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4.0 Data storage and exchange with third-parties

4.1 Booking platforms

If you make a booking via a third-party platform, we receive various kinds of personal information from the respective platform operator. These are generally the data listed in section 1.4 of this privacy policy. Furthermore, inquiries regarding your booking may be forwarded to us. We use these data in particular to register your booking as requested and provide the booked services. The legal basis for processing data for this purpose is the performance of a contract in accordance with Art. 6 (1) (b) GDPR.

Finally, we may be informed by the platform operator about disputes in connection with a booking. In this case, it is possible that we receive data relating to the booking process, whereby a copy of the booking confirmation counts as evidence that the booking has been made. We process these data to enforce and assert our rights. This is for the purpose of pursing our legitimate interests in accordance with Art. 6 (1) (f) GDPR.

Please also note the information on data protection by the respective provider.

4.2 Central storage and linking of data

We store the data provided to us in sections 1.1 to 1.10 and 2.1 to 2.3 in a central, electronic data processing system (CRM). The data relating to you are systematically recorded and linked for the purpose of processing your bookings and handling contractual services, or based on your consent. To this end, we use software provided by the company “protel hotelsoftware Gmbh” in 44269 Dortmund, Germany. Personal data are processed in a CRM program using software provided by the company “Toedt, Dr. Selk & Coll. GmbH” in 80333 Munich, Germany. These data are processed using the software for the purpose of pursing our legitimate interests in managing data in a customer-friendly and efficient way in accordance with Art. 6 (1) (f) GDPR, and for the performance of contractual measures in accordance with Art. 6 (1) (b) GDPR.

Based on your consent, we use your data for further purposes as described in the following. In doing so, we combine your data with data stored in our company relating to your stay in our hotel, your visits to the restaurant, the SPA and Internet use, and then use this combined data to send you general information and offers for products and services of our hotel, tailored individually to you and your interests, by e-mail, SMS or post, during or after your stay.

The legal basis for processing data for this purpose is your consent in accordance with (Art. 6 (1) (a) GDPR). You may revoke your consent at any time with future effect by email ([email protected]).

4.3 Duration of storage

We only store personal data for as long as is necessary to use the tracking services named above and to process them further for the purpose of pursuing our legitimate interests. We keep contractual data for longer, as this is required by statutory storage obligations. Obligations to store data result from regulations on reporting rights, accounting and tax law. According to these regulations, business communication, concluded contracts and accounting documents must be kept for up to 10 years. If we no longer require these data to be able to provide services for you, the data are blocked. This means that they may then only be used for accounting and tax purposes.

4.4 Passing data on to third parties

We only pass on your personal data to third parties if you have given your express consent, if we are legally obliged to do so, or if it is necessary to enforce our rights, in particular to assert our claims resulting from the contractual relationship. In addition, we pass on your data to third parties insofar as this is necessary within the scope of using the website and performing the contract (also outside the website), and in particular processing your bookings.

Please also take note of the information in the preceding sections of this privacy policy regarding the transfer of data to third parties.

We may share your personal information with all affiliates in our group if necessary, provided that it is used for the same original purposes as described in this privacy policy.

These are in particular:

Widder Hotel AG
Rennweg 7
8001 Zürich 

Hotel Alex Management AG
Seestrasse 182
8800 Thalwil

Terreni alla Maggia SA
Via Muraccio 105
6612 Ascona

Castello del Sole - Terreni alla Maggia SA
Via Muraccio 142
6612 Ascona 

Sammlung E.G. Bührle
Rämistrasse 46
8001 Zürich

Géza Anda-Stiftung
Bleicherweg 18
8002 Zürich 

In the following, we provide an overview of third parties we employ:

4.4.1 Webmasters

We work together with technical partners to operate and maintain our website and guarantee contractual services and offers on our website. As a result, personal data are passed on to, or can be accessed by, the following partners:

Positioner SA
Centro Monda 3
6528 Camorino

The websites are hosted on servers in Switzerland. Data are passed on for the purpose of offering and maintaining the functions of our website. This constitutes our legitimate interests in accordance with Art. 6 (1) (f) GDPR.

4.4.2 Room reservation system 

Personal data relating to room reservations on the website are collected and sent to us by

QNT S.r.l. a Socio Unico
Via Lucca,52 – 50142

4.4.3 Central storage and linking of data 

Personal data are consolidated to enhance and improve our services to guests using a CRM. The data are supplied and processed by

Toedt, Dr. Selk & Coll. GmbH
Augustenstr. 79
80333 Munich

[email protected].

4.4.4 Restaurant reservations

Personal data for restaurant reservations on the website are collected and processed by  

aleno AG
Aegertenstrasse 6
8003 Zurich

+41 43 508 24 65

4.4.5 Event tickets and vouchers

Personal data for the purchase of event tickets and vouchers on the website are collected, processed and supplied by 

pdc salespitcher ag 
Schwimmbadstrasse 45
5430 Wettingen 


Idea Creation GmbH
Walchestrasse 15
8006 Zurich

4.4.6 Credit card payments

If you pay on the website by credit card, we pass on your credit card information to your credit card issuer and to the credit card acquirer. To this end, we work with the software platform “Stripe” provided by 

Stripe Inc.
510 Townsend Street,
CA 94107 San Francisco


Concardis GmbH
Helfmann-Park 7
65760 Eschborn

If you decide to pay by credit card, you are asked each time to enter all mandatory information. The legal basis for processing data for this purpose is the performance of a contract in accordance with Art. 6 (1) (b) GDPR. Regarding the processing of your credit card information by these third parties, please also read the general terms and conditions and the privacy policy of your credit card issuer.

4.4.7 Chat

Personal data for the use of the chat tool on the website are collected and processed by   

JivoSite Inc.
1013 Centre Rd, Suite 403-B
Wilmington, Delaware 19805

[email protected].

4.4.8 Application tool 

Personal data for the use of the application tool on the website are collected and processed by 

Jacando AG
Münchensteinerstrasse 41
4052 Basel

4.4.9 WiFi provider

Personal data for the use of WiFi in the hotel are collected and processed by  

Monzoon Networks AG
8192 Zweidlen

4.5 Transferring personal data abroad

We are entitled to also transfer your personal data to third-party companies (contracted service providers) abroad for the purpose of data processing as described in this privacy policy. These third parties are obliged to protect data to the same extent as we are. If the level of data protection in a country does not correspond to that of Switzerland or Europe, we contractually ensure that the protection of your personal data corresponds to that of Switzerland or the EU at all times.

4.5.1 Note on data transfers to the USA

For the sake of completeness, we would like to point out to users resident or domiciled in the EU or Switzerland that US authorities impose surveillance measures in the USA that generally allow the storage of all personal data of all persons whose data has been transferred from Switzerland or the EU to the USA. This is done without any differentiation, limitation or exception, based on the objective pursued, and without any objective criterion that would make it possible to restrict the US authorities' access to, and subsequent use of, the data to very specific, strictly limited purposes that could justify such an intervention related to both access to and use of the data. Furthermore, we would like to point out that in the USA, there are no legal means available to data subjects from Switzerland and the EU that would allow them to access, rectify or erase their data, and that there is no effective legal protection against general access rights of US authorities. We explicitly draw the attention of data subjects to this legal and factual situation to allow them to make an informed decision before giving their consent to the use of their data.

We point out to users who are resident in a member state of the EU that, from the point of view of the European Union, the USA does not have an adequate level of data protection, partly due to the issues mentioned in this section. Insofar as we have explained in this privacy statement that recipients of data (such as Google) are based in the USA, we will ensure that your data stored at our partners is protected to an appropriate extent, either through contractual arrangements with these companies or by ensuring that these companies are certified under the EU or Swiss-US Privacy Shield.

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5.0  Further information


The Living Circle – is a hand-picked group of first-class hotels and restaurants in incomparably beautiful locations, run by dedicated hosts. Rice, vegetables, fruit, and a whole array of exquisite produce – including wine, of course – is whisked fresh from our own farms directly to your table. That is how we define luxury. That is The Living Circle – luxury fed by nature.

Discover The Living Circle website