Privacy policy
This privacy policy provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name www.monopolluzern.ch. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.
For individual or additional activities and operations, we may publish further data protection declarations or other information on data protection.
We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
In its decision of 26 July 2000, the European Commission recognized that Swiss data protection law ensures adequate data protection. In its report of January 15, 2024, the European Commission confirmed this adequacy decision.
Table of contents
- 1. contact addresses
- 2. terms and legal bases
- 3. nature, scope and purpose of the processing of personal data
- 4. disclosure of personal data
- 5. communication
- 6. applications
- 7. data security
- 8. personal data abroad
- 9. rights of data subjects
- 10. use of the website
- 11 Notifications and messages
- 12. social media
- 13. services of third parties
- 14. success and reach measurement
- 15. video surveillance
- 16. final notes on the privacy policy
1. contact addresses
Responsible in the sense of data protection law:
Hotel Monopol and Metropole Luzern AG
Hotel Monopol and Metropole Lucerne AG
Pilatusstrasse 1
6003 Lucerne
In individual cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties. We are happy to provide data subjects with information about the respective responsibility on request.
Data protection representation in the European Economic Area (EEA)
We have the following data protection representation in accordance with Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The Data Protection Representation serves data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for inquiries in connection with the GDPR.
2. terms and legal bases
2.1 Terms
Data subject: Natural person about whom we process personal data.
Personal data: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data concerning trade union, political, religious or philosophical opinions and activities, data concerning health, privacy or membership of an ethnic or racial group, genetic data, biometric data uniquely identifying a natural person, data concerning criminal or administrative sanctions or prosecutions, and data concerning social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, collection, deletion, disclosure, arrangement, organization, storage, modification, dissemination, linking, destruction and use of personal data.
European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.
2.2 Legal basis
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
If and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests - including the legitimate interests of third parties - unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are, in particular, the permanent, humane, secure and reliable performance of our activities and operations, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
- Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
- Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. nature, scope and purpose of the processing of personal data
We process the personal data required to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute particularly sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, insofar as such processing is permitted.
Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.
We process personal data for the duration required for the respective purpose. We anonymize or delete personal data in particular depending on statutory retention and limitation periods.
4. disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties are, in particular, specialized providers whose services we use.
For example, we may disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.
5. communication
We process personal data in order to communicate with individuals as well as with authorities, organizations and companies. In particular, we process data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or with comparable tools.
Third parties who transmit data about other persons to us are obliged to independently ensure the data protection of these data subjects. In particular, they must ensure that such data is correct and may be transmitted.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We can also use such services to manage and otherwise process the data of data subjects beyond direct communication.
We use in particular:
- Mews: Property management system (PMS) for hotels and other accommodation; Service provider: Mews System B.V. (Netherlands); Privacy Policy: Privacy Policy, "Data Privacy".
6. applications
We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms.
We also process personal data that applicants voluntarily disclose or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.
We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants, in particular in accordance with Art. 9 para. 2 lit. b GDPR.
We may allow applicants to add their details to our talent pool so that they can be considered for future vacancies. We may also use such information to maintain contact and provide updates. If we believe that an applicant is suitable for a vacancy based on the information provided, we may inform the applicant accordingly.
We use selected services from suitable third parties to advertise jobs via e-recruitment and to enable and manage applications.
We use in particular:
- Ostendis: E-Recruitment; Service provider: Ostendis AG (Switzerland); Data protection information: Privacy policy.
7. data security
We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.
Access to our website and our other digital presence takes place using transport encryption(SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting a website without transport encryption.
Our digital communication - like all digital communication in general - is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.
8. personal data abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.
We can export personal data to all countries on earth and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - also in accordance with the decision of the European Commission.
We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.
9. rights of data subjects
9.1 Data protection claims
We grant data subjects all rights in accordance with the applicable law. Data subjects have the following rights in particular:
- Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
- Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Possibility for own point of view and human review: In the case of decisions that are based exclusively on automated processing of personal data and are associated with a legal consequence for them or significantly affect them (automated individual decisions), data subjects can present their own point of view and request a review by a human being.
- Deletion and objection: Data subjects can have their personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.
In exceptional cases, we may charge costs for the exercise of rights. We will inform affected persons of any costs in advance.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
9.2 Legal protection
Data subjects have the right to enforce their data protection claims by taking legal action or to lodge a complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB ). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany.
10. use of the website
10.1 Cookies
We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as "session cookies" or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
Cookies can be completely or partially deactivated, restricted or deleted at any time in the browser settings. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies - at least if and to the extent required by applicable law.
For cookies that are used to measure success and reach or for advertising, a general opt-out is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
10.2 Logging
We may log at least the following information for each access to our website and our other digital presence, insofar as this information is transmitted to our digital infrastructure during such accesses: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpage of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. The information is required to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.
10.3 Tracking pixels
We can integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can be used to record at least the same information as is recorded in log files.
11 Notifications and messages
11.1 Measuring success and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages effectively and in a user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
11.2 Consent and objection
You must always consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and time stamp, for reasons of proof and security.
You can object to receiving notifications and communications such as newsletters at any time . With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
11.3 Service provider for notifications and messages
We send notifications and messages with the help of specialized service providers.
12. social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights - if and insofar as the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly way.
Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Data Controller Addendum" with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights data".
13. services of third parties
We use services from specialized third parties in order to be able to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used collect the IP addresses of users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Services of Google: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) partly for users in the European Economic Area (EEA) and in Switzerland; General information on data protection: "Privacy and security principles", "More information on how Google uses personal data", Privacy policy, "Google is committed to complying with applicable data protection laws", "Guide to data protection in Google products", "How we use data from websites or apps on or in which our services are used", "Types of cookies and similar technologies used by Google" ,"Advertising" ("Personalized advertising"). where our services are used", "Types of cookies and similar technologies Google uses", "Advertising you can control" ("Personalized advertising").
- Services from Microsoft: Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; General information on data protection: "Data protection at Microsoft", "Data protection and privacy", Privacy Policy, "Data and privacy settings".
13.1 Digital infrastructure
We use the services of specialized third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
- METANET: Hosting; Service provider: METANET AG (Switzerland); Data protection information: Privacy policy, "Technical and organizational measures".
13.2 Audio and video conferences
We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, also apply.
Depending on your life situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.
We use in particular:
- Google Meet: Video conferencing; Service provider: Google; Google Meet-specific information: "Google Meet - Security and privacy for users".
- TeamViewer Meeting: Video conferencing; Service provider: TeamViewer Germany GmbH (Germany); Data protection information: Privacy policy, "First-class data protection".
- Zoom: Platform for collaborative work, in particular with video conferencing; Service provider: Zoom Video Communications Inc. (USA); Information on data protection: "Data protection at Zoom", Privacy policy, "Legal compliance".
13.3 Online collaboration
We use third-party services to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy policies, also apply.
We use in particular:
- Microsoft Teams: Platform for productive collaboration, in particular with audio and video conferencing; Service provider: Microsoft; Teams-specific information: "Security and compliance in Microsoft Teams", in particular "Data protection".
13.4 Social media functions and social media content
We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.
We use in particular:
- Facebook (social plugins): Embedding Facebook functions and Facebook content, for example "Like" or "Share"; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Privacy policy.
- Instagram platform: Embedding Instagram content; Service provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Privacy Policy: Privacy Policy (Instagram), Privacy Policy (Facebook).
- LinkedIn Consumer Solutions Platform: Embedding functions and content from LinkedIn, for example with plugins such as the "Share Plugin"; Provider: Microsoft; LinkedIn-specific information: "Data protection" ("Privacy"), data protection declaration, cookie policy, cookie management / objection to e-mail and SMS communication from LinkedIn, objection to interest-based advertising.
13.5 Card material
We use third-party services to embed maps in our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: "How Google uses location information".
13.6 E-Commerce
We operate e-commerce and use third-party services in order to successfully offer services, content or goods.
13.7 Payments
We use specialized service providers to process payments securely and reliably. For the processing of payments, the legal texts of the individual service providers also apply, for example general terms and conditions (GTC) or data protection declarations.
We use in particular:
- Stripe: Processing of payments; Providers: Stripe Inc. (USA) / Stripe Capital Europe Limited (Ireland) / Stripe Payments Europe Limited (SPEL, Ireland) / Stripe Payments UK Limited (United Kingdom); Privacy Policy: "Stripe Privacy Center", Privacy Policy, Cookie Policy.
- TWINT: Processing of payments in Switzerland; Service provider: TWINT AG (Switzerland); Data protection information: Privacy policy, "Security according to Swiss standards".
- Worldline: Processing of payments, in particular with mobile payment solutions; Providers: Worldline SA (France), Worldline Schweiz AG (Switzerland) and other Worldline companies around the world (including in the USA); Data protection information: Privacy policy, "Responsible data handling program", Cookie policy.
13.8 Advertising
We use the option of displaying targeted advertising on third parties such as social media platforms and search engines for our activities and operations.
With such advertising, we would particularly like to reach people who are already interested in our activities and operations or who might be interested in them(remarketing and targeting). For this purpose, we may transmit corresponding - possibly also personal - data to third parties who make such advertising possible. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may be able to assign the use of our website to your profile there.
We use in particular:
- Google Ads: Search engine advertising; Service provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, whereby various domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - are used for Google Ads, privacy policy for advertising, "Manage displayed advertising directly via ads".
- LinkedIn Ads: Social media advertising; Service provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Privacy Policy: Remarketing and targeting in particular with the LinkedIn Insight tag, "Privacy Policy", Privacy Policy, Cookie Policy, Objection to personalized advertising.
- Meta ads (Meta Ads): Social media advertising on Facebook and Instagram; Service provider: Meta Platforms Ireland Limited (Ireland) and other meta companies (including in the USA); Data protection provisions: Targeting, including retargeting, in particular with the meta pixel and with custom audiences including lookalike audiences, Privacy Policy, "Advertising preferences" (registration as user required).
- Microsoft Advertising: Search engine advertising on Bing, DuckDuckGo, Yahoo! and other search engines; Service provider: Microsoft; Microsoft Advertising-specific information: "Legal, data protection and security", "Settings for advertising" (objection to personalized advertising).
14. success and reach measurement
We try to measure the success and reach of our activities and operations. In this context, we can also measure the effect of third-party references or check how different parts or versions of our digital presence are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements.
In most cases, the IP addresses of individual users are recorded to measure success and reach. In this case, IP addresses are generally shortened ("IP masking") in order to comply with the principle of data minimization through the corresponding pseudonymization.
Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window and the - at least approximate - location. In principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile of the respective service.
We use in particular:
- Google Marketing Platform: Performance and reach measurement, in particular with Google Analytics; Service provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices (cross-device tracking) with pseudonymized IP addresses, which are only transmitted in full to Google in the USA in exceptional cases, privacy policy for Google Analytics, "Browser add-on to deactivate Google Analytics".
- Google Tag Manager: Integration and management of services from Google and third parties, in particular for measuring success and reach; Provider: Google; Google Tag Manager-specific information: Privacy policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.
15. video surveillance
We use video surveillance to prevent criminal acts, to preserve evidence in the event of criminal acts, to exercise and assert our own legal claims, to defend ourselves against third-party legal claims and to exercise our domiciliary rights. If and insofar as the General Data Protection Regulation (GDPR) is applicable, these are overriding legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, in the case of particularly sensitive personal data with reference to Art. 9 para. 2 lit. f GDPR.
We store recordings from our video surveillance for as long as they are required for the preservation of evidence or another specified purpose.
We may save recordings from our video surveillance and transmit them to competent authorities, in particular judicial or law enforcement authorities, provided that the transmission is necessary for a stated purpose, in our other legitimate overriding interest or due to legal obligations.
16. final notes on the privacy policy
We have created this privacy policy using the data protection generator from Datenschutzpartner.
We may update this privacy policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current privacy policy on our website.
