Privacy policy

Responsibility for the processing of personal data:

Andermatt Sedrun Disentis Marketing AG c/o Andermatt-Sedrun Sport AG Oberalppass Berggasthaus Piz Calmot 6490 Andermatt

info@asd-marketing.ch

In individual cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties.

1.1 Data protection representation in the European Economic Area (EEA)

We have the following data protection representation pursuant to Art. 27 DSGVO: MLL EU-GDPR GmbH Ganghoferstrasse 33 80339 Munich, Germany a-s-d-marketingag@mll-gdpr.com The data protection representative 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.

2.1 Definitions 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 that uniquely identifies a natural person, data concerning criminal and 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, recording, 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 bases We process personal data in accordance with Swiss data protection 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 insofar as 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 processing of personal data necessary 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 subject.

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).

We process the personal data required to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. The processed personal data 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. 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 for legal reasons. 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.

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 and insurance companies.

We process personal data in order to be able to communicate with third parties. In this context, we process in particular data that a data subject transmits when making contact, 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 are obliged to guarantee data protection for such data subjects. Among other things, the accuracy of the personal data transmitted must be ensured. We use selected services from suitable providers in order to be able to communicate better with third parties. In particular, we use

• Typeform: Online form service; Provider: TYPEFORM SL (Spain); Data protection information: Privacy policy, "Security & Privacy Standards at Typeform".

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 the personal data that applicants voluntarily provide 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 use selected services from suitable third parties to advertise jobs via e-recruitment and to enable and manage applications. We use in particular:

• Abacus Umantis: solution for recruitment and other talent management; provider: Abacus Umantis AG (Switzerland) and other Abacus Group companies (Switzerland, Germany); Data protection information: Privacy policy.

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 online presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting websites 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.

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 may export personal data to all countries on earth and elsewhere in the universe, provided that the local law 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.

10.1 Data protection claims

We grant data subjects all rights under applicable data protection law. In particular, data subjects have the following rights:

• Information: Data subjects can request information about whether we process personal data concerning them, and if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the processed personal data itself, but also information on the purpose of the processing, the storage period, any disclosure or export of data to other countries, and the origin of the personal data.

• Correction and restriction: Data subjects can have inaccurate personal data corrected, incomplete data completed, and the processing of their data restricted.

• 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 their personal data or the transfer of their data to another controller.

We may, within the legally permissible framework, postpone, restrict, or refuse the exercise of data subjects' rights. We may inform data subjects of any prerequisites that may need to be met to exercise their data protection rights. For example, we may refuse to provide information, in whole or in part, citing confidentiality obligations, overriding interests, or the protection of other persons. We may also refuse to delete personal data, in whole or in part, particularly citing statutory retention obligations.

In exceptional cases, we may charge fees for exercising your rights . We will inform affected individuals in advance about any such costs.

We are obligated to identify data subjects who request information or assert other rights, using appropriate measures. Data subjects are obligated to cooperate.

10.2 Legal protection

Data subjects have the right to enforce their data protection rights through legal action or to file 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 authorities are organized as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), the data protection authorities are structured federally, particularly in Germany .

11.1 Cookies

We may use cookies. Cookies – both our own (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data is not limited to traditional text-based cookies.

Cookies can be stored temporarily in the browser as "session cookies" or for a specific period as so-called persistent cookies. Session cookies are automatically deleted when the browser is closed. Persistent cookies have a specific storage duration. Cookies make it possible, in particular, to recognize a browser on the next visit to our website and thus, for example, to measure the reach of our website. Persistent cookies can also be used for online marketing purposes.

Cookies can be completely or partially disabled and deleted at any time in your browser settings. Without cookies, our website may not be fully functional. We actively request – at least where and to the extent necessary – your explicit consent to the use of cookies.

For cookies used for performance and reach measurement or for advertising, a general objection ("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).

11.2 Logging

For each access to our website and our other online presence, we may log at least the following information, provided that this information is transmitted to our digital infrastructure during such access: 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 the amount of data transferred, and the last website accessed in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. This information is necessary to ensure the continuous, user-friendly, and reliable provision of our online presence. Furthermore, this information is necessary to guarantee data security – including through or with the assistance of third parties.

11.3 counting pixels

We may integrate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are typically small, invisible images or scripts written in JavaScript that are automatically retrieved when our online presence is accessed. (See also the privacy policy of Andermatt Sedrun Disentis Marketing AG / December 2024.) Tracking pixels can collect at least the same information as log files.

12.1 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 were clicked. Such web links and tracking pixels can also record the use of notifications and messages on a personal level. We require this statistical usage data for performance and reach measurement, enabling us to send notifications and messages effectively, user-friendly, and in a sustainable, secure, and reliable manner, based on the needs and reading habits of the recipients.

12.2 Consent and objection

You mustgenerallyconsent to the use of your email address and other contact information, unless such use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain your consent, if required. In this case, you will receive a message with instructions for completing the two-step confirmation process. For evidentiary and security purposes, we may log obtained consents, including IP address and timestamp .

You can generally object to receiving notifications and communications such as newsletters at any time. By objecting, you also object to the statistical collection of your usage data for performance and reach measurement. This does not affect notifications and communications necessary in connection with our activities and operations.

12.3 Service providers for notifications and messages

We send notifications and messages using specialized service providers.

We use in particular:

• Amazon Simple Email Service (SES) : Email delivery platform; Provider: Amazon Web Services Inc. (USA); Data protection information: Privacy Policy ,"Data Protection Center" , "Frequently Asked Questions about Data Protection" .

• Braze: Platform for customer communication via email, SMS and other communication channels; Provider: Braze Inc. (USA); Data protection information: Privacy Policy , «Privacy» («Data Protection») .

We maintain a presence on social media and other online platforms to communicate with interested individuals and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The general terms and conditions (GTC), terms of use, privacy policies, and other provisions of the individual operators of such platforms also apply. These provisions provide information, in particular, about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland) – insofar as the General Data Protection Regulation (GDPR) applies. Meta Platforms Ireland Limited is part of the Meta group of companies (among others, in the USA). Page Insights provide information about how visitors interact with our Facebook page. We use Page Insights to ensure our social media presence on Facebook is effective and user-friendly. Further information about the type, scope, and purpose of data processing, information about the rights of data subjects, and the contact details of Facebook and its data protection officer can be found in Facebook's Privacy Policy . We have concluded the so-called "Controller Amendment" with Facebook, thereby agreeing in particular that Facebook is responsible for guaranteeing the rights of data subjects. The relevant information for Page Insights can be found on the page "Information about Page Insights," including "Information about Page Insights Data."

We use services from specialized third parties to ensure that our activities and operations are carried out sustainably, user-friendly, securely, and reliably. These services allow us, among other things, to embed functions and content into our website. For technically essential reasons, these services collect users' IP addresses, at least temporarily, when such content is embedded.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process aggregated, anonymized, or pseudonymized data related to our activities and operations. This includes, for example, performance or usage data, in order to provide the respective service.

We use in particular:

• Google services : Providers: Google LLC (USA) / Google Ireland Limited (Ireland), partially for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and security principles" , "Information on how Google uses personal data" , Privacy Policy , "Google is committed to complying with applicable data protection laws" , "Guide to privacy in Google products" , "How we use data from websites or apps where our services are used" , "Types of cookies and similar technologies Google uses" , "Ads you can control" ("Personalized ads" ).

• Microsoft services : 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 statement , "Data and privacy settings" .

• Services provided by Braze: Provider: Braze, Inc. (USA) for users worldwide; Privacy information: Privacy Policy , Data Processing Addendum , Data Privacy Framework Notice . We use Braze to support customer relationships and to conduct personalized marketing campaigns.

• Skidata services: Provider: Skidata GmbH (Austria) for users worldwide; Data protection information: Privacy Policy . We use Skidata services, in particular for access control solutions and ticketing systems.

• Services provided by Alturos: Provider: Alturos Destinations GmbH (Austria) for users worldwide; Data protection information: Privacy Policy . We use services from Alturos, in particular for digital marketplace platforms and e-commerce solutions in the tourism sector.

14.1 Digital Infrastructure

We use services from specialized third parties to access the necessary digital infrastructure related to our activities and operations. This includes, for example, hosting and storage services from selected providers.

We use in particular:

• Amazon Web Services (AWS) : Storage space and other infrastructure; Providers: Amazon Web Services Inc. (USA) for users in Switzerland / Amazon Web Services EMEA SARL (Luxembourg) for users in the European Economic Area (EEA); Data protection information: Privacy Policy , "Data Protection Center" , "Frequently Asked Questions about Data Protection" , "General Data Protection Regulation (GDPR) Center" .

• Google Cloud, including Google Cloud Platform (GCP) : storage space and other infrastructure; Google Cloud-specific providers: Google LLC (USA) for users in the USA, among others / Google Ireland Limited or Google Commerce Limited (both Ireland) for users in the European Economic Area (EEA) and Switzerland, among others (see " Google Contracting Entity" for providers in other countries); Google Cloud-specific information: "Privacy Resource Center" , "Data Protection" , "Compliance Resource Center" , "Trust and Security" .

14.2 Scheduling

We use services from specialized third parties to enable online appointment scheduling, for example, for meetings. In addition to this privacy policy, any directly visible terms and conditions of the services used, such as terms of use or privacy policies, also apply.

We use in particular:

• Google Calendar: Online appointment scheduling; Provider: Google; Google Calendar-specific information: «Scheduling with Google Calendar» , «Data protection in Google Calendar» .

14.3 Audio and video conferences

We use specialized audio and video conferencing services to communicate online. This allows us, for example, to hold virtual meetings or conduct online classes and webinars. Participation in audio and video conferences is also subject to the legal terms and conditions of the individual services, such as privacy policies and terms of use.

Depending on your life situation, we recommend that when participating in audio or video conferences you mute your microphone by default and blur your background or display a virtual background.

We use in particular:

• Google Meet: Video conferencing; Provider: Google; Google Meet-specific information: «Google Meet – Security and privacy for users» .

14.4 Online Collaboration

We use third-party services to enable online collaboration. In addition to this privacy policy, any directly apparent terms and 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, especially with audio and video conferencing; Provider: Microsoft; Teams-specific information: "Security and compliance in Microsoft Teams", in particular "Data protection" .

14.5 Map material

We use third-party services to embed maps into 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" .

• Outdooractive : Map service; Provider: Outdooractive AG (Germany); Data protection information: Privacy policy .

14.6 Digital Content

We use services from specialized third parties to integrate digital content into our website. Digital content includes, in particular, images, videos, music, and podcasts.

We use in particular:

• YouTube : Video platform; Provider: Google; YouTube-specific information: «Privacy and Security Center» , «My data on YouTube» .

14.7 E-Commerce

We operate an e-commerce business and use third-party services to successfully offer services, content, or goods.

14.8 Payments

We use specialized service providers to process payments from our customers securely and reliably. The legal texts of the individual service providers, such as their terms and conditions or privacy policies, also apply to payment processing.

We use in particular:

• Datatrans : Payment processing; Provider: Datatrans AG (Switzerland); Data protection information: Data protection regulations , «Security & Compliance» .

• TWINT : Processing of payments in Switzerland; Provider: TWINT AG (Switzerland); Data protection information: Privacy policy , "Security according to Swiss standards" .

14.9 Advertising

We use the option to display targeted advertising for our activities and operations on third-party platforms such as social media platforms and search engines.

With this type of advertising, we aim to reach individuals who are already interested in our activities or might become interested in them (remarketing and targeting). For this purpose, we may transfer relevant information – which may include personal data – to third parties who facilitate such advertising. We can also determine whether our advertising is successful, specifically 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 associate your use of our website with your profile there.

We use in particular:

• Google Ads: Search engine advertising; Provider: Google; Google Ads-specific information: Advertising based, among other things, on search queries, using various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – for Google Ads, Privacy Policy for Advertising , "Manage ads displayed directly from ads" .

• LinkedIn Ads: Social media advertising; Providers: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Data protection information: Remarketing and targeting, in particular with the LinkedIn InsightTag, "Data protection" , Privacy policy , Cookie policy , Objection to personalized advertising .

• Meta ads : Social media advertising on Facebook and Instagram; Providers: Meta Platforms Ireland Limited (Ireland) and other meta companies (including in the USA); Data protection information: Targeting, including retargeting, in particular with the meta pixel and with custom audiences including lookalike audiences , privacy policy , "Ad preferences" (registration as a user is required).

• TikTok Ads: Social media advertising; Providers: TikTok Information Technologies UK Limited (United Kingdom) and TikTok Technology Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland / TikTok Inc. (USA) for users in the USA / TikTok Pte. Ltd. (Singapore) for users in the rest of the world; Data protection information: Remarketing and targeting, in particular with the TikTok pixel , Privacy Policy , "Privacy Policy for Younger Users" , Cookie Policy , "TikTok for Business – Privacy and Cookie Policy"

We use plug-ins for our website in order to be able to use additional features. We may use selected services from suitable providers or use such plug-ins on our own digital infrastructure.

We use in particular:

• Google reCAPTCHA: Bot protection (distinguishing between desired human activity and undesired bot activity); Provider: Google; Google reCAPTCHA-specific information: "What is reCAPTCHA?".

We strive to measure the success and reach of our activities. This includes measuring the impact of third-party feedback and examining how different parts or versions of our online offerings are used (A/B testing). Based on the results of this success and reach measurement, we can, in particular, correct errors, strengthen popular content, or implement improvements.

For performance and reach measurement, the IP addresses of individual users are recorded in most cases . In this case, IP addresses are generally shortened ("IP masking") to adhere to the principle of data minimization through appropriate pseudonymization.

Cookies may be used and user profiles created for performance and reach measurement. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, information about the screen or browser window size, and the user's location (at least approximate). As a general rule, 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, at best, associate the use of our online services with the user's account or profile on the respective service.

We use in particular:

• fusedeck: Success and reach measurement; Provider: cptr AG (Switzerland); Data protection information: «Data & Data Protection» , Privacy Policy .

• Google Marketing Platform: Success and reach measurement, in particular with Google Analytics; Provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices (cross-device tracking) with pseudonymized IP addresses, which are only exceptionally transferred in full to Google in the USA, 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, especially 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 with the individual integrated and managed services.

We have created this privacy policy using the Datenschutz-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.