Privacy notice

1. Controllers and contact details

The operator of the joint website and the controller responsible for its operation is Spangenberg Beteiligungs- und Beratungs GmbH, represented by its managing director, Dr Christof Spangenberg. It operates the website for the properties offered by both landlords.

For enquiries and bookings for Villa Orea Elena and Mikri Eleni, Anne and Christof Spangenberg are the controllers. For enquiries and bookings for Haus Schwänli, the controller is Spangenberg Beteiligungs- und Beratungs GmbH, represented by its managing director, Dr Christof Spangenberg.

The address in each case is: Valerystraße 10c, 85716 Unterschleißheim, Germany. Full provider information can be found in the Legal notice.

The central point of contact for questions about this website and data protection is Christof Spangenberg: christof.spangenberg@spangenbergs.de. For property-specific matters, please name the relevant property so that your enquiry can be assigned to the responsible landlord. You may exercise your rights directly against the relevant controller.

2. Website hosting

This website is hosted by ALL-INKL.COM – Neue Medien Münnich, proprietor René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. The provider operates its data centres in Germany. Processing on our behalf is based on the data processing agreement incorporated into the hosting contract.

When the website is accessed, technical connection data such as the IP address, time, requested page, browser and device information and, where applicable, the referring page are processed. This enables the content to be delivered and faults or attacks to be detected. The legal basis is our legitimate interest in a secure and functional website (Article 6(1)(f) GDPR).

Technical logs are retained for as long as necessary to provide, troubleshoot and secure the service; in the event of a specific security incident, longer retention may be necessary for investigation and legal enforcement. Further information is available in the provider’s privacy information.

Photographs and fonts are loaded from our website server. We have not integrated advertising pixels or analytics tools into the website.

3. Enquiries by email

When you write to us, we process your email address, the content of your message and, where applicable, your name and any other information you provide voluntarily. We use this information to respond to and handle your enquiry. For an intended or existing booking, the legal basis is Article 6(1)(b) GDPR; for other matters, it is our legitimate interest in communicating with you under Article 6(1)(f) GDPR.

Our contact mailbox is hosted by WEB.DE, a service of 1&1 Mail & Media GmbH, Elgendorfer Straße 57, 56410 Montabaur, with a branch office at Brauerstraße 48, 76135 Karlsruhe. The provider processes messages and technical communications data for the email service. It describes its own processing activities in its WEB.DE Privacy Policy. An email link opens your email application; simply visiting the contact page does not transmit a message to WEB.DE.

Please provide only the information needed for your enquiry. Without a means of contacting you, we cannot respond. We retain messages for as long as they are needed to deal with the matter, answer subsequent questions, comply with legal obligations or establish, exercise or defend legal claims.

4. Availability and booking with Smoobu

We use Smoobu GmbH, Pappelallee 78/79, 10437 Berlin, for availability, bookings and guest communications. Smoobu processes guest data on behalf of the landlords under a data processing agreement. The centrally managed account is administered by Christof Spangenberg.

The embedded module is loaded only after you give your express consent on the booking page. Smoobu then receives technical data such as your IP address and browser information. The module may use cookies or similar storage technologies. Voluntary activation is based on Article 6(1)(a) GDPR and, where required, Section 25(1) TDDDG. Your choice is not stored permanently on our website and applies only to the page currently open.

Using “Disable Smoobu” above the loaded module, you can withdraw this activation with effect for the future. The page will reload and the module will be removed; any entries you have not submitted will be lost. Data already transmitted to Smoobu and cookies set by Smoobu will not be deleted retrospectively as a result. You can also remove cookies in your browser. The module must be activated again each time the page is reopened.

Alternatively, without activating the module, you can send an enquiry by email or open the separately linked Smoobu booking page. When you open this external link, the privacy information and choices provided there apply. Consent given here does not replace any choices that may be offered in the Smoobu module for additional purposes.

For a booking, the contact, travel, guest and contract data requested in the form are processed. Required fields are marked; a booking cannot be made without the required information. A booking or booking enquiry is processed under Article 6(1)(b) GDPR, and legal obligations are fulfilled under point (c). Additional information provided voluntarily is not a condition of booking.

Further information: Smoobu Privacy Policy, Data Processing Agreement in Appendix A and Sub-processors.

5. Who receives guest data

Access is granted to the people involved in letting the properties: Christof Spangenberg, family members who provide support and the relevant property managers. Property managers can see only bookings for the properties they manage. The data are used to organise your stay, including arrival, handover and on-site support. The legal basis is performance of the rental agreement under Article 6(1)(b) GDPR.

Other recipients are the technical service providers described above and public authorities where we are legally required to disclose data. We do not sell guest data.

6. Retention and international processing

Enquiry and booking data are required to handle the enquiry or booking, organise the stay and complete the subsequent administration. Retention and deletion thereafter depend on the relevant purpose, applicable tax and commercial-law obligations and any outstanding claims. Documents subject to retention requirements will continue to be held for these purposes. You may withdraw consent; any unaffected statutory or contractual legal bases remain in force.

Smoobu subcontractors may process data outside the EU or EEA. Smoobu identifies the companies and countries involved in its subcontractor list linked above; the transfer rules are described in the data processing agreement. You can request information and, where applicable, copies of the relevant safeguards from our contact point.

7. Your rights

Subject to the statutory requirements, you have the right of access, rectification, erasure, restriction of processing and data portability. You may withdraw consent at any time with effect for the future; this does not affect the lawfulness of processing carried out before withdrawal.

Where processing is based on legitimate interests, you may object on grounds relating to your particular situation. You may object to processing for direct marketing at any time.

To exercise these rights, contact christof.spangenberg@spangenbergs.de or the responsible landlord at the address given above. You may also lodge a complaint with a data protection supervisory authority, particularly in the place where you live or work, or where the alleged infringement occurred. For private-sector entities in Bavaria, the Bavarian State Office for Data Protection Supervision is one authority you may contact.

We do not use solely automated decision-making, including profiling, within the meaning of Article 22 GDPR for our letting decisions.