Privacy Policy

  • Definitions
  • Name and Address of the controller
  • Cookies
  • Collection of general data and information
  • Registration on our website
  • Subscription to our newsletters
  • Newsletter Tracking
  • Contact possibility via the website
  • Routine erasure and blocking of personal data
  • How we use your personal data
  • How is your personal data collected
  • Your Rights
  • Data protection for applications and the application procedures
  • Legal basis for processing personal data
  • The legitimate interests pursued by us or by a third party
  • Period for which the personal data will be stored
  • Data security
  • Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
  • Existence of automated decision-making
  • Use of Google Analytic
  • Use of Google AdWords Conversion Tracking
  • Use of Google Maps
  • Use of Google Remarketing
  • Use of Web fonts
  • Use of Instagram
  • Use of Facebook
  • Use of Elfsight
  • Use of Content delivery networks (CDN)
  • This site is hosted on the service provider webflow.com.
  • We use Cool Cousin (8 Dror st., Tel Aviv) on our website and in our emails.
  • Glossary

We are delighted that you have shown interest in our company. Data protection is of particularly high importance for the management of Vonder. The use of the Vonder website is possible without any indication of your personal data; however, if you want to use our special enterprise services via our website, processing your personal data may become necessary. If the processing of your personal data is necessary and there is no statutory basis for such processing, we will obtain consent from you as the data subject. The processing of your personal data, such as your name, address, e-mail address, or telephone number subject shall always be in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection laws applicable to Vonder. By means of this data protection declaration and policy, we would like to inform you and the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, you are informed, by means of this data protection declaration, of the rights to which you are entitled.

Controller

Vonder is made up of different legal entities, details of which can be found below (“Vonder Group”):

  • Vonder UK Limited: a company registered in England and Wales under company number 11623330 and whose registered office is at 60 Welbeck Street, London, United Kingdom, W1G 9XB.

  • Vonder UK Accommodation Limited: a company registered in England and Wales under company number 12198896 and whose registered office is at 60 Welbeck Street, London, United Kingdom, W1G 9XB.

VAT number: GB 332994772

  • Vonder GmbH: a company registered in Germany whose office is at Schlüterstr. 45, Charlottenburg, Berlin, 10707

EU VAT number: DE294625257

  • Vonder Poland Sp. Z o.o.: a company registered in Poland whose office is at 24 Solec Street Unit 10 00-403, Warsaw

EU VAT number: PL 5252799689

This privacy policy is issued on behalf of the Vonder Group so when we mention "Vonder", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Vonder Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Vonder Group is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any of the below stated legal rights, please contact the DPO using the details set out below.

Name or title of DPO: Tony Pegrum
Email address: DPO@vondereurope.com
Postal address: 60 Welbeck Street, London, United Kingdom, W1G 9XB

As the controller, Vonder Group has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, you are free to transfer personal data to us via alternative means, e.g. by telephone. 

This privacy policy aims to give you information on how Vonder collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or make a booking through our website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 17 March 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. Definitions

The data protection declaration of Vonder is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would first like to explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:

a)    Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c)    Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

d)    Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e)    Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. 

f)     Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g)    Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. 

h)    Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. 

i)      Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing. 

j)      Third party

Third party is a natural or legal person, public authority, agency or body other than you, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k)    Consent

Consent is any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of your personal data. 

  1. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:


Vonder GmbH
Schlüterstr. 45

10707 Berlin
Germany
Website: www.vondereurope.com

You have the right to make a complaint at any time to the relevant Data and Privacy regulatory bodies. We would, however, appreciate the chance to deal with your concerns before you approach any of these bodies, so please contact us in the first instance.

  1. Cookies

The Internet pages of Vonder use cookies. Cookies are text files that are stored in a computer system via an Internet browser. Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate your individual browser from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID. Through the use of cookies, Vonder can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimised with the user in mind. Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. The website user that uses cookies does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie. You may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the you deactivate the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable. For more information on our Cookies policy, please refer to the policy by following this link: [LINK]

  1. Collection of general data and information

The website of Vonder collects a series of general data and information when you or an automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. When using these general data and information, Vonder does not draw any conclusions about you. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website, as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Vonder analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided.



  1. Registration on our website

You have the possibility to register on our website with the indication of personal data. Which personal data are transmitted to us is determined by the respective input mask used for the registration. The personal data entered by you are collected and stored exclusively for our internal use, and for his own purposes. We may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to us. By registering on our website, the IP address—assigned by the Internet service provider (ISP) and used by the you—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure us. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution. Your registration, with the voluntary indication of personal data, is intended to enable us to offer you contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from our data stock. We shall, at any time, provide information upon your request as to what personal data are stored about you. In addition, we shall correct or erase personal data at your request or indication, insofar as there are no statutory storage obligations. The entirety of our employees are available to you in this respect as contact persons.



  1. Subscription to our newsletters

On our website, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from us. Vonder informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by you if (1) you have a valid e-mail address and (2) you register for the newsletter. A confirmation e-mail will be sent to the e-mail address you have registered. This confirmation e-mail is used to prove to verify your identity and confirm that you are authorised to receive the newsletter. During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by you at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to understand the (possible) misuse of your e-mail address at a later date, and it therefore serves the aim of our legal protection. The personal data collected as part of the registration for our newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by you at any time. The consent to the storage of personal data, which you have given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on our website, or to contact us and request the same.

  1. Newsletter Tracking

Our newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when an e-mail was opened, and which links in the e-mail were used. Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by us in order to optimise the shipping of the newsletter, as well as to adapt the content of future newsletters even better to your interests. You are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, this personal data will be deleted by us. We automatically consider a withdrawal from the receipt of the newsletter as a revocation.

  1. Contact possibility via the website

Our website contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If you contact us by e-mail or via a contact form, the personal data transmitted are automatically stored. Such personal data transmitted on a voluntary basis to us are stored for the purpose of processing or contacting you.

  1. Routine erasure and blocking of personal data

We shall process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which we are subject to. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

The lawful basis on which Vonder uses your data is set out below.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or made a booking with us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of making a booking.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;

  • create an account on our website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please refer to our cookie policy for further details.



  1. Your Rights

a) Right of confirmation

You shall have the right granted by the European legislator to obtain from us the confirmation as to whether or not personal data concerning you are being processed. If you wish to avail yourself of this right of confirmation, he or she may, at any time, contact any of our employees.

b) Right of access

You shall have the right granted by the European legislator to obtain from us free information about your personal data stored at any time and a copy of this information.

Furthermore, the European directives and regulations grant you access to the following information:
– the purposes of the processing;

– the categories of personal data concerned;
– the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

– where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
– the existence of the right to request from us the rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing;
– the existence of the right to lodge a complaint with a supervisory authority;

– where the personal data are not collected from you, any available information as to their source;
– the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

Furthermore, you shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, you shall have the right to be informed of the appropriate safeguards relating to the transfer. If you wish to avail yourself of this right of access, he or she may, at any time, contact any of our employees.


c) Right to rectification 


You shall have the right granted by the European legislator to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may, at any time, contact any of our employees.

d) Right to erasure (Right to be forgotten)

You shall have the right granted by the European legislator to request us to erase your personal data without undue delay, and we shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary: 
– The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
– You withdraw consent which formed the legal basis of processing according to Article 6(1)(a) of the GDPR, or Article 9(2)(a) of the GDPR, and where there is no other legal ground for the processing.

– You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR. 
– The personal data have been unlawfully processed.
– The personal data must be erased for compliance with a legal obligation in Union or Member State law to which we are subject.

– The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by us, you may, at any time, contact any of our employees. An employee of Vonder shall promptly ensure that the erasure request is complied with immediately. Where we have made personal data public and are obliged pursuant to Article 17(1) GDPR to erase the personal data, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that you have requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of Vonder will arrange the necessary measures in individual cases.



e) Right to request restriction of processingof your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.



f) Right to data portability

You shall have the right granted by the European legislator to receive the personal data concerning you, which was provided to us, in a structured, commonly used and machine-readable format. You shall have the right to transmit those data to another controller without hindrance from us, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Furthermore, in exercising your right to data portability pursuant to Article 20(1) of the GDPR, you shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, you may at any time contact any of our employees.

g) Right to object

You shall have the right granted by the European legislator to object, on grounds relating to your particular situation, at any time, to processing of personal data concerning you, which is based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions. Vonder shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. If Vonder processes personal data for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If you object to Vonder in relation to the processing for direct marketing purposes, Vonder will no longer process the personal data for these purposes. In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you by Vonder for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, you may contact any employee of Vonder. In addition, you are free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use your right to object by automated means using technical specifications.



h) Automated individual decision-making, including profiling

You shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the you and us, or (2) is not authorised by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between you and us, or (2) it is based on your explicit consent, Vonder shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express your point of view and contest the decision. If you wish to exercise the rights concerning automated individual decision-making, you may, at any time, contact any employee of Vonder.



i) Right to withdraw data protection consent


You shall have the right granted by the European legislator to withdraw your consent to processing of your personal data at any time. If you wish to exercise the right to withdraw the consent, you may, at any time, contact any employee of Vonder.



11. Data protection for applications and the application procedures

We shall collect and process the personal data of applicants for the purpose of the processing of the application. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on our website. If we conclude an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests are opposed to the erasure.

12. Legal basis for processing personal data

Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as the fulfilment of our tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect your vital interests or those of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if you are our client/customer (Recital 47 Sentence 2 GDPR). 


13. The legitimate interests pursued by us or by a third party

Where the processing of personal data is based on Article 6(1)(f) GDPR our legitimate interest, it means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience, as well as carry out our business in favour of the well-being of all our employees and the shareholders. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

14. Period for which the personal data will be stored

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

16. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data.

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that you provide your personal data, which must subsequently be processed by us. You are, for example, obliged to provide us with personal data when our company signs a contract with you. The non-provision of the personal data would have the consequence that the contract with you could not be concluded. Before personal data is provided by you, you must contact any employee. The employee clarifies to you whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

17. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

18. Use of Google Analytics


Our internet page use Google Analytics, an internet analysis service from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA which uses cookies. We use Google Analytics with the extension _anonymise IP, which can ensure the anonymisation of the IP address and so preventing the possibility of directly linking it to any particular individual. This means that your IP address is shortened by Google. Only in exceptional cases will the whole IP address be transferred to a Google server in the USA and shortened there. In these cases, the processing takes place pursuant to Article 6 (f) GDPR to realise our legitimate interests for marketing purposes and to sustain the attractiveness of our website. The IP address sent by your browser will not be connected to other data from Google. You can prevent the storing of cookies by selecting the respective settings in your browser software. In addition, you can also prevent the sampling of data produced by the cookie and associated with your use of the website, as well as its processing by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. ‍If you no longer wish for the anonymised analysis of your website use by Google Analytics, you can opt out at any time. By clicking on the link, an opt-out cookie will be saved to your device. If you visit our website again, this cookie prevents your data from being collected. In order to prevent data collection by Google Analytics across multiple devices, you need to carry out the opt-out on all systems used. Google LLC, based in the USA, is certified as part of the US-European data protection agreement “Privacy Shield” which guarantees compliance with the data protection level applicable in the EU.

More information on how Google Analytics handles user data is available in the Google Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=de.

19. Use of Google AdWords Conversion Tracking


Google AdWords, an online advertising and conversion tracking program is used on our website. Google Conversion Tracking is a systematic administration given by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. When you tap on an advert conveyed by Google, a cookie is stored on your PC. These cookies become invalid after 30 days and contain no close to home data and in this way do not serve for individual distinguishing proof. If you visit particular pages on our website and the cookie has not yet lapsed, we and Google can identify that you have tapped on the advert and have been diverted to that page. Each Google AdWords client gets an alternate cookie. There is a probability that cookies can be followed by means of the sites of AdWords clients. The data assembled by this change cookie serves to create transformation measurements for AdWords clients. Clients can discover the aggregate number of clients who have tapped on their advert and were coordinated to a page utilising the transformation following tag. In any case, clients do not get any data that can be utilised to distinguish various clients. If you do not want to participate, you can reject this use by preventing the installation of cookies by selecting the appropriate settings in your browser (disable option). By doing so, you will not be included in the conversion tracking statistics. If you would prefer not to take part in following, you can dismiss this feature by keeping the establishment of cookies by choosing the fitting settings in your program (disable alternative). Thus you will not be incorporated into the transformation following measurements. You can discover more information and in addition the Google privacy policy a
t http://www.google.com/policies/technologies/ads/,  http://www.google.de/policies/privacy/



20. Use of Google Maps


We utilise Google Maps (API) on our site from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Maps is a web benefit for showing intelligent (nation) maps for exhibiting land data outwardly. Utilising this administration will demonstrate to you our area and encourage discovering headings to contact us. The above information processing takes place pursuant to Article 6 (f) GDPR for marketing purposes and maintaining the engaging quality of our website. Each time Google Maps is opened, Google sets a cookie with a specific end goal to process client settings and information while showing the page on which the Google Maps segment is coordinated. This cookie is not erased on shutting the program, however rather lapses after a particular timeframe except if you physically erase it before such time. In the event that you are not in agreement with this processing of your personal data, you may deactivate the Google Maps benefit and keep the transmission of information to Google. To do this, you need to deactivate the JavaScript work in your program

The use of “Google Maps” and the information attained via “Google Maps” is governed by Google’s terms of use https://policies.google.com/terms?hl=de&gl=de ‍as well as the additional terms and conditions for “Google Maps” https://www.google.com/intl/de_US/help/terms_maps.html



21. Use of Google Remarketing


We utilise the Google Remarketing service on our site, an administration given by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Google Remarketing may be utilised to circulate notices for customers that have visited our site previously. Inside the Google promoting system, notices are adjusted to your interests and may be shown on our website. Google Remarketing utilises cookies for this assessment. This makes it possible to recognise customers that visit site destinations inside the Google promoting system. Along these lines, advertisements may be shown inside the Google promoting system by identifying content that the user has already used on sites inside this system. As indicated by its own data, Google gathers individual data as a feature of this. You can deactivate this element by changing the comparing settings in https://adssettings.google.com/.



22. Use of Web fonts


External fonts, Google fonts are used on these Internet pages. Google fonts is a service of Google Inc. (Google). The integration of these Web fonts is done by a server call, typically a server by Google in the United States. This is submitted to the server of our web pages that you have visited. Also, the IP address of the browser of the terminal equipment of the visitor of this website from Google is stored. For more information, see the privacy notice by Google, which you can get here:
www.Google.com/fonts#AboutPlace:www.Google.com/policies/privacy/.



23. Use of Instagram


Our site utilises social modules by Instagram, which are worked by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA. These modules are set apart with an Instagram logo, e.g. as an Instagram camera. When you visit a page of our site containing said module, your program sets up an immediate association with Instagram’s servers. The substance of the module is sent from Instagram straightforwardly to your program and incorporated into the page. Through this incorporation, Instagram gets the data that your program has gotten to the relating page on our site, regardless of whether you don’t have an Instagram account or are not as of now signed in to Instagram. This data (counting your IP address) is transmitted by your program straightforwardly to an Instagram server in the USA and put away there. If you are signed in to Instagram, Instagram can straightforwardly interface your visit to our site to your Instagram account. On the off chance that you connect with the modules, e.g. by tapping the “Instagram” catch, this data is additionally sent specifically to an Instagram server and put away there. The data is additionally distributed on your Instagram record and showed to your contacts there. Please visit Instagram’s security arrangement for additional information on the reason and extent of information gathering and the further processing and utilisation of information by Instagram, and your related rights and settings alternatives for ensuring your protection:
https://help.instagram.com/155833707900388/. In the event that you do not need Instagram to directly connect the information collected on our site to your Instagram account, you need to log out of Instagram before visiting our website. You can likewise keep Instagram modules from stacking utilising additional items for your program.



24. Use of Facebook


Our site utilises social modules by Facebook, which are provided by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. When you visit our website containing said module, your program sets up an immediate association with Facebook’s servers. The substance of the module is sent from Facebook directly to your program and incorporated into the page. Through this coordination, Facebook received the data that your program has gotten to the relating page on our website, regardless of whether you do not have a Facebook account or you are not signed in on Facebook. This data (including your IP address) is transmitted by your program directly to a Facebook server in Ireland and stored there. If you are signed in on Facebook, Facebook can directly interface your visit to our website to your Facebook account. If you communicate with the modules, e.g. by tapping the Facebook catch, this data is additionally sent directly to a Facebook server and stored there. The data is likewise distributed on your Facebook record and showed to your contacts there. Please see Facebook’s security arrangement for additional on the reason and extent of information gathering and the further processing and utilisation of information by Facebook, and also your related rights and settings alternatives for ensuring your protection:
https://www.facebook.com/about/security/ Quit: https://www.facebook.com/settings?tab=ads In the event that you do not wish for Facebook to specifically connect the information accumulated on our site to your Facebook account, you need to log out of Facebook before visiting our site. You can likewise keep Facebook modules from stacking and utilising additional items for your program. 

25. Use of Elfsight


We use the services of Elfsight to include Instagram photos. Details on the handling of personal data by Elfsight and related rights are provided in the privacy notice by Elfsight:
https://elfsight.com/privacy-policy/25.



26. Use of Content delivery networks (CDN)

On this page, we use technologies of CDN servers (content delivery network), thus the optimisation of the loading speed is achieved. In this regard, general libraries are called servers. Should you have previously used the library on a different page from the CDN, your browser will rely on the copy stored in the cache. This requires a download, connection information, such as your IP address, from your browser to the CDN will be transferred.-code.jquery.com-cdnjs.cloudflare.com.



27. This site is hosted on the service provider webflow.com.

More information about the privacy policy of Webflow.com the following link (English): https://webflow.com/privacy



28. We use Cool Cousin (8 Dror st., Tel Aviv) on our website and in our emails.

Cool Cousin is a web service which provides travel guides for us consisting of local recommendations for the improvement of your stay experience and will be sent to you as a service by us. Every time Cool Cousin is opened, it sets a cookie in order to configure the travel guide and provide a better experience during future usages of the guides. This cookie expires after a specific period of time unless you manually delete it before such time. Cookies can also be disabled by selecting the relevant settings in your browser. The Cool Cousin service also consists of a map component, though the company does not collect any location-related data through usage. To see their privacy policy please visit www.coolcousin.com.



29. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business as further defined in 13 above.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Vonder Group acting as joint controllers or processors and who are based in the UK, Germany, Poland, Ireland, Malta and Cyprus. and provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in Germany, Switzerland, the United States, Israel who provide IT and system administration services in order to process bookings, reservations, and promotional online campaigns.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, Germany and Poland who provide consultancy, banking, legal, insurance and accounting services.

YOUR LEGAL RIGHTS

You have the right to:

Request accessto your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processingof your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transferof your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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