1. Introduction and general information
Protecting your personal data is very important to us. This Privacy Policy informs you about the
most important aspects of data processing on our website in accordance with the EU General Data
Protection Regulation (GDPR), the Italian Data Protection Code (Legislative Decree No. 196/2003
as amended), and other applicable privacy laws.
This policy applies to the processing of personal data on our website www.hirben.it by the
Controller (Art. 4(7) GDPR):
Hirben
Person: Barbara Stoll
Rienzstrasse 5
Tel.: 0039 0474 745010
Fax: 0039 0474 740679
E-Mail: info@hirben.it
MwSt.-Nr.: IT03187020213
CIN: IT021113B4TI8YK2OQ
2. Collection and storage of personal data
We process personal data only to the extent necessary. Personal data means any information relating
to an identified or identifiable natural person.
a) When visiting the website
When you access our website, our system automatically collects the following data:
• IP address (anonymized where possible)
• Date and time of access
• Name and URL of the retrieved file
• Website from which access is made (referrer URL)
• Browser used, operating system, and name of the access provider
Purpose of processing:
Ensuring a smooth connection to the website, system security and stability, and statistical analysis.
Legal basis:
Art. 6(1)(f) GDPR (legitimate interests)
3. Cookies
Our website uses cookies. These are small text files stored on your device.
Types of cookies:
• Technically necessary cookies: Essential for the operation of the site. (Legal basis: Art.
6(1)(f) GDPR)
• Functional cookies: Improve user experience.
• Marketing and tracking cookies: Analyze user behavior (only with your consent).
When you first visit our website, a cookie banner (consent tool) asks for your consent to the use of
non-essential cookies. Your selection is stored and can be revoked at any time.
4. Contact form & email inquiries
If you contact us via contact form or email, we process your information (e.g., name, email address,
message) to handle your inquiry.
Legal basis:
Art. 6(1)(b) GDPR (pre-contractual steps or contract performance)
5. Booking requests via the website
If you make an inquiry or reservation via our integrated booking tool, your data will be processed to
carry out pre-contractual measures and for contract performance.
Legal basis:
Art. 6(1)(b) GDPR
Note: The booking software is provided by a third-party provider (e.g., Kognitiv, vioma,
Easybooking). In this case, processing takes place under a data processing agreement pursuant to
Art. 28 GDPR.
6. Newsletter
If you subscribe to our newsletter, we process your email address and, where applicable, your first
and last name to send you regular information about offers and news.
a) Double opt-in procedure
After subscribing, you will receive a confirmation email. The newsletter will only be activated once
you confirm.
Legal basis:
Art. 6(1)(a) GDPR (consent)
Unsubscribe:
You can unsubscribe at any time via the link in every email or by contacting us.
Email service provider:
The newsletter may be sent via a third-party provider (e.g., Mailchimp, Sendinblue, CleverReach)
located in the EU or the USA (in compliance with the Standard Contractual Clauses pursuant to
Art. 46 GDPR).
7. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Ireland Limited
(Google Ireland, Gordon House, Barrow Street, Dublin 4, Ireland).
Data collected:
• IP address (anonymized)
• Usage behavior
• Session duration
• Device type, browser, language settings
We use Google Analytics with the “anonymizeIP” extension so that IP addresses are processed
only in truncated form.
Legal basis:
Art. 6(1)(a) GDPR (consent)
Opt-out:
You can withdraw your consent at any time via the cookie banner or use the browser add-on:
tools.google.com/dlpage/gaoptout
8. Google Ads / Remarketing
We use Google Ads, including remarketing features, to display targeted ads based on your interests.
This allows users of our website to be recognized on other pages within the Google network.
Legal basis:
Art. 6(1)(a) GDPR (consent)
Deactivation:
You can disable personalized advertising in your Google settings:
adssettings.google.com
9. Facebook & Instagram (Meta Pixel)
We use the Meta Pixel from Facebook/Instagram (Meta Platforms Ireland Ltd., 4 Grand Canal
Square, Dublin 2, Ireland) to analyze visitor actions on our website and to run targeted advertising.
Data collected:
• Visit behavior
• IP address (anonymized)
• Device information
Legal basis:
Art. 6(1)(a) GDPR (consent)
Data transfer to the USA:
Data may be transferred to Meta in the USA. Such transfers are based on the EU Standard
Contractual Clauses.
Withdrawal:
Via the consent tool or: www.facebook.com/adpreferences/
10. Integration of third-party content
Our website integrates content from third-party providers (e.g., Google Maps, YouTube, social
media feeds). When accessed, IP addresses may be transmitted to these providers.
Legal basis:
Art. 6(1)(a) GDPR (consent)
11. Rights of data subjects
You have the right to:
• Access (Art. 15 GDPR)
• Rectification (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Object to processing (Art. 21 GDPR)
• Withdraw consent (Art. 7(3) GDPR)
Please contact: info@hirben.it
You also have the right to lodge a complaint with the competent supervisory authority:
Garante per la protezione dei dati personali (https://www.garanteprivacy.it/)
12. Processors
We do not share your data with third parties except for processing by service providers bound by
our instructions pursuant to Art. 28 GDPR. Data processing agreements are in place with all
partners.
13. Data security
We use SSL encryption (HTTPS) and technical and organizational measures to protect your data in
the best possible way.
14. ADDITIVE+ LANDINGPAGE - Online Marketing and Landing Pages
Beside our website we do also operate optimized landing pages for means of hotel online marketing. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”), our partner in the field of hotel digital marketing. The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence. Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
Die Datenverarbeitung erfolgt auf Basis der gesetzlichen Bestimmungen des Art 6 Abs 1 lit f (berechtigtes Interesse) der DSGVO.
Unser Anliegen im Sinne der DSGVO (berechtigtes Interesse) ist die Verbesserung unseres Angebots und unseres Webauftritts durch Analyse der Benutzung unserer Website sowie Vertriebs- und Marketingmaßnahmen.
Zudem verwenden unsere Landingpages sowie unsere Website Remarketing-Funktionen der Google Inc. („Google“) sowie der Meta Platforms Inc. („Meta“). Dabei wird an Meta und Google übermittelt, dass Sie diese Website besucht haben. Diese Funktionen dienen dazu, Besuchern der Landingpages interessenbezogene Werbeanzeigen im Werbenetzwerk von Google oder im Sozialen Netzwerk Facebook sowie Instagram zu präsentieren.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. Only by clicking on the corresponding button you consent to the use of these cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.
15. ADDITIVE+ MARKETING AUTOMATION - Direct Marketing
In order to increase customer loyalty and to sell our services and additional services we use hotel online marketing software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”) within the field of hotel marketing automation. Therefore your data, which we gather and process in connection with your request, reservation, order, activation, registration or the transmission of other contact forms on our website, will be analysed and used to provide you with automatically generated offers for our services and additional services. Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.
You can deny the use of your data for this purpose anytime by clicking on the “unsubscribe” link in the respective message.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the prevention of competitive disadvantages, the increase in brand awareness and the maximisation of our economic success through an optimal use of the acquired contacts.
16. ADDITIVE+ VOUCHERS
On our website you have the possibility to buy vouchers by using the integrated voucher software. To process your purchase and to save and store your data we use software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”) in the context of voucher marketing. Through the use of these services and systems your data will be processed and stored in the EU.
The data you provide is required to fulfil the contract or to carry out pre-contractual measures. Without this data we cannot conclude a contract with you. The data will not be transferred to an outside third party, except for your credit card data which will be transferred to the payment provider and to our tax accountant to fulfil our tax obligations.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit b (processing necessary for the performance of a contract) of the GDPR.
17. ADDITIVE+ NEWSLETTER
On our website you have the possibility to subscribe to our newsletter. For the subscription we need your email address and your consent to receive our newsletter through ADDITIVE, our provider for hotel e mail marketing. To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin in our hotel newsletter tool.
After signing up for our newsletter you will receive an email containing a link to confirm the subscription.
Your subscription can be cancelled any time by clicking on the cancellation link in the respective newsletter.
To process your subscription, to send our newsletter and to determine openings and clicks we use software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”). ADDITIVE uses the mailing service provider “Sinch Mailjet”, Paris, France to handle the secure delivery of the newsletter. Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.
Why choose the Hirben? This is what sets us apart:
25-metre pool, heated all year round
Five saunas, quiet rooms and lawn for relaxing, fitness and yoga room
Unbeatable location in the Dolomites, plus a fabulous activity programme
Regional cuisine for breakfast, snacks, and dinner
Recognised sustainable approach
