1. General
Passo Tourismo GmbH, Elsässer Strasse 32, 81667 Munich, Federal Republich of Germany
(“Passo Tourismo”) respects the privacy of customers and users of its platform. This Data
Protection Policy lays down provisions on the protection and processing (collection, processing,
use and disclosure) of the personal data collected by Passo Tourismo from customers and users
of its platform.
Passo Tourismo observes the German Data Protection Act (Datenschutzgesetz) and the data
protection law of the EU (collectively “applicable data protection law”). Customers and users need
to provide their personal data to use Passo Toursimo’s services.

2. Types Of Personal Data
2.1 Data collected directly from customers/users to implement a contract.
Passo Tourismo collects the following data from its customers and users:

  • Basic data (first name and surname (including title), address, email address, telephone
    number, date of birth) when a user contacts a customer,
  • Data on the Listing posted,
  • Data on the services/products provided by Passo Tourismo,
  • Data on contact between users/customers and Passo Tourismo (including copies of all
    messages that are sent directly through the Passo Tourismo E-mail System).

2.2 Data collected automatically to optimise services (analytics tools)

2.2.1 Usage analysis by Passo Tourismo
Passo Tourismo does not analyses customer/user behaviour on its platform using cookies.
Cookies are packets of data that are sent from Passo Tourismo’s web server to your browser,
saved on your computer and retrieved by the web server again during subsequent visits.

2.2.2 Usage analysis by Google Analytics
The Passo Tourismo Platform also uses Google Analytics, a web analytics service provided by
Google Inc. (“Google”). Google Analytics uses cookies to provide its web analytics services. The
information generated by the cookies about your use of this website (including your IP address) is
transferred to a Google server that may be outside EU and stored there. Google uses this
information to analyse your use of the website, compile reports on website activity for the website
operators and provide other services related to use of the website and the internet. Google may
also transfer this information to third parties, if required to do so by law or if third parties process
this information on Google’s behalf. Customers and/or Users can prevent cookies being installed
by using the appropriate setting in their browser software; Passo Tourismo would, however, like to
point out that doing so will mean that not all of the website’s functions may be used to their fullest
extent. By using this website Customers and/or Users agree to allow Google to process the data
collected about them in the manner described above and for the purposes described above. For
further information on Google Analytics, Passo Tourismo recommends you visit the following

3. Intended Use Of The Data Collected
Passo Tourismo processes customer/user data for the following purposes:

  • to perform contracts/services (establish contact between customers and users, process
    orders, reservations and to fulfil bookings and rentals),
  • to safeguard payment transactions between customers and users,
  • to communicate with customers and users,
  • to fulfil legal obligations,
  • to improve Passo Tourismo’s products and services and their position on the market
    (including dispatching the newsletter, if you have subscribed),
  • to compile statistics on contact made through the Passo Tourismo platform.

4. Data Processing By Third Parties In The EU And Abroad
Passo Tourismo may also have personal data processed by third parties in the EU and/or abroad
for the purpose of running the platform and for the purposes stated in Section 3.

4.1 Categories of external service providers
Such recipients of personal data include suppliers in the field of payment services, password
administration, platforms for managing dispatch of the newsletter, logistics companies and data
centres for storing and processing the data collected. When doing so, Passo Tourismo ensures
that adequate assurance is given to protect the personal data in accordance with the applicable
data protection law and that corresponding agreements have been concluded with each of the
external suppliers.
Passo Tourismo’s servers are located in The Federal Republic of Germany and run by a German
host provider.

4.2 Social media plug-ins
Functions from various third-party providers of social media platforms (such as Facebook, Twitter,
Google+) are integrated into the Passo Tourismo platform. Plug-ins enable users to share content
on social networks.
If a plug-in is displayed when browsing the Passo Tourismo platform (e.g. Facebook’s “Like”
button), a connection with the relevant third-party provider’s servers is automatically established.
This means that data on customers’ and users’ visit to the website can be transmitted to these
third-party providers. If the customer or user is also registered with this third-party provider’s
network, the visit to the website may also be assigned to their network account (e.g. Facebook
Passo Tourismo has no control over the method of this type of data transmission. The purpose
and scope of the data collection and the subsequent processing and use of the data by the
relevant social media providers as well as the related rights and configuration options for privacy
protection can be found in the privacy notices of the relevant third-party providers.

5. Data Security
Passo Tourismo does not pass its customers’ data on to third parties under any circumstances,
except for to the external service providers in accordance with Section 4, and solely uses their
data for the purposes stated in Section 3. Passo Tourismo also uses state-of-the-art technology
to take the usual steps to protect the data. However, Passo Tourismo provides no guarantee for
the security of customer data. It is the customer’s responsibility to produce an up-to-date backup
of the data transmitted and to save it off the platform. It is also the customer’s responsibility to set
a secure password for their customer account, to keep this safe and to change it regularly.

6. Customers’ And Users’ Rights
Passo Tourismo’s customers and users have the right to have their data amended or erased. This
is subject to statutory retention requirements. They can restrict the processing of their personal
data in addition to this. To assert these rights, Passo Tourismo’s customers and users should
contact the following address: [].
Customers and/or users have the right to object to the processing of their personal data at any
time. If they object to this, the contract between Passo Tourismo and the customer or user will be
terminated without notice. Payment obligations that the customer is contractually bound to will
remain unaffected.
If Passo Tourismo fails to observe the applicable data protection law, customers and users have
the right to make a complaint to the competent supervisory authority.

7. Storage Of Customer And User Data
Passo Tourismo stores the personal data it has collected from customers and users for as long as
necessary to fulfil its contractual and legal obligations and to meet the purposes stated in Section
3. Passo Tourismo’s legal retention obligations will remain.

8. Contact
Questions regarding Passo Tourismo’s data processing practices can be sent to the following
Passo Tourismo GmbH
Elsässer Strasse 32
81667 München
Federal Republic of Germany
Tel.: +49-89-44454512