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2.0 Data processing in connection with your stay

2.1 Data processing to fulfil statutory reporting requirements

When you arrive at our restaurant, we require the following information from you and any accompanying persons (* mandatory):

  • First name and last name *
  • Address*
  • Data of birth*
  • Place of birth*
  • Nationality*
  • Official passport/identity card and number *
  • Day of arrival and day of departure

We collect this information in order to fulfil statutory reporting requirements, in particular in connection with hospitality or police laws. Insofar as we are obliged to do so under the applicable regulations, we forward this information to the responsible police authority.

Fulfilling the legal requirements constitutes our legitimate interests in accordance with Art. 6 (1) (f) GDPR.

2.2 Recording purchased services

If you purchase additional services (e.g. restaurant, using items from the mini bar or pay TV, etc.) during your stay, we will record the supplied service as well as the time the service was purchased for invoicing purposes. Processing these data is necessary for the performance of the contract with us in accordance with Art. 6 (1) (b) GDPR.

2.3 WLAN usage

To provide you with access to the internet via our WLAN network, we record and use the following data when you dial into and use our WLAN network:

So-called inventory data (* mandatory)

  • Your first name and last name incl. title *
  • The email address you have given*
  • Your mobile phone number

We use these inventory data to register you for our WLAN service. The legal basis for processing data for this purpose is the performance and fulfilment of a contract in accordance with Art. 6 (1) (b) GDPR.

In addition, we collect so-called traffic data:

  • The type of device you use to access our WLAN network
  • Various device identifiers, namely the WLAN MAC address and the login allocated to you
  • The IP address allocated to you
  • Date and time of your WLAN and internet connections
  • Certain location data: These include the location of the nearest WLAN access point to you, with which you are connected via WLAN; this also includes a time stamp. The location of this access point usually tells us which room in our hotel you use your device and when. We do not receive more exact information about your actual location.

We require the above traffic data to establish a technical connection between your device and our WLAN network, via which we can then provide you with access to the Internet and process it technically. The purpose of the location data is to connect you to the WLAN access point with the strongest signal. This constitutes our legitimate interests in data processing in accordance with Art. 6 (1) (f) GDPR.

In addition, the IP address is evaluated together with other data in the event of attacks on the network infrastructure or other unauthorized or improper WLAN use for clarification and defence purposes. If necessary, it is used as part of criminal proceedings to identify and initiate civil and criminal proceedings against the users concerned. This constitutes our legitimate interests in data processing in accordance with Art. 6 (1) (f) GDPR.

Based on your consent, we use your data for other purposes, as described in the following. We combine your above data with data we have stored during the course of your stay, and use these combined data for the following purposes:

  • To send you general information and individual offers for products and services provided by our hotel, tailored to you and your interests on the basis of your existing data, by e-mail, during or after your stay. The information and offers you receive may also be geared to your previous and current location within our hotel, e.g. if you have just entered one of our restaurants or visit our fitness studio frequently. If you have also provided us with your mobile phone number, we will use it to send you additional information and offers of this kind via SMS to your mobile phone.
  • To improve our range of services, we would like to help our employees address you by name whenever they contact you. To this end, we may use your name and the location information described above to let our staff know who is in a particular room of our hotel. This makes it easier for our staff to address you personally by name.
  • For statistical evaluations, e.g. how our guests react to our marketing campaigns, what services our guests use particularly frequently within the hotel, how our guests prefer to move around the hotel, which WLAN areas have good coverage. 

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

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3.0  Plugins and APIs

4.0  Data storage and exchange with third-parties

5.0  Further information


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

Discover The Living Circle website