Data protection information
The data protection information provided below applies from 01 September 2019 and reflects the enhanced transparency requirements as provided in the EU General Data Protection Regulation.
Who is the controller?
Fresabieno [ Fresa Bieno Ltd ] (Address: Cyprus, Nicosia 2028, Strovolos, Laodikeias 17, Off.102) (hereinafter also “Fresabieno”, “we”, “us”) wishes to inform you below of how your personal data are processed within the context of our offerings. These offerings can be directly accessed via Fresabieno.eu (“website”).
Any mention of Fresabieno below refers to the Fresabieno (Company names).
Whom can I contact?
If you have any further queries regarding data protection in connection with our website offered there, please contact our data protection officer:
Data Protection Officer for the Fresabieno
Ivan Osipau
Fresabieno (company name)
E-Mail: [email protected]
Please address any request for information to:
Fresabieno
Data Information
Address
or by e-mail to:
[email protected]u
If you contact us by e-mail, communication is unencrypted.
Why do we process your data (purpose of the processing) and what is the legal basis?
We process personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR).
We process your data for the purposes of our legitimate interests pursuant to Art. 6(1), Subparagraph 1(f) GDPR
- for the purpose of creating statistics to improve our products and services. In individual cases, we may create customer profiles for this purpose by processing reservation data; however, these profiles will be rendered anonymous immediately and will not be used to analyse or predict any aspects relating to your personal preferences.
- To communicate with you, to the extent that an ongoing business relationship with you or your employer already exists, or if we desire to establish such a relationship (business contacts).
We process your data based on your consent pursuant to Art. 6(1), Subparagraph. 1(a) GDPR for specific purposes, especially:
- for sending out newsletters
- for receiving specific information and offers from Fresabieno
- for market research and customer surveys
- for personalised use of the website and personalised offers, including profiling
- to support processes relating to usage of the website, with reminder features and live chats
- for analytical purposes so that we can optimise our offer for you.
Any consent given can be withdrawn at any time. This also applies to the withdrawal of declarations of consent given to us before the GDPR came into force, in other words, prior to 01/09/2019. Withdrawal of consent has effect for the future only and does not affect the lawfulness of data processed up until the withdrawal.
Which personal data are you required to provide?
For legally stipulated or contractual requirements, we have marked on our website forms the input fields that you are required to fill in so that we can provide you with the desired service or feedback.
How long are your data stored?
Your personal data is erased as soon as it is no longer required for the purposes stated. Your personal data are deleted as soon as they are no longer needed for the specified purposes. However, we must sometimes continue to store your data until the retention periods and deadlines set by the legislator or supervisory authorities. These generally amount to six to ten years. We may also retain your data until the statutory limitation periods have expired (usually three years, but up to 30 years in some cases), provided that this is necessary for the establishment, exercise or defence of legal claims. After that, the relevant data are routinely erased.
Who receives your data?
In the context of the data processing above and the respective legal bases given (contract performance, legitimate interests, consent or processing obligations under law), your data may be passed on to the following categories of recipients:
- Fresabieno
- other service providers, e.g. for the provision of the website, newsletter dispatch, feedback handling
- state agencies and bodies, e.g. based on entry requirements or police activities and investigations.
In the process, personal data may be transmitted to third countries or international organisations. For your protection and the protection of your personal data, appropriate safeguards are provided for such data transmissions as per and in accordance with legal requirements.
If these transmissions do not have a legal basis or are to a country for which the EU Commission has not issued an adequacy decision, we use EU standard contractual clauses.
The objective of these supplements is also to include the processing of business card information in the normal course of business.
Information on EU standard contractual clauses is available here on the European Union website.
What are your data protection rights?
Fresabieno is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:
- Right to information, Art. 15 of the GDPR
- Right to correction, Art. 16 of the GDPR
- Right to deletion (“Right to be forgotten”), Art. 17 of the GDPR
- Right to limit processing, Art. 18 of the GDPR
- Right to data transmissibility, Art. 20 of the GDPR
- Right to object, Art. 21 of the GDPR
To exercise your right, please email [email protected]
Please provide the following details so that we can identify you:
- Name
- Postal address
- E-mail address
If you send us a copy of your ID, please black out all other information apart from your first and last name and address.
In order to be able to process your request, as well as for identification purposes, please note that we will use your personal data in accordance with Art. 6 para. 1 (c) of the GDPR.
You also have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in combination with Section 19 GDPR. The relevant supervisory authority for Fresabieno is:
_________________________
How can you withdraw your consent?
If you consent to us processing your personal data, please note that you may withdraw this consent at any time.
If you gave this consent on this website, please visit the page where you originally gave consent or log in using your LH ID in order to withdraw consent in the settings.
If you have consented to receive our newsletter, you may withdraw this consent yourself using the Unsubscribe link in the newsletter.
In all other cases or if you have problems withdrawing your consent on this website, you can contact the data protection officer.
Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal data on a different legal basis – to perform a contract, for example.
Information about your right to object pursuant to Art. 21 GDPR
You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on Article 6 (1) (e) or (f) of the GDPR, including profiling based on those provisions.
The controller shall no longer process the personal data that relates to you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or processing is necessary for the establishment, exercise or defence of legal claims.
Where personal data that relates to you is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal data that relates to you shall no longer be processed for such purposes.
You have the option of exercising your right of objection in connection with the use of the services of the information company using an automated procedure – notwithstanding Directive 2002/58/EC – in which technical specifications are used.
Disclaimer and limitations of these data protection notices
These data protection notices only apply to processing for the website. Other websites are not subject to these data protection guidelines and may provide their own specific data protection guidelines.
What data do we process when you visit our website?
Our website uses cookies. Cookies are small text files placed by a web portal on the computer systems (computer, tablet or smartphone) of the users that visit it. Cookies may store personal data.
You can prevent tracking via cookies (do not track, tracking protection list) and reject the storage of third-party cookies in your browser settings.
If you delete all cookies, this will also delete any opt-out cookies placed, so you will have to actively opt-out again.
We want you to be in a position to make an informed decision for or against the use of cookies which are not absolutely necessary for the website’s technical features. Please note that you will be shown advertising that is less targeted to your interests if you reject cookies used for advertising. However, you will still be able to use all of the functionality of the website.
We differentiate between cookies that are absolutely necessary for the website’s technical features and optional cookies.
To enable you to select the data protection settings for your visits to our website that best suit your requirements, we give you the option below of adjusting your preferences with respect to the categories of operational necessity, statistics, convenience and personalisation.
1. Operational necessity category
These cookies are necessary for the operation of the website and to manage our corporate commercial objectives. Furthermore, these cookies also allow us to recognise whether you wish to remain logged in to your profile so that we can provide our services to you more quickly on your next visit to our website.
2. Statistics category
We collect anonymised data for statistics and analysis so that we can continue to improve our offering and website. These cookies allow us to determine visitor numbers and the effect of certain pages of our website, for example, and optimise our content.
3. Convenience category
We use these cookies to make our website easier to use. We can also recognise when you need support and have a customer service agent assist you via the chat functionality.
Fresabieno uses the remarketing feature of Google Inc. (“Google”) on the website. This feature is implemented by cookie technology and is used to show interest-based advertising to website visitors within the scope of the Google advertising network. In this way, a visitor to these pages may see ads which relate to content the visitor previously accessed on other websites. According to information provided by Google, it collects no personal data during this process. However, if you do not wish to receive this remarketing feature from Google, you can always deactivate it by visiting http://www.google.com/settings/ads , where you can adjust the relevant settings. For further information on Google remarketing and Google’s privacy policy, please go to: http://www.google.com/privacy/ads/.
Usage-based online advertising with third-party providers
We use your visits to Fresabieno and third-party websites and your surfing behaviour to try and discern your current interests so that we can deliver relevant, targeted advertising to you.
We use third-party cookies and create usage profiles under a pseudonym for the purpose of retargeting/remarketing to website visitors and for conversion tracking. We may analyse these for advertising and monitoring purposes. It is not possible for us to trace these back directly to any one individual.
For example, we use advertising cookies for the following purposes:
- To store your website visits in order to determine your interests
- To verify whether you clicked on an ad
- To monitor the number of visitors that click on an ad
- To use third-party services to display ads tailored to your needs, interests or preferences
- To determine which kind of advertising is efficient for us
- To display ads for products you have clicked on or searched for previously
- To monitor the number of ads shown so that the same ads do not appear all of the time
- To display other interesting ads based on your use of Lufthansa websites
- To analyse which ads you have clicked on before buying products
- To establish the number of orders resulting from ads and their monetary value
Description of third-party cookies used
Usage-based online advertising:
We use various remarketing and tracking technologies on our website. These allow us to recognise visitors on the websites of our advertising partners and target them with personalised information.
The following companies are responsible for collecting the data needed to deliver usage-based online advertising: Google (Adwords (Remarketing), DoubleClick (Floodlight)), Facebook
The same contractors deliver usage-based online advertising.
The tracking and remarketing tools used fall under different categories:
- Google Adwords remarketing – Personalisation category
- DoubleClick Floodlight (conversion) – Statistics category
- DoubleClick Floodlight (remarketing) – Personalisation category
- DoubleClick Search – Statistics category
Further information and explanations regarding the Google products used are availablehere.
You can discover more about Facebook’s interest-based advertising here.
To opt out of interest-based advertising from Facebook, please follow Facebook’s instructions here.
Facebook adheres to the self-regulatory principles for online behavioural advertising established by the Digital Advertising Alliance. More information on Facebook’s privacy protection provisions is available here in the Facebook Privacy Policy.
The following systems are also used on the website:
Under the Operational necessity category:
Google Analytics
This website uses Google Analytics, a web analysis service of Google Ireland Limited, (Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). It includes the use of “Universal Analytics” technology, which makes it possible to assign data, web sessions and interactions on several devices to an anonymised user ID, thus enabling an analysis of a user’s activities across multiple devices.
Google Analytics uses so-called “cookies”, text files which are saved on your computer and which enable an analysis of your usage of the website. Information generated by the cookie about your usage of this website is generally transferred to a Google server in the USA and stored there. In the event that IP anonymisation is activated on this website, your IP address will be shortened by Google within the member states of the European Union or in other states which are party to the Agreement on the European Economic Area before the transfer takes place. Only in exceptional circumstances will the complete IP address be transferred to a Google server in the USA and shortened there. The IP address of your browser conveyed in the context of Google Analytics will not be joined with other Google data. Google will use this information on behalf of the operator of this website to evaluate your usage of the website in order to compile reports about the website activities and to provide the website operator with additional services in connection with the usage of the website and the internet. These purposes also constitute our legitimate interest in the data processing. The legal basis for the use of Google Analytics is Section 15(3) German Telemedia Act (TMG) and Art. 6(1), Subparagraph 1(f), GDPR. Sessions and campaigns are terminated on expiry of a fixed period. The fixed period for the termination of sessions is generally 30 minutes without activity, and for campaigns the limit is six months. The maximum permissible time limit for campaigns is two years. More information about conditions of use and data protection can be found at http://www.google.com/analytics/terms/de.html or at https://policies.google.com/?hl=de.
You can prevent cookies from being installed by activating a corresponding setting in your browser software; however, we must inform you that, in this case, it is possible that you will not be able to use all the functions of this website in full. Furthermore, you can prevent the capture of data by Google relating to your use of the website generated by the cookie (including your IP address), as well as the processing by Google of this data, by downloading and installing the browser add-on. Opt-out cookies prevent the future collection of your data when visiting this website. To prevent the capture of your data across multiple devices by Universal Analytics, you must complete the opt-out process on all systems you use. Click here to install an opt-out cookie: disable Google Analytics
Social media features
We offer social network functionality in various parts of our website. These include:
- sharing and recommendation features for Fresabieno content (e.g. share and like buttons)
- linking Fresabieno offerings with social networks, e. g. when logging into your personalised area on the website (“social login”)
We give you the opportunity to share and recommend your content in social networks in our online offerings. If you visit our website and use the recommendation features, we pass on the URL to the social network you select.
We recommend that you read the privacy information of the respective social networks carefully.
“Social login” is an addition to the conventional login option on our online offerings. Instead of using your Miles & More service number or user name and PIN, you select your favourite network from a list of different social networks with which you would like to identify yourself to Lufthansa.
When you click on one of the buttons, a window of the selected network opens to ask if you consent to Lufthansa accessing your personal profile. Depending on the network, you are also told which information in your profile we will have access to as soon as you provide your consent.
On our website, we may use this two-click solution for the following social media plugins:
What is the situation when you receive our newsletter?
If you have consented in the Newsletter section of our website to receive the newsletter (up until you withdraw your consent or Fresabieno stops sending out a newsletter), we wish to make you aware of the following:
consent is the legal basis for the processing.
Your consent relates to the processing of the following personal data provided voluntarily by you:
- Email address
- Surname, first name, title, gender/salutation
- Country of origin
Your consent is used for the purpose of using your email address to send the newsletter to the address given.
The newsletter provides you with information on topics from Fresabieno activities.
We analyse your usage patterns in every newsletter by using cookies and similar technologies to personalise communication. This analysis includes, for example, pages opened, clicks, reading time and potential bookings.
Personalisation of the newsletter is based on the analysis of
- your interaction with the newsletter
- your master data voluntarily provided to us
- your IP address
The following systems and technologies are used in our newsletter:
Outlook Microsoft
The following data are processed by the Outlook delivery tool for marketing, optimisation and legal purposes:
Email delivery
Email opening
Time of opening and time of clicks
MailChimp
The following data are processed by the Litmus email marketing tool for marketing and optimisation purposes:
Reading time and reading behaviour
Location where opened
Email programme and end device used
These data are stored on a subscriber/customer basis (email address).
If you do not consent to the technologies and analyses used in the newsletter and wish to withdraw this consent, please unsubscribe from the newsletter by using the link provided in every edition of the newsletter.
Jivochat
Purpose of personal data processing:
We process your personal data to provide the Jivochat Service.
Scope of your personal data that are processed for this purpose:
Subscriber or Subscriber’s representative: name; company name; e-mail.
Legal basis for data processing:
We process your personal data because processing is necessary to perform a contract with you, such as to deliver the Jivochat Service.
How long we store your personal data:
Personal data is processed until termination of a contract.
More information about conditions of use and data protection can be found at Privacy pilicy of Jivochat.
Feedback
We offer you various channels for providing feedback. You can therefore freely decide how you wish to communicate with us. Included in this, you have the option of using our feedback form on our website to send us data. A letter is another way to communicate with us. You may also choose to use other channels to provide feedback, such as your email address, fax. Please be aware that your individual feedback may be used for training and quality purposes.