Privacy policy

I. Controller

Leipzig Tourismus und Marketing GmbH
Grimmaischer Steinweg 8
04103 Leipzig, Germany
Tel. +49 341 7104-260
Fax +49 341 7104-271

II. Data Protection Officer

Leipzig Tourismus und Marketing GmbH
Data Protection Officer Thomas Köhn
Grimmaischer Steinweg 8
04103 Leipzig, Germany
Tel. +49 341 7104-320
Fax +49 341 7104-301

III.        Purposes and legal bases for data processing by LTM GmbH

LTM GmbH processes personal data in accordance with the provisions of the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and other applicable data protection regulations where required by law.

The specific data processed and the way in which it is used depend primarily on the respective services requested or agreed. Further details or additions concerning the purposes of data processing can be found in the relevant contractual documents, agreements, forms, declarations of consent and/or other information provided (e.g. in connection with the use of the mulderadweg.de website, travel terms and conditions for package offers from LTM GmbH).

1.         Purposes based on consent pursuant to Art. 6(1)(a) GDPR

Personal data may be processed for specific purposes (e.g. use of the email address for marketing purposes) on the basis of consent. As a rule, consent may be withdrawn at any time. This also applies to the withdrawal of declarations of consent given to LTM GmbH before the GDPR came into force, i.e. before 25 May 2018. Information on the purposes and the consequences of withdrawing or not granting consent is provided separately in the relevant consent text.

As a general rule, the withdrawal of consent only takes effect for the future. Processing carried out before consent is withdrawn is not affected and remains lawful.

2.         Purposes for the performance of a contract or pre-contractual measures pursuant to Art. 6(1)(b) GDPR

Personal data is processed for the performance of contracts entered into by LTM GmbH and for the execution of orders, as well as for the implementation of measures and activities within the scope of pre-contractual relationships, e.g. with prospective customers. Processing therefore serves in particular to provide tourism services and deliver products in accordance with orders and requests, and includes the services, measures and activities required for this purpose. This essentially includes:

• contract-related communication, documentation of orders, other agreements and transactions, as well as quality control through appropriate documentation, goodwill procedures, measures to manage and optimise business processes and to fulfil general due diligence obligations, management and control by affiliated companies (e.g. parent company),
• statistical analyses for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, billing and tax assessment of business services, risk management, assertion of legal claims and defence in legal disputes,
• ensuring IT security (including system and plausibility tests) and general security, including building and facility security, ensuring and exercising domiciliary rights, ensuring the integrity, authenticity and availability of data, preventing and investigating criminal offences; monitoring by supervisory bodies or control authorities (e.g. internal audit).

3.         Purposes for fulfilling legal requirements pursuant to Art. 6(1)(c) GDPR or in the public interest pursuant to Art. 6(1)(e) GDPR

Like everyone involved in economic activity, LTM GmbH is also subject to a large number of legal obligations. These are primarily legal requirements (e.g. commercial and tax laws, but where applicable also regulatory or other official requirements). The purposes of processing may include identity and age verification, fraud and money laundering prevention, the prevention, combating and investigation of terrorist financing and asset-endangering criminal offences, checks against European and international anti-terror lists, compliance with tax control and reporting obligations, and the archiving of data for data protection and data security purposes and for audits by tax and other authorities. In addition, the disclosure of personal data may become necessary in the context of official/judicial measures for the purposes of gathering evidence, criminal prosecution or enforcing civil claims.

4.         Purposes based on a legitimate interest of LTM GmbH or third parties pursuant to Art. 6(1)(f) GDPR

Beyond the actual performance of the contract or pre-contract, LTM GmbH may process data where necessary to safeguard legitimate interests of LTM GmbH or third parties, in particular for the following purposes:

• advertising and market and opinion research, provided that the use of the data has not been objected to,
• obtaining information and exchanging data with credit agencies, where this goes beyond the economic risk of LTM GmbH,
• reviewing and optimising procedures for needs analysis,
• further development of products and services as well as existing processes and systems,
• disclosure of personal data in the context of a risk assessment during company sale negotiations,
• checking against European and international anti-terror lists, insofar as this goes beyond legal obligations,
• enriching LTM data, including through the use of or research into publicly accessible data, 
• market analysis or statistical evaluations,
• benchmarking,
• assertion of legal claims and defence in legal disputes that cannot be directly attributed to the contractual relationship,
• restricted storage of data where deletion is not possible, or only possible with disproportionate effort, due to the particular nature of the storage,
• development of scoring systems or automated decision-making processes,
• prevention and investigation of criminal offences, insofar as this is not solely for the fulfilment of legal requirements,
• building and facility security, insofar as this goes beyond general due diligence obligations;
• internal and external investigations, security checks,
• possible monitoring or recording of telephone calls for quality control and training purposes,
• obtaining and maintaining private-law or official certifications,
• ensuring and exercising domiciliary rights through appropriate measures to protect customers and employees of LTM GmbH and to secure evidence in the event of criminal offences and prevent them.

IV.       Categories of data processed by LTM GmbH, where the data was not provided directly, and their origin

Where necessary for the provision of services by LTM GmbH, LTM GmbH processes personal data lawfully obtained from other companies or other third parties (e.g. address publishers, credit agencies). In addition, LTM GmbH processes personal data that has been lawfully extracted, received or acquired from publicly accessible sources (such as telephone directories, the press, the internet and other media, commercial and association registers, population registers, debtor registers, land registers) and may be processed.

Relevant categories of personal data may include in particular:

• personal details (name, date of birth, place of birth, nationality, marital status, profession/industry and comparable data),
• contact details (address, email address, telephone number and comparable data),
• address data (registration data and comparable data),
• payment/funds confirmation for bank and credit cards,
• information about customers' financial situation (creditworthiness data including scoring, and data for assessing economic risk),
• customer history,
• data concerning the use of electronic information and communication services offered by LTM GmbH (e.g. time of access to the LTM website, pages/links of LTM GmbH clicked or entries and comparable data, newsletters),
• video and photo data.

V.        Recipients or categories of recipients 

Within LTM GmbH, data is received by those internal departments that require it to fulfil contractual and legal obligations or in the course of processing and implementing the legitimate interest of LTM GmbH.

In addition, LTM GmbH shares personal data, where permitted or required by law, with other recipients that provide services for LTM GmbH. LTM GmbH limits the disclosure of personal data to what is necessary. In some cases, LTM service providers receive personal data as processors and are then strictly bound by the instructions of LTM GmbH when handling personal data.

Data is transferred to external bodies exclusively:

• in connection with contract processing,
• on the basis of the legitimate interest of LTM GmbH or the legitimate interest of the third party for the purposes referred to under section III. / 4 (e.g. to authorities, credit agencies, debt collection agencies, lawyers, courts, experts, group companies and bodies and control authorities),
• for the purpose of fulfilling legal requirements under which LTM GmbH is obliged to provide information, report or transfer data, or where the transfer of data is in the public interest (see III. / 3),
• where external service companies process data on behalf of LTM GmbH as processors or functional successors (e.g. external data centres, support/maintenance of EDP/IT applications, archiving, document processing, call centre services, compliance services, controlling, data screening for anti-money laundering purposes, data validation or plausibility checks, data destruction, purchasing/procurement, customer administration, mailing services, marketing, media technology, research, risk controlling, billing, telephony, website management, auditing services, credit institutions, printers or data disposal companies, courier services, logistics),
• where consent has been given to LTM GmbH for transfer to third parties.

VI.       Duration of data storage

LTM GmbH processes and stores data for the duration of the respective business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the performance of a contract.

In addition, LTM GmbH is subject to various retention and documentation obligations arising, among other things, from the German Commercial Code (HGB) and the German Fiscal Code (AO). The retention and documentation periods stipulated there are up to ten years beyond the end of the business relationship or pre-contractual legal relationship.

Furthermore, specific legal provisions may require a longer retention period, such as the preservation of evidence within the scope of statutory limitation periods. Under Sections 195 et seq. of the German Civil Code (BGB), the regular limitation period is three years, but limitation periods of up to 30 years may also apply.

If the data is no longer required to fulfil contractual or legal obligations and rights, it will be deleted unless its - temporary - further processing is necessary to fulfil the purposes listed under III. / 4 due to an overriding legitimate interest. Such an overriding legitimate interest also exists, for example, where deletion is not possible, or only possible with disproportionate effort, due to the particular nature of the storage, and processing for other purposes is excluded by suitable technical and organisational measures.

VII.      Third-country transfers, data transfers to international organisations

Data is transferred to bodies in countries outside the European Union (EU) or the European Economic Area (EEA) (so-called third countries) where this is necessary for the execution of an order/contract, required by law (e.g. tax reporting obligations), is within the scope of a legitimate interest of LTM GmbH or a third party, or where consent has been granted to LTM GmbH.

Data may also be processed in a third country in connection with the engagement of service providers within the scope of processing on behalf. If there is no decision by the European Commission for the country concerned confirming an adequate level of data protection there, LTM GmbH ensures through appropriate contracts in accordance with EU data protection requirements that  rights and freedoms are adequately protected and guaranteed. LTM GmbH provides corresponding detailed information upon request.

VIII.    Data protection rights as a data subject

Subject to the statutory requirements, data subjects have the following rights, which may be asserted against LTM GmbH:

Right of access: Under Art. 15 GDPR, there is a right to request confirmation from LTM GmbH as to whether LTM GmbH processes its customers' personal data. If this is the case, there is a right under Art. 15 GDPR to obtain information about this personal data and certain other information (including purposes of processing, categories of personal data, categories of recipients, planned storage period, origin of the data, use of automated decision-making and, in the case of third-country transfers, appropriate safeguards) and a copy of the data (where applicable, subject to restrictions under Section 34 BDSG).

Right to rectification: Under Art. 16 GDPR, there is a right to request that LTM GmbH rectifies customers' stored personal data if it is inaccurate or incorrect.

Right to erasure: Subject to the requirements of Art. 17 GDPR, there is a right to request that LTM GmbH erases customers' personal data without undue delay. Among other things, the right to erasure does not apply where the processing of personal data is necessary for exercising the right to freedom of expression and information, for compliance with a legal obligation to which LTM GmbH is subject (e.g. statutory retention obligations), or for the establishment, exercise or defence of legal claims.

Right to restriction of processing: Subject to the requirements of Art. 18 GDPR, there is a right to request that LTM GmbH restricts the processing of customers' personal data.

Right to data portability: Subject to the requirements of Art. 20 GDPR, there is a right to request that LTM GmbH provides customers' personal data that has been made available to LTM GmbH in a structured, commonly used and machine-readable format.

Right to withdraw consent: There is a right to withdraw consent given for the processing of personal data at any time with effect for the future.

Right to object: Subject to the requirements of Art. 21 GDPR, there is a right to object to the processing of personal data, meaning that LTM GmbH must cease processing this personal data. The right to object exists only within the limits provided for in Art. 21 GDPR. In addition, the interests of LTM GmbH may prevent the termination of processing, so that LTM GmbH may be entitled to process personal data despite the objection.

Right to lodge a complaint with a supervisory authority: Subject to the requirements of Art. 77 GDPR, there is a right to lodge a complaint with a supervisory authority, in particular in the Member State of habitual residence, place of work or place of the alleged infringement, where it is considered that the processing of personal customer data infringes the GDPR. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

The supervisory authority responsible for LTM GmbH is:

The Saxon Data Protection Commissioner
Devrientstraße 5
01067 Dresden
Telephone: 0351/85471-101
Fax: 0351/85471-109
Internet: www.datenschutz.sachsen.de
Email: 

However, LTM GmbH recommends that a complaint should always first be addressed to the company Data Protection Officer.

Requests to exercise rights should, where possible, be addressed in writing to the address stated above under section I or directly to the Data Protection Officer of LTM GmbH.

IX.       Scope of obligations to provide data

In principle, there is no obligation to provide personal data to LTM GmbH. However, if this data is not provided, LTM GmbH will not be able to respond to customer enquiries or enter into a contract, and the LTM GmbH website may not be usable in part. Personal data that LTM GmbH does not necessarily require for the processing purposes mentioned above is marked as voluntary information by “where applicable” or another symbol.

X.        Automated decision-making / profiling pursuant to Article 22 GDPR

LTM GmbH does not use automated decision-making or profiling (an automated analysis of personal circumstances).

XI.       Information on the right to object pursuant to Art. 21 GDPR

1.         There is a right to object at any time to the processing of data carried out on the basis of Art. 6(1)(e) GDPR (data processing in the public interest) or Art. 6(1)(f) GDPR (data processing on the basis of a balancing of interests), where there are grounds relating to a particular situation. This also applies to profiling based on these provisions within the meaning of Art. 4(4) GDPR.

If an objection is made, LTM GmbH will no longer process personal data unless compelling legitimate grounds for the processing can be demonstrated which override the interests, rights and freedoms, or where processing serves the establishment, exercise or defence of legal claims.

2. In individual cases, LTM GmbH also processes personal data for direct marketing purposes. If advertising is not desired, there is a right to object to it at any time; this also applies to profiling insofar as it is connected with such direct marketing. LTM GmbH will observe this objection for the future.

LTM GmbH will no longer process data for direct marketing purposes if the processing for these purposes is objected to.

3. The objection may be made informally and should preferably be sent to:

Leipzig Tourismus und Marketing GmbH
Grimmaischer Steinweg 8
04103 Leipzig, Germany
Tel. +49 341 7104-260
Fax +49 341 7104-271

XII.      Amendments

LTM GmbH reserves the right to amend this privacy policy at any time. Any amendments will be announced by publishing the amended privacy policy on the LTM GmbH website mulderadweg.de. Unless otherwise specified, such amendments shall take effect immediately. It is recommended that this privacy policy be reviewed regularly in order to view the most current version.

This privacy policy is dated 03/05/2022.

I. Controller

Leipzig Tourismus und Marketing GmbH
Grimmaischer Steinweg 8
04103 Leipzig, Germany
Tel. +49 341 7104-260
Fax +49 341 7104-271

II. Data Protection Officer

Leipzig Tourismus und Marketing GmbH
Data Protection Officer Thomas Köhn
Grimmaischer Steinweg 8
04103 Leipzig, Germany
Tel. +49 341 7104-320
Fax +49 341 7104-301

III.        Purposes and legal bases for data processing on the website www.mulderadweg.de

1.         Informational use of the website

The LTM GmbH website can be visited without providing any personal information. If the LTM website is used solely for informational purposes, LTM GmbH does not process any personal data, with the exception of the data transmitted by the browser to enable the visit to the website and information transmitted to LTM GmbH as part of cookies used for the statistical analysis of the use of the LTM website.

a.         Technical provision of the website

For the purpose of technically providing the website, it is necessary for LTM GmbH to process certain automatically transmitted information so that the browser can display the website and the website can be used. This information is automatically collected every time the LTM GmbH website is accessed and stored in server log files. This information relates to the computer system of the accessing computer. The following information is collected:

• IP address (Internet Protocol address) of the accessing computer,
• the website from which the LTM website is accessed (referrer),
• the website visited on the LTM website,
• the date and duration of the visit,
• browser type and browser settings,
• operating system.

Furthermore, LTM GmbH uses cookies to make the website available for use. Cookies are text files that are stored in the internet browser or by the internet browser on the user's computer system when a website is accessed. A cookie contains a characteristic sequence of characters that enables the browser to be uniquely identified when the website is accessed again. LTM GmbH uses these cookies exclusively to provide the website with its technical functions. Some functions of the LTM website cannot be offered without the use of cookies.

LTM GmbH uses cookies to the following extent:

• Transient cookies are temporarily used on the LTM website. These include session cookies in particular. They store a so-called session ID, which allows various browser requests to be assigned to the same session. This means that the browser can be recognised when the website is visited again. Session cookies are deleted when the browser is closed.
• LTM GmbH also uses persistent cookies (limited-time use). These store certain preferences so that they are available when the website is next visited. For example, the language setting can be remembered for 24 hours. Such cookies are automatically deleted after a specified period, which may vary depending on the cookie. Cookies can be deleted at any time in the browser's security settings.

Information collected by LTM GmbH through the aforementioned cookies is not used to create user profiles or analyse browsing behaviour.

LTM GmbH processes personal data for the technical provision of the LTM website on the following legal bases:

• for the performance of a contract or the implementation of pre-contractual measures pursuant to Art. 6(1)(b) GDPR, insofar as the LTM website is visited to obtain information about the services of LTM GmbH, and
• to safeguard the legitimate interests of LTM GmbH pursuant to Art. 6(1)(f) GDPR, in order to be able to technically provide the website. The legitimate interest of LTM GmbH is to provide an appealing, technically functioning and user-friendly website, as well as to take measures to protect the LTM website against cyber risks and prevent cyber risks to third parties from arising from the LTM website.

Use of web fonts
External fonts, Google Fonts, are used on this website. Google Fonts is a service provided by Google Inc. ("Google") (1600 Amphitheatre Parkway, Mountain View, California, 94043). The use of Google Fonts serves to simplify reading on the website and make it more visually appealing. They are used either with prior consent or through local integration. The following may be transmitted to the server and stored by Google:

• Name and version of the browser used
• Website from which the request was initiated (referrer URL)
• Computer operating system
• Computer screen resolution
• IP address of the requesting computer
• Language settings of the browser or operating system used by the user

Further information is available in Google's privacy policy: www.google.com/fonts#AboutPlace:about 

Use of the Outdooractive service
Where the Outdooractive service, in particular map material, is used on this website, the following privacy policy additionally applies:

Outdooractive provides electronic databases that can be used in the form of an electronic information portal in the digital tourism sector. This includes, for example, map and route planning. Outdooractive receives the following data, which is technically necessary for Outdooractive to display the electronic databases and ensure stability and security (the legal basis is Art. 6(1) sentence 1(f) GDPR):

• IP address
• Date and time of the request
• Time zone difference from Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status/HTTP status code
• Amount of data transmitted in each case
• Website from which the request originates
• Browser
• User location
• Operating system and its interface
• Language and version of the browser software.

Outdooractive uses cookies stored in the user's browser for analysis. Outdooractive stores the information collected in this way on servers in Germany and in third countries. Analysis can be stopped by deleting existing cookies and preventing cookies from being stored. If the storage of cookies is to be prevented, please note that the Outdooractive electronic databases cannot be used to their full extent. Cookies can be prevented from being stored through browser settings.

The IP address transmitted by the browser is not merged with other data collected. Outdooractive also uses GPS data when the electronic databases are used.
LTM GmbH has no influence over the data collected and data processing operations, nor is LTM GmbH aware of the full extent of data collection, the purposes of processing or the storage periods. LTM GmbH also has no information regarding the deletion of collected data by Outdooractive.
Outdooractive stores the collected data as usage profiles and uses it for market research and/or the needs-based design of the electronic databases. There is a right to object to the creation of these user profiles, although this must be exercised directly with Outdooractive. The legal basis for using Outdooractive services is Art. 6(1) sentence 1(f) GDPR.
Further information on the purpose and scope of data collection and processing by Outdooractive can be found in Outdooractive's privacy policy. It also contains further information on your rights and settings options for protecting your privacy.

Privacy policy of Outdooractive GmbH & Co. KG, Missener Straße 18, 87509 Immenstadt:

corporate.outdooractive.com/de/datenschutzrichtlinien/

www.outdooractive.com/de/datenschutz.html

Use of Open Street Map
For reasons of data minimisation, the website uses Open Street Map. The OpenStreetMap Foundation, St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, GB – United Kingdom, is a charitable organisation registered in the United Kingdom whose aim is to support the OpenStreetMap project. When the page is accessed, map components are loaded from Open Street Map servers. Data is automatically processed by Open Street Map in this process. Open Street Map uses user data solely for operating and further developing its services. In anonymised form, user data is used for research purposes and made available to the public at https://planet.openstreetmap.org. 

b.        Statistical analysis of the use of the LTM website and increased reach

For the purpose of statistically analysing the use of the LTM website, LTM GmbH uses Google Analytics and thus cookies that enable an analysis of browsing behaviour. This enables LTM GmbH to improve the quality of the LTM website and its content. LTM GmbH learns how the website is used and can therefore continuously optimise the LTM offering.

LTM GmbH processes personal data for the statistical analysis of the use of the LTM website on the following legal basis:

• Consent pursuant to Art. 6(1)(a) GDPR.

Google Analytics

On the LTM website, LTM GmbH uses Google Analytics, a web analytics service provided by Google Inc., USA. Google Analytics uses so-called "cookies", text files that are stored on the user's computer and enable analysis of how the website is used. The information generated by the cookie about use of the LTM website is generally transmitted to and stored on a Google server in the USA. However, if IP anonymisation is activated on the LTM website, Google will truncate the IP address beforehand within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of LTM GmbH, Google will use this information to evaluate use of the website, compile reports on website activities and provide other services to the website operator related to website and internet use. The IP address transmitted by the browser within the scope of Google Analytics will not be merged with other Google data.

On the LTM website, LTM GmbH uses Google Analytics with the "_anonymizeIp()" extension. This means that IP addresses are further processed in truncated form, thereby excluding the possibility of direct personal identification.

LTM GmbH uses Google Analytics exclusively with prior consent. This consent, once given, can be withdrawn by

• preventing the storage of cookies through an appropriate setting in the browser software; however, LTM GmbH points out that in this case it may not be possible to use all functions of the LTM website in full,
• downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de 
• preventing future data collection by Google Analytics on the LTM website. An opt-out cookie is stored in the browser for this purpose. Please note that the opt-out cookie must be activated in every browser used on all devices and may need to be reactivated if all cookies in a browser are deleted.

Further information on terms of use and data protection at Google Analytics is available here: https://www.google.de/intl/de/policies/

Google Analytics Remarketing

The LTM website uses the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google AdWords. The provider is Google Inc., USA.

This function makes it possible to link advertising target groups created with Google Analytics Remarketing with the cross-device functions of Google AdWords. In this way, interest-based, personalised advertising messages that have been tailored according to previous usage and browsing behaviour on one device (e.g. mobile phone) can also be displayed on another device (e.g. tablet or PC).

If you have given the relevant consent, Google links your web and app browsing history with your Google account for this purpose. This allows the same personalised advertising messages to be placed on every device on which you sign in to your Google account.

To support this function, Google Analytics collects Google-authenticated user IDs, which are temporarily linked to our Google Analytics data in order to define and create target groups for cross-device advertising.

You can permanently object to cross-device remarketing/targeting by disabling personalised advertising in your Google account: www.google.com/settings/ads

The combination of the collected data in your Google account takes place exclusively on the basis of your consent, which can be given to or withdrawn from Google (Art. 6(1)(a) GDPR). For data collection processes that are not combined in your Google account (e.g. because no Google account exists or you have objected to the combination), data collection is based on Art. 6(1)(f) GDPR. The legitimate interest arises from the fact that LTM GmbH, as the website operator, has an interest in the anonymised analysis of website visitors for advertising purposes.

Further information and the data protection provisions can be found in Google's privacy policy at: policies.google.com/technologies/ads.

2.        Active use of the website

In addition to purely informational use of the LTM website, the website can also be actively used to order an LTM product or contact LTM GmbH. In addition to the processing of personal data described above for purely informational use, LTM GmbH then also processes further personal data required to process orders or deal with and answer enquiries.

a.        User enquiries

In order to process and answer enquiries to LTM GmbH, for example via the contact form, order forms for information material and merchandise, or email address, LTM GmbH processes the personal data provided in this context. This always includes the name and email address in order to receive a reply, as well as other information sent to LTM GmbH in communications.

LTM GmbH processes personal data to answer user enquiries on the following legal basis:

• to safeguard the legitimate interests of LTM GmbH pursuant to Art. 6(1)   (f) GDPR; the legitimate interest is the appropriate response to customer enquiries.

b.        Ordering information materials and merchandise

In the event of an order for information materials and/or merchandise, the personal data is transmitted to LTM GmbH for the purpose of processing the order. This also constitutes the legitimate interest of LTM GmbH pursuant to Art. 6(1)(b) GDPR. The data will be deleted by LTM GmbH as soon as it is no longer required for the stated purposes or after the expiry of applicable statutory requirements.

Providing the data is neither legally nor contractually required. There is no obligation to provide personal data. If processing is objected to, this means that no booking/order can be made with LTM GmbH.

c.        Use of Typeform for surveys and feedback

Description and scope of data processing
We use the Typeform service for the defect reporting tool and feedback form on our website. The provider is Typeform S.L., Carrer de Bac de Roda, 163, 08018 Barcelona, Spain (hereinafter "Typeform").

If you take part in one of our surveys or complete a form, the data you enter (e.g. name, email address, free-text responses) is transmitted to Typeform's servers and stored there. In addition, Typeform collects technical data during use, such as your IP address, browser type, operating system, and the date and time of access.

As Typeform is a globally operating company, it cannot be ruled out that data may also be transferred to servers of its parent company, Typeform Inc., in the USA. Typeform uses standard contractual clauses (SCCs) approved by the European Commission to guarantee an adequate level of data protection.

Purpose of data processing
Typeform is used to offer you a user-friendly and interactive way to contact us, leave feedback or participate in surveys. This helps us to continuously improve our services and customer service.

Legal basis for data processing
Your data is processed on the basis of your consent in accordance with Art. 6(1)(a) GDPR. You actively give this consent by agreeing to the use of Typeform via our cookie consent banner or by ticking the relevant checkbox before submitting the form.

Insofar as technical basic data (such as the IP address) is strictly necessary to display the form correctly on our website, processing is based on our legitimate interest in the secure and functional provision of our website pursuant to Art. 6(1)(f) GDPR.

Storage period
The data is stored for as long as is necessary to achieve the purpose for which it was collected (e.g. until the relevant survey has been fully evaluated) or until you withdraw your consent. The data will then be deleted, provided that there are no statutory retention obligations to the contrary.

Right of withdrawal and removal
You can withdraw your consent to data processing at any time with effect for the future. Simply contact us by email using the contact details stated in the legal notice. Please note that data already processed has been processed lawfully up to the time of withdrawal.

Further information on data protection and Typeform settings can be found in the provider's privacy policy at: typeform.com

Data processing agreement
We have concluded a data processing agreement (Data Processing Addendum, DPA) with Typeform. In it, Typeform undertakes to process the data of our website visitors strictly in accordance with our instructions and to comply with the high European level of data protection.

d.        Compliance with legal requirements

LTM GmbH also processes personal data in order to fulfil other legal obligations affecting LTM GmbH in connection with order processing. These include, in particular, retention periods under commercial, trade or tax law.

LTM GmbH processes personal data on the following legal bases:

• to fulfil a legal obligation to which LTM GmbH is subject pursuant to Art. 6(1)(c) GDPR in conjunction with commercial, trade or tax law, insofar as LTM GmbH is obliged to record and retain the data.

e.         Enforcement of legal claims

LTM GmbH also processes personal data in order to assert its own rights and enforce its own legal claims. LTM GmbH also processes personal data in order to defend the company against legal claims. Finally, LTM GmbH processes personal data insofar as this is necessary to prevent or prosecute criminal offences.

LTM GmbH processes personal data for this purpose on the following legal bases:

• to safeguard the legitimate interests of LTM GmbH pursuant to Art. 6(1)   (f) GDPR, insofar as LTM GmbH can assert legal claims or defend itself in legal disputes, or criminal offences can thereby be prevented or investigated.

f.        Use of data for email advertising and right to object

If LTM GmbH receives your email address in connection with the provision of LTM products and you have not objected, LTM GmbH reserves the right to regularly send you offers of similar products from the LTM range by email. You may object to this use of your email address at any time by sending a message to the contact option described below or via a link provided for this purpose in the advertising email, without incurring any costs other than the transmission costs according to the basic rates.

IV.        Links and social links

a.         Links

Some sections of the LTM website contain links to third-party websites. These websites are subject to their own privacy policies. LTM GmbH is not responsible for their operation, including data handling. If information is sent to or via such third-party sites, the privacy policies of those sites should be reviewed before providing information that can be associated with a person.

b.         Social links

The LTM website includes links to services such as Instagram and YouTube. Once the link is clicked, you will be redirected to the respective provider's page, i.e. user information is only then transmitted to the respective provider. Please refer to the respective providers' privacy notices for information on how your data is handled when using other providers' websites.

V.        Recipients or categories of data recipients

Within LTM GmbH, those internal departments receive data that require it to fulfil contractual and legal obligations or in the context of processing and implementing LTM GmbH's legitimate interest. In addition, LTM GmbH shares personal data, insofar as this is legally permitted or required, with other recipients who provide services for LTM GmbH in connection with the LTM website. LTM GmbH limits the disclosure of personal data to what is necessary, in particular in order to process the order/booking. In some cases, LTM service providers receive personal data as processors and are then strictly bound by the instructions of LTM GmbH when handling personal data.

The categories of personal data recipients are listed below:

• external service providers for ordering information materials
• logistics service providers to deliver goods,
• IT service providers for the administration and hosting of the LTM website,
• where applicable, further categories of recipients.

VI.        Storage period

Informational use of the website

When the LTM website is used solely for informational purposes, LTM GmbH stores personal data on its servers only for the duration of the visit to the LTM website. Once the LTM website is left, the personal data is deleted immediately.

Cookies installed by LTM GmbH are also generally deleted after leaving the LTM website. However, this does not apply to persistent cookies (including cookies used by Google Analytics), which are automatically deleted after a specified period that may vary depending on the cookie - maximum storage period one year (see III. / 1. / a. and b.).

It is also possible at any time to delete installed cookies yourself (see III /1. / a. and b.).

Active use of the website

When the LTM website is actively used, LTM GmbH initially stores personal data for the duration of responding to an enquiry or for the duration of the business relationship. This also includes initiating a contract (pre-contractual legal relationship) and performing a contract.

In addition, LTM GmbH then stores personal data until any legal claims become time-barred in order to use it as evidence if necessary. The limitation period is generally between 12 and 36 months, but may also be up to 30 years.

Once the limitation period has expired, LTM GmbH deletes personal data unless there is a statutory retention obligation, for example under the German Commercial Code (Sections 238, 257(4) HGB) or the German Fiscal Code (Section 147(3), (4) AO). These retention obligations may last from two to ten years.

VII.        Third-country transfers

When using Google tools, LTM GmbH transfers the truncated IP address to the USA. The data transfer is based on Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequacy of the protection provided by the EU-US Privacy Shield.

Otherwise, LTM GmbH does not transfer personal data to countries outside the EU or EEA or to international organisations.

VIII.       Your data protection rights as a data subject

Subject to the statutory requirements, you have the following rights as a data subject, which may be asserted against LTM GmbH:

Right of access: Pursuant to Art. 15 GDPR, you have the right to request confirmation from LTM GmbH as to whether LTM GmbH processes personal data; where this is the case, pursuant to Art. 15 GDPR, you have the right to obtain information about this personal data and certain other information (including processing purposes, categories of personal data, categories of recipients, planned storage period, origin of the data, use of automated decision-making and, in the case of third-country transfers, appropriate safeguards) and a copy of your data (possibly subject to restrictions under Section 34 BDSG).

Right to rectification: Pursuant to Art. 16 GDPR, you have the right to request that LTM GmbH rectifies stored personal data if it is inaccurate or incorrect.

Right to erasure: Subject to the conditions of Art. 17 GDPR, you have the right to request that LTM GmbH deletes the relevant personal data without undue delay. The right to erasure does not apply, among other things, if processing of personal data is necessary for exercising the right to freedom of expression and information, for compliance with a legal obligation to which LTM GmbH is subject (e.g. statutory retention obligations), or for the establishment, exercise or defence of legal claims.

Right to restriction of processing: Subject to the conditions of Art. 18 GDPR, you have the right to request that LTM GmbH restricts the processing of its customers' personal data.

Right to data portability: Subject to the conditions of Art. 20 GDPR, you have the right to request that LTM GmbH provides the personal data supplied to LTM GmbH in a structured, commonly used and machine-readable format.

Right to withdraw consent: You have the right to withdraw your consent to the processing of personal data at any time with effect for the future.

Right to object: Subject to the conditions of Art. 21 GDPR, you have the right to object to the processing of personal data, with the consequence that LTM GmbH must cease processing personal data. The right to object applies only within the limits provided for in Art. 21 GDPR. In addition, the interests of LTM GmbH may prevent the processing from being terminated, so that LTM GmbH may remain entitled to process personal data despite the objection.

Right to lodge a complaint with a supervisory authority: Subject to the conditions of Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data infringes the GDPR. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

The supervisory authority responsible for LTM GmbH is:

The Saxon Data Protection Commissioner
Devrientstraße 5
01067 Dresden
Telephone: 0351/85471-101
Fax: 0351/85471-109
Internet: www.datenschutz.sachsen.de
Email: 

However, LTM GmbH recommends that you always first address a complaint to the company data protection officer.

Requests to exercise rights should, where possible, be addressed in writing to the address stated above under section I or directly to the data protection officer of LTM GmbH.

IX.       Scope of obligations to provide data

In principle, there is no obligation to provide LTM GmbH with personal data. However, if this is not done, LTM GmbH will not be able to answer customer enquiries, enter into a contract, and the LTM GmbH website may not be usable in part. Personal data that LTM GmbH does not necessarily require for the processing purposes stated above is marked as voluntary information by "where applicable" or another symbol.

X.         Automated decision-making / profiling pursuant to Article 22 GDPR

LTM GmbH does not use automated decision-making or profiling (an automated analysis of personal circumstances).

XI.         Information on the right to object pursuant to Art. 21 GDPR

1. You have the right to object at any time to the processing of data based on Art. 6(1)(e) GDPR (data processing in the public interest) or Art. 6(1)(f) GDPR (data processing on the basis of a balancing of interests), where there are reasons arising from your particular situation. This also applies to profiling based on these provisions within the meaning of Art. 4(4) GDPR.

If you object, LTM GmbH will no longer process personal data unless it can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

2. In individual cases, LTM GmbH also processes personal data for direct marketing purposes. If you do not wish to receive advertising, you have the right to object at any time; this also applies to profiling insofar as it is connected with such direct marketing. LTM GmbH will observe this objection for the future.

LTM GmbH will no longer process the data for direct marketing purposes if you object to processing for these purposes.

3. The objection may be made in any form and should preferably be addressed to:

Leipzig Tourismus und Marketing GmbH
Grimmaischer Steinweg 8
04103 Leipzig, Germany
Tel. +49 341 7104-260
Fax +49 341 7104-271

XII.         Copyright

The content and works created by LTM GmbH on the LTM website are subject to German copyright law. Reproduction, editing, distribution and any kind of use outside the limits of copyright law require the written consent of the respective author or creator. Downloads and copies of the LTM website are permitted only for private, non-commercial use. Where content on this website was not created by the operator, third-party copyrights are respected. In particular, third-party content is identified as such. Should you nevertheless become aware of a copyright infringement, LTM GmbH requests that you notify it accordingly. Upon becoming aware of legal infringements, LTM GmbH will remove such content immediately.

XIII.        Changes

LTM GmbH reserves the right to amend this privacy policy at any time. Any changes will be announced by publishing the amended privacy policy on the LTM GmbH website www.mulderadweg.de. Unless otherwise specified, such changes will take effect immediately. You are advised to review this privacy policy regularly to view the most current version.

This privacy policy is dated 3 May 2022.