Privacy

Here you will find information about how we handle your personal data when you visit our website. In order to provide the functions and services of our website, it is necessary for us to collect personal data about you. Below we explain which data we collect about you, why this is necessary and what rights you have in relation to your data.

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Responsible for the processing of personal data on this website is: Ski & Snowboard School Gitschberg STP GmbH - VAT. No. 03058730213 - 

Code Dest.: M5UXCR1 - PEC: skischule.gitschbergstp@pec.it

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If you have any questions about data protection, you can also contact our data protection officer at any time at skischule.gitschbergstp@pec.it.

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Informational Use

If you use this website without otherwise transmitting data to us (e.g. by registering or using the contact form), we collect technically necessary data that is automatically transmitted to our server, including:

• IP address

• Date and time of the request

• content of the request

• Access Status/HTTP Status Code

• browser type

• Browser software language and version

• operating system

 

This is technically necessary in order to be able to show you our website. We also use the data to ensure the security and stability of our website. The legal basis for the collection is Article 6 (1) (f) GDPR.

 

Google reCAPTCHA

This website uses the reCAPTCHA function of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). reCAPTCHA makes it possible to recognize whether an input (e.g. in forms) is made by a natural person or a machine/software (e.g. "bots"). reCAPTCHA sends the IP address of the user and possibly other data required by Google for the service. The use of reCAPTCHA is in accordance with Art. 6 Para. 1 lit. f GDPR and is due to the conscious avoidance of abuse and spam. When using Google reCAPTCHA, personal data may also be transmitted to the servers of Google LLC. come in the US. You can see more information about Google reCAPTCHA and Google's privacy policy at: https://www.google.com/intl/de/policies/privacy/

 

Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Inc. (hereinafter: Google). Google Analytics uses so-called "cookies", i.e. text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Due to the activation of IP anonymization on this website, however, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

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You can prevent the storage of cookies by setting your browser software accordingly; we would like to point out to you however that in this case you will if applicable not be able to use all functions of this website in full. You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by Google by downloading the browser plug-in available under the following link and install: https://tools.google.com/dlpage/gaoptout?hl=de.

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storage duration

We only process and store your data for as long as is necessary for processing or to comply with legal obligations. After the purpose of processing no longer applies, your data will be blocked or deleted. If there are also legal storage obligations, we will block or delete your data once the statutory storage periods have expired.

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Your rights

You have the following legal rights towards us with regard to the personal data concerning you:

• Right to information You have the right to request confirmation as to whether we are processing personal data relating to you. If this is the case, you have the right to information about this personal data as well as further information, e.g. the processing purposes, the recipient and the planned duration of storage or the criteria for determining the duration.

• Right to correction and completion You have the right to demand the correction of incorrect data immediately. Taking into account the purposes of the processing, you have the right to request the completion of incomplete data.

• Right to erasure (“right to be forgotten”) You have the right to erasure if processing is not necessary. This is the case, for example, if your data is no longer necessary for the original purpose, you have revoked your declaration of consent under data protection law, or the data was processed unlawfully.

• Right to restriction of processing You have the right to restriction of processing, for example if you believe that the personal data is incorrect.

• Right to data portability You have the right to receive your personal data in a structured, commonly used and machine-readable format.

• Right of objection You have the right to object at any time to the processing of certain personal data relating to you for reasons arising from your particular situation. In the case of direct advertising, you as the data subject have the right to object at any time to the processing of personal data relating to you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.

• Right to revoke your data protection consent You can revoke your consent to the processing of your personal data at any time with effect for the future. However, this does not affect the lawfulness of the processing that took place up until the revocation.

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You can also lodge a complaint with a data protection supervisory authority at any time, for example if you believe that data processing is not in accordance with data protection regulations.​

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Online dispute resolution in accordance with EU Regulation No. 524/2013: The European Commission provides a platform for online dispute resolution (OS), which you can find under the link http://ec.europa.eu/consumers/odr/Find  . Consumers have the opportunity to use this platform to settle their disputes about contractual obligations arising from online purchase or online service contracts.

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Privacy Information Clause Template for Customers (e.g. hotel – Data Controller) The folowing clause shal be incorporated into the privacy notice published on the hotel’s website, in a section specifica ly dedicated to the services offered on the site. As Data Controler, it shal be the customer’s responsibility to ensure that the overa l privacy notice is complete, transparent, and compliant with the GDPR. [X].

 

Processing of personal data through the KOSMO virtual assistant An interactive virtual assistant [insert chatbot name] (hereinafter, the “Chatbot”) is active on our website to assist you during navigation, provide information about our services, and answer your questions. This service is developed by AI KOSMO S.r.l., which acts as Data Processor pursuant to Article 28 of the GDPR, on the basis of a specific agreement governing its tasks and responsibilities. The Data Controler of the data you provide through the Chatbot remains Skischule Gitschberg.

 

The Chatbot uses Large Language Model (LLM) artificial inteligence systems to understand your requests and provide relevant responses. a. Categories of data processed The processing concerns the folowing personal data:

 

● Data actively provided by the user: any information that you voluntarily type into the chat window, such as questions, requests for information, first name, last name, contact details, or stay preferences;

 

● Session-related technical data: IP address, browser type, operating system, and other technical data necessary to ensure the proper technical functioning of the chat;

● Conversation content: the ful text of your interactions with the Chatbot. b. Purposes and legal basis of the processing Your personal data are processed for the folowing purposes:

● Provision of chat-based assistance and support services: to respond to your requests, assist you during navigation, and provide you with the necessary information about our services. The legal basis for this processing is the legitimate interest of the Data Controler in providing efficient and immediate customer support. In the case of pre-contractual requests (e.g. quotations, booking availability), the legal basis is the performance of pre-contractual measures.

 

● Service improvement and training of artificial intelligence algorithms: to analyse conversations (in aggregated and anonymised form where possible) in order to improve the accuracy of the Chatbot’s responses and the effectiveness of the service. The legal basis for this processing is the legitimate interest of the Data Controler and the Data Processor in improving the technology and the quality of the service offered, provided that your interests or fundamental rights and freedoms do not prevail.  

 

The provision of data for purpose no. 1 is optional but necessary in order to use the Chatbot service. For purpose no. 2, you may object at any time, without prejudice to your ability to continue using the chat service. c. Processing methods and security measures The processing is carried out using IT and telematic tools. In accordance with the principles of data protection by design and by default (Article 25 GDPR), appropriate technical and organisational measures are adopted to ensure a level of security appropriate to the risk, including pseudonymisation or anonymisation of data where possible, especialy for the purposes of training the algorithms. d. Data retention period Your personal data wi l be retained in accordance with the principle of storage limitation:

 

● For assistance purposes, conversation logs wi l be retained for the time strictly necessary to manage your request and, in any case, for a period not exceeding 6 months from the closure of the chat session, unless the emergence of a dispute justifies further retention.

● For algorithm training purposes, personal data wi l be retained in a form that alows your identification only for the time strictly necessary for analysis and extraction of information useful for improving the model, after which they wi l be irreversibly anonymised or deleted. In any case, this period wi l not exceed 90 days. e. Data disclosure and transfers The data colected through the Chatbot are processed by our provider AI KOSMO, appointed as Data Processor. AI KOSMO may use sub-processors (e.g. cloud service providers) for the provision of the service, in compliance with the obligations set out in Article 28 of the GDPR. The use of such services may involve the transfer of your personal data outside the European Economic Area (EEA).

 

Such transfers wi l take place only where appropriate safeguards are in place, such as adequacy decisions of the European Commission or the execution of Standard Contractual Clauses. f. Use of artificial intelligence systems The Chatbot service makes use of artificial inteligence technologies, in particular LLMs. In line with the transparency principles set out in the European AI Act, the GDPR, and national Law No. 132/2025, we wish to provide you with the folowing information:

● Transparency obligation: we inform you that you are interacting with a system that uses AI components. This system has been designed to assist Hotel staff in interpreting and routing your requests.  ● Operation and system logic: the AI system analyses the text of your requests in order to understand their content and purpose and to route them to the competent department.  

● Human oversight and absence of automated decision-making: we guarantee that the AI system operates as a support tool for our staff. No decision producing legal effects or similarly significantly affecting you (pursuant to Article 22 GDPR) is taken in a solely automated manner. Any complex request, charge, or relevant decision is subject to review and validation by a human operator.

 ● Fairness and non-discrimination: AI systems have been developed and are periodicaly monitored to minimise the risk of errors and discriminatory effects, in line with best practices and regulatory requirements. g. Data Subject rights in relation to the use of AI In addition to the general rights provided for by the GDPR (access, erasure, restriction, portability, objection), we remind you that, in relation to the use of artificial inteligence systems, you are guaranteed specific rights, in line with the guidance of supervisory authorities:

● Right to rectification: if you find that the information generated by the Chatbot concerning you is inaccurate, you have the right to request its correction;  

● Right to erasure: if the correction of inaccurate data is not technicaly possible, you have the right to obtain their erasure;  

● Right to object: you may object at any time to the processing of your data for the purpose of algorithm training based on legitimate interest. To exercise your rights, you may contact [name of the hotel] using the contact details provided in this privacy notice.

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