700 Westlake Ave N Ste 200, Seattle, WA 98109, USA. The provider processes meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail addresses, telephone numbers)in the USA in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in keeping our website secure and protected from attacks.
The transfer of personal data to a country outside the EEA takes place on the legal basis standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.wordfence.com/privacy-policy/.
2.8.10 D3X
We use D3X as an AI-powered chatbot for automated processing of inquiries and messages (including via WhatsApp). The provider is akin labs, Inc., 440 N Barranca Ave #2546, Covina, CA 91723, USA. The provider processes contact data (e.g., names, phone numbers), booking and reservation details (e.g., booking number, check-in and check-out dates, room number, booked services, access codes), and meta/communication data (e.g., chat contents) in the USA.
The legal basis for the processing is Art. 6 (1) (b) GDPR (performance of an accommodation contract or pre-contractual measures) as well as Art. 6 (1) (f) GDPR. We have a legitimate interest in the efficient and automated handling of our guest communications.
The transfer of personal data to a country outside the EEA is based on Standard Contractual Clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is ensured by standard data protection clauses issued in accordance with the examination procedure under Art. 93 (2) GDPR (Art. 46 (2) (c) GDPR), which we have agreed upon with the provider.
The data will be erased as soon as the purpose of its collection ceases to apply and no legal retention obligations prevent its deletion. Further information can be found in the provider’s privacy policy at https://d3x.ai.
2.8.11 heyData
We have integrated a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.
The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data privacy compliance. At the same time, the provider has a legitimate interest in ensuring that only guests with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative as confirmation.
As the data is masked after collection, there is no possibility to identify website visitors. Further information is available in the privacy policy of the provider at https://heydata.eu/en/privacy-policy.
1. Operational Data Processing within the Framework of Hotel Operations (Without Reception)
Since Homaris is operated as a modern hotel concept without a physical reception, we manage all booking, check-in, communication, personnel, and administrative operations via integrated digital systems. The processing of your data in these systems is essential for the execution of our accommodation concept.
3.1 Property & Booking Management (Apaleo & Guesty)
We use the Apaleo and Guesty systems for the central management of all our guest data, room occupiliations, reservations, and payment processing. In this context, master data, contact data, and booking details are processed. The providers utilize standard cloud hosting structures. The transfer to third countries is secured via Standard Contractual Clauses (SCCs) or the EU-US Data Privacy
Framework. The legal basis for this processing is Art. 6 Abs. 1 S. 1 lit. b GDPR (fulfillment of the accommodation contract).
3.2 Online Check-in (likeMagic)
We offer the option of a digital online check-in on our website and through linked channels. For this purpose, we use the software likeMagic. The provider is likeMagic AG, Heinrich-Federer-Strasse 4, 8038 Zurich, Switzerland. The provider processes personal data (in particular master data such as name, date of birth, address, and nationality, as well as the serial number of the identity document for foreign guests) in the EU and in Switzerland. The transfer of personal data to a country outside the EEA (Switzerland) is carried out on the legal basis of an adequacy decision by the EU Commission.
The legal basis for the subsequent processing is Art. 6 Abs. 1 S. 1 lit. c GDPR. The processing is necessary to fulfill a legal obligation to which we, as an accommodation facility, are subject under Sections 29 and 30 of the German Federal Registration Act (Bundesmeldegesetz – BMG). Insofar as the data is required for the execution of the accommodation contract, the legal basis is also Art. 6 Abs. 1 S. 1 lit. b GDPR. Within this digital process, no photocopies or scans of identity documents are made or stored. Further information can be found in the provider’s privacy policy at .
3.3 Guest Communication (WhatsApp Business, likeMagic & D3X Chatbot)
For digital communication with our guests, sending booking confirmations and automated notifications regarding reservations, as well as providing guest services, we use WhatsApp Business. The service provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Incoming and outgoing WhatsApp messages are processed centrally via the management platform likeMagic (likeMagic AG, Switzerland). For the automated processing of inquiries and messages, we also utilize the AI-powered chatbot D3X provided by akin labs, Inc. (440 N Barranca Ave #2546, Covina, CA 91723, USA).
As part of this communication, we process the following personal data:
Full name and title (as well as a reference for group bookings)
Booking details (booking number, arrival and departure dates, room number, booked services)
Individual door access codes
Content of exchanged messages and chat history
For sending booking confirmations, stay-related information, access codes, and handling service requests, the legal basis is Art. 6 (1) (b) GDPR (performance of a accommodation contract or taking steps prior to entering into a contract).
Insofar as the use of WhatsApp is optional and based on legitimate interests in efficient and modern customer communication, the legal basis is Art. 6 (1) (f) GDPR.
The transfer of data to akin labs, Inc. (USA) is based on Standard Contractual Clauses (EU SCCs) pursuant to Art. 46 (2) (c) GDPR. For data transfers to likeMagic AG (Switzerland), an adequacy decision by the EU Commission pursuant to Art. 45 GDPR applies. For further information, please refer to the privacy policies of Meta, likeMagic, and akin labs (d3x.ai).
3.4 Digital Telephone Support (Aircall & Sipgate)
For our telephonic guest service, we use the digital telephony systems Aircall (Aircall SAS, France) and Sipgate (Sipgate GmbH, Gladbacher Str. 74, 40219 Düsseldorf, Germany). (Note: The 3cx system has been deactivated). No direct guest contacts are handled via Sipgate. When using our support via Aircall, calls are recorded for quality and training purposes, provided you actively consent at the beginning of the call in the selection menu (“Press 1”).
The legal basis for the call itself is our legitimate interest in providing support (Art.
6 Abs. 1 S. 1 lit. f GDPR). The legal basis for the call recording is your explicit consent pursuant to Art. 6 Abs. 1 S. 1 lit. a GDPR, which you can revoke at any time with effect for the future. Further information can be found in the provider’s privacy policy at .
3.5 Process Automation (Make.com)
For the software-side linking and automation of our internal data processes, we use the Make.com platform (provider: Celonis SE, Germany). Via Make, guest data is automatically transferred in the background between our systems (e.g., for data forwarding from Guesty) to guarantee a smooth process without a physical reception. (Note: The US system Zapier has been deactivated). The legal basis is our legitimate interest in the efficient automation of our hotel processes (Art. 6 Abs. 1 S. 1 lit. f GDPR) as well as the fulfillment of the contract (Art. 6 Abs. 1 S. 1 lit. b GDPR). Further information can be found at .
3.6 Internal AI Infrastructure (Langdock)
We deploy the data-protection-compliant AI working environment Langdock (Langdock GmbH, Germany). This system supports our employees in internal processes and, in this course, also processes guest data (e.g., for structuring and
evaluating digital guest feedback). The legal basis is our legitimate interest in the technological optimization of our guest service (Art. 6 Abs. 1 S. 1 lit. f GDPR). (Note: The ChatGPT and Microsoft Copilot systems are no longer used directly by us). Further information can be found at .
3.7 Guest Feedback Systems (Typeform)
To collect digital guest feedback after your stay, we use Typeform (Typeform S.L., Spain). In this process, the booking number is processed and individual feedback is captured. Typeform uses the provider’s standard cloud infrastructure without restriction to pure EU servers. Participation in these surveys is voluntary. The legal basis is your consent through voluntary participation (Art. 6 Abs. 1 S. 1 lit. a GDPR) as well as our legitimate interest in continuous quality assurance (Art. 6 Abs. 1 S. 1 lit. f GDPR). Further information can be found at .
3.8 Digital Contract Management (Adobe Sign)
For the digital conclusion of lease and accommodation contracts directly with our guests, as well as for B2B and personnel contracts, we use Adobe Sign (Adobe Systems Software Ireland Limited, Ireland). (Note: The DocuSign system is not used for this purpose). You provide a digital signature via Adobe Sign. The legal basis for the associated data processing is the conclusion and fulfillment of the contract (Art. 6 Abs. 1 S. 1 lit. b GDPR). Further information can be found at .
3.9 Finance, Invoicing & Procurement (DATEV, CANDIS, Pleo, lucanet, easybill)
For our internal financial accounting, expense management, and controlling, we use the systems DATEV (DATEV eG), CANDIS (Candis GmbH), Pleo (Pleo Technologies ApS), and lucanet. No invoices are created for hotel guests via these internal accounting systems, and no operational guest data is processed; they serve exclusively to capture B2B data (vendor invoices, partner data, and expense receipts).
Automated invoicing directly to hotel guests is handled separately via the easybill system (easybill GmbH), whereby statutory fiscal and commercial retention periods of 10 years are fulfilled. The legal basis for easybill is Art. 6 Abs. 1 S. 1 lit. b and lit. c GDPR; for the internal financial tools, our legitimate interest in proper bookkeeping (Art. 6 Abs. 1 S. 1 lit. f GDPR) as well as the fulfillment of legal obligations (Art. 6 Abs. 1 S. 1 lit. c GDPR) applies.
3.10 IT Infrastructure & Cloud Storage (Microsoft 365
& Collaboration Tools) Our internal office communication, file storage, user management, and document processing run via the cloud infrastructure of Microsoft 365 (including SharePoint, OneDrive, Teams, Forms, Entra ID, Intune, Defender, and PowerApps, provided by Microsoft Ireland Operations Limited). Insofar as technically configurable, data hosting is restricted to servers within the EU.
For internal project organization, we utilize monday.com (monday.com Ltd., hosting takes place on German servers). For password security, we use Bitwarden, and for internal software coordination, we use Azure DevOps, Todoist, and Postman. Exclusively technical functional tests and internal task structures without any personal reference to hotel guests are processed via Todoist and Postman. The legal basis is our legitimate interest in a secure IT environment and a structured operational organization (Art. 6 Abs. 1 S. 1 lit. f GDPR).
1. Data processing on social media platforms
We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users’ data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users’ computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.
If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
4.1 Facebook
We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements:
https://www.facebook.com/settings?tab=ads.We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.
4.2 Instagram
We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.
4.3 YouTube
We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.
4.4 LinkedIn
We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
1. Changes to this privacy policy
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
1. Questions and comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

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