Privacy policy
This Privacy Policy provides information about the processing of personal data in connection with our activities and services, including data processing in connection with our websites under the domain names liechtenstein-marketing.li, tourismus.li, liechtenstein-business.li, liechtenstein.li, and staatsfeiertag.li. In particular, we explain what personal data we process, for what purpose, how, and where. We also provide information about the rights of individuals whose data we process. We are subject to the laws of the Principality of Liechtenstein and, due to our membership in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) of the European Union (EU), which is directly applicable in Liechtenstein.
1. contact addresses
Responsible in the sense of data protection law:
Liechtenstein Marketing
Äulestrasse 30
9490 Vaduz
datenschutz@liechtenstein.li
2. terms and legal bases
2.1 Terms
- Data subject: A natural person whose personal data we process.
- Personal data: Any information relating to an identified or identifiable natural person.
- Sensitive personal data: Data concerning trade union, political, religious, or philosophical views and activities; data concerning health, sexual life, or membership in an ethnic or racial group; genetic data; biometric data that uniquely identifies a natural person; data concerning criminal or administrative sanctions or proceedings; and data concerning social assistance measures.
- Processing: Any handling of personal data, regardless of the means and methods used, such as retrieving, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, revealing, sorting, organizing, saving, modifying, disseminating, linking, destroying, and using personal data.
- European Economic Area (EEA): Member states of the European Union (EU), as well as the Principality of Liechtenstein, Iceland, and Norway.
2.2 Legal basis
We process personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests - including the legitimate interests of third parties - unless the fundamental freedoms and rights and interests of the data subject prevail.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
- Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
- Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. nature, scope and purpose of the processing of personal data
We process the personal data necessary to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed may include, in particular, browser and device data, content data, communication data, metadata, usage data, master data (including inventory and contact information), location data, transaction data, contract data, and payment data. The personal data may also constitute special-category personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, to the extent that such processing is permitted. We process personal data for as long as is necessary for the respective purpose. We anonymize or delete personal data, in particular in accordance with statutory retention and statute of limitations periods.
4. disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties include, in particular, specialized service providers whose services we use.
4.1 Newsletter registration
You have the option of subscribing to our newsletter on our website. Registration is required for this. The following data must be provided as part of the registration process:
- First name (mandatory field)
- Last name (optional)
- E-mail address (mandatory field)
By subscribing to the newsletter, you consent to the processing of all data provided for promotional purposes in connection with the distribution of the newsletter.
You may revoke this consent at any time and for any reason by clicking the unsubscribe link included in every newsletter.
If you'd like to update your information, you can use the "Update Information" link in the newsletter.
We use the eworx Marketing Suite software to send and analyze our newsletters. The eworx Marketing Suite records the opening and clicking behavior. Specifically, the following information is tracked: time of delivery, time of opening, duration of opening, IP address of opening, email program used (mail client), which link was clicked and the time of the click. This data is processed exclusively within the European Union and is not passed on to third parties.
5. communication
We process personal data in order to communicate with individuals as well as with authorities, organizations and companies. In particular, we process data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or with comparable tools.
Third parties who transmit data about other persons to us are obliged to independently ensure the data protection of these data subjects. In particular, they must ensure that such data is correct and may be transmitted.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners.
6. data security
We implement appropriate technical and organizational measures to ensure data security commensurate with the respective risk. Through these measures, we ensure, in particular, the confidentiality, availability, traceability, and integrity of the personal data we process, though we cannot guarantee absolute data security. Access to our website and our other digital platforms is secured via transport encryption (SSL/TLS, specifically using the Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers issue a warning before visiting a website without transport encryption.
7. personal data abroad
We generally process personal data in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to have it processed there.
We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees.
8. rights of data subjects
8.1 Data protection claims
We grant data subjects all rights in accordance with the applicable law. Data subjects have the following rights in particular:
- Right of Access: Data subjects may request information regarding whether we process personal data about them and, if so, what personal data is involved. Data subjects will also receive the information necessary to exercise their data protection rights and ensure transparency. This includes the personal data being processed, as well as details regarding the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
- Correction and Restriction: Data subjects may correct inaccurate personal data, have incomplete data completed, and request that the processing of their data be restricted.
- Opportunity to express one’s own viewpoint and request a human review: Individuals affected by decisions that are based solely on the automated processing of personal data and that have legal consequences for them or significantly affect them (automated individual decisions) may present their own viewpoint and request a review by a human.
- Deletion and Objection: Data subjects may request the deletion of their personal data (“right to be forgotten”) and object to the processing of their data with future effect.
- Data Disclosure and Data Transfer: Data subjects may request the disclosure of their personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
8.2 Legal protection
Data subjects have the right to enforce their data protection claims by taking legal action or to lodge a complaint with a data protection supervisory authority.
Liechtenstein Data Protection Authority
Kirchstrasse 8 | P.O. Box 684
9490 Vaduz
T +423 236 60 90 | info.dss@llv.li
9. use of the website
9.1 Cookies
We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as "session cookies" or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
Cookies can be completely or partially deactivated, restricted or deleted at any time in the browser settings. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies - at least if and to the extent required by applicable law.
9.2 Logging
For every visit to our website and our other digital platforms, we may log at least the following information, provided that it is transmitted to our digital infrastructure during such visits: Date and time, including time zone; IP address; access status (HTTP status code); operating system, including user interface and version; browser, including language and version; specific subpages of our website accessed, including the amount of data transferred; the last webpage accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. The information is required to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.
9.3 Tracking pixels
We can integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can be used to record at least the same information as is recorded in log files.
10. notifications and messages
10.1 Measuring success and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages effectively and in a user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
10.2 Consent and objection
You must generally consent to the use of your email address and other contact information, unless such use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log obtained consents, including IP addresses and timestamps, for evidentiary and security purposes.
You can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach.
10.3 Service provider for notifications and messages
We send notifications and communications through specialized service providers. In particular, we use:
- SendGrid: Platform for transactional emails (“Email delivery made easy”); Providers: Twilio Inc. (USA) / Twilio Ireland Limited (Ireland); Privacy information: Privacy Policy.
11. social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Meta (Facebook/Instagram), including so-called Page Insights, to the extent that the General Data Protection Regulation (GDPR) applies. Meta Platforms Ireland Limited is part of the Meta group of companies (including those in the U.S.). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to ensure that our social media presence on Facebook is effective and user-friendly.
Further details regarding the nature, scope, and purpose of data processing, information on the rights of data subjects, and the contact information for Facebook and Facebook’s Data Protection Officer can be found in Facebook’s Privacy Policy. We have entered into the so-called “Addendum for Controllers” with Facebook, thereby agreeing, in particular, that Facebook is responsible for ensuring the rights of data subjects. For so-called Page Insights, the relevant information can be found on the “Information about Page Insights” page, including “Information about Page Insights Data.”
12. services of third parties
We use services provided by specialized third parties to ensure that our operations and activities are sustainable, user-friendly, secure, and reliable. These services allow us, among other things, to embed features and content on our website. When such embedding occurs, the services used collect users’ IP addresses —at least temporarily—for technical reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Google Services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland), in part for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and Security Principles, ” “More information on how Google uses personal data,” Privacy Policy, “Google is committed to complying with applicable data protection laws, ” “Guide to Data Protection in Google Products, ” “How We Use Data from Websites or Apps on Which Our Services Are Used, ” “Types of Cookies and Similar Technologies Used by Google,” “Advertising You Can Control” (“Personalized Advertising”).
12.1 Digital infrastructure
We use the services of specialized third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
-
- Cloudflare: Content Delivery Network (CDN); Cloudflare Inc. (USA); Privacy policy: “Privacy”, Privacy Policy, Cookie Policy.
- Exoscale: Digital infrastructure; Provider: Akenes SA (Switzerland); Privacy information: Privacy Policy, “Exoscale Security Policy.”
- Google Cloud, including Google Cloud Platform (GCP): storage space and other infrastructure; Google Cloud-specific providers: national or regional Google entities, depending on the country and region; Google Cloud-specific information: “Privacy Center, ” “Google Cloud and General Privacy Principles, ” “Google Cloud Privacy Notice, ” “Privacy.”
- Novatrend: Hosting; Provider: NovaTrend Services GmbH (Switzerland); Privacy information: Privacy Policy.
12.2 Social media functions and social media content
We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.
12.3 Card material
We use third-party services to embed maps in our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: “How Google uses location information.”
- OpenStreetMap (OSM): Map service; Provider: OpenStreetMap Foundation (United Kingdom); Privacy information: Privacy Policy.
- Outdooractive: Map service; Provider: Outdooractive AG (Germany); Privacy information: Privacy Policy.
12.4 Digital content
We use services provided by specialized third parties to embed digital content on our website. Digital content includes, in particular, images, videos, music, and podcasts. Specifically, we use:
- YouTube: Video platform; Provider: Google; YouTube-specific information: “Privacy and Safety Center, ” “My Data on YouTube.”
12.5 Documents
We use third-party services to integrate documents into our website. Such documents may include PDF files, presentations, tables and text documents. We can thus enable not only the viewing, but also the editing or commenting of such documents.
We use in particular:
- Yumpu: Digital documents and electronic publications; Provider: i-Magazine AG (Switzerland); Privacy information: Privacy Policy, Cookie Policy.
12.6 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols on our website.
We use in particular:
- Font Awesome: Icons and logos; Provider: Fonticons Inc. (USA); Privacy information: Privacy Policy
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: “Your Privacy and Google Fonts,” “Privacy and Data Collection” (Google Fonts).
12.7 E-Commerce
We operate e-commerce and use third-party services in order to successfully offer services, content or goods.
12.8 Advertising
We take advantage of the opportunity to display targeted advertisements for our activities and services on third-party platforms, such as social media platforms and search engines.
We use this type of advertising specifically to reach people who are already interested in our activities and services, or who might be interested in them (remarketing and targeting). To this end, we may share relevant information—including, where applicable, personal data—with third parties that facilitate such advertising. We can also determine whether our advertising is successful, specifically whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may be able to assign the use of our website to your profile there.
We use in particular:
- Google Ads: Search engine advertising; Provider: Google; Google Ads-specific information: Advertising based, among other things, on search queries, whereby various domain names—in particular doubleclick.net, googleadservices.com, and googlesyndication.com—are used for Google Ads; Privacy Policy for Advertising; “Manage ads displayed directly via Ads.”
- LinkedIn Ads: Social media advertising; Providers: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Privacy information: Remarketing and targeting, particularly using the LinkedIn Insight Tag, “Privacy, ” Privacy Policy, Cookie Policy, Opt-out of personalized advertising.
- Meta Ads: Social media advertising on Facebook and Instagram; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the U.S.); Data protection information: Targeting, including retargeting, in particular using the Meta Pixel and Custom Audiences including Lookalike Audiences, Privacy Policy, “Ad Preferences” (user registration required).
- TikTok Ads: Social media advertising; Providers: TikTok Information Technologies UK Limited (United Kingdom) and TikTok Technology Limited (Ireland) for users in the European Economic Area (EEA), Switzerland, and the United Kingdom / TikTok Inc. (USA) for users in the United States / TikTok Pte. Ltd. (Singapore) for most users in the rest of the world; privacy information: remarketing and targeting, particularly using the TikTok pixel, Privacy Policy, “Children’s Privacy Policy,” “TikTok Partner Privacy Policy, ” Cookie Policy.
We use services provided by Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden ("Spotify"), to display targeted advertising on the Spotify platform to visitors of our online offerings who have shown an interest in our Spotify-related content (remarketing). For this purpose, information about your interactions with our content related to Spotify (e.g., clicks on Spotify links, interaction with embedded Spotify playlists or tracks) may be collected in a pseudonymized form and transmitted to Spotify. Spotify uses this information on our behalf to assign you to segments for ad delivery. No directly identifying personal data, such as your name or email address, is transmitted to Spotify unless you have provided this data to Spotify yourself and consented to its use.
13. extensions for the website
We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure.
We use in particular:
- Google reCAPTCHA: Spam protection (distinguishing between desired content from humans and unwanted content from bots and spam); Provider: Google; Google reCAPTCHA-specific information: “What is reCAPTCHA?”
14. success and reach measurement
We try to measure the success and reach of our activities and operations. In this context, we can also measure the effect of third-party references or check how different parts or versions of our digital presence are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements.
In most cases, the IP addresses of individual users are collected for the purpose of measuring success and reach. In such cases, IP addresses are always truncated (“IP masking”) in order to comply with the principle of data minimization through appropriate pseudonymization.
Cookies may be used to measure performance and reach, and user profiles may be created. Any user profiles created may include, for example, the specific pages visited or content viewed on our digital platform, information about the size of the screen or browser window, and the user’s location (at least approximately). In principle, any user profiles created are exclusively pseudonymized and are not used to identify individual users. Certain third-party services with which users are registered may, in some cases, associate the use of our online offering with the user’s account or profile on the respective service.
We use in particular:
- Google Marketing Platform: Measurement of success and reach, particularly using Google Analytics; Provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices (cross-device tracking) using pseudonymized IP addresses, which are only transferred in full to Google in the U.S. in exceptional cases ; Google Analytics Privacy Policy; “Browser add-on to disable Google Analytics.”
- Google Tag Manager: Integration and management of Google and third-party services, particularly for measuring performance and reach; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found in the privacy policies of the individual integrated and managed services.
- Matomo: Performance and reach measurement; Provider: InnoCraft Ltd. (New Zealand, free open-source software); Data protection information: Used on our own digital infrastructure and with pseudonymized IP addresses, “List of all Matomo Features.”
15. video surveillance Liechtenstein Center
The Liechtenstein Center in the town of Vaduz is under video surveillance. The installed video system is used to monitor the publicly accessible premises of the Liechtenstein Center in Vaduz and is operated exclusively for the purpose of preventing and investigating theft, damage and vandalism.
Technical protective measures
The video system was installed and commissioned by AFS Anstalt für Sicherheitstechnik in Vaduz in such a way that the video images and data obtained are protected against unauthorized access. Sound recordings or data linking with other lT systems do not take place.
Operation of the video surveillance system / deletion of data
The video surveillance system operates in recording mode 24 hours a day throughout the entire monitored area. To minimize the infringement of the personal rights of those affected (employees, customers, and suppliers) by video surveillance, special consideration was given to workstations when selecting camera positions and their respective orientations. They are positioned in such a way that privacy is maintained during breaks and personal errands. The duration of video recording is limited to what is necessary and to achieving the intended purpose. Video recordings in the store area and forecourt are retained for exactly 7 days and are then automatically deleted, unless they are required for the preservation of evidence.
Evaluation of the findings
The recordings (live viewing without the ability to edit ) are reviewed by monitoring them on a tablet or PC at the Liechtenstein Center.
Records are reviewed only when necessary to investigate losses, shoplifting, burglaries, vandalism, property damage, or to preserve evidence following criminal acts.
For the purpose of preserving evidence, image data relevant to the case may be transferred by the operators, upon authorization, to storage media such as CDs, DVDs, USB drives, or hard drives, and subsequently processed strictly for the specific purpose of data analysis. Individuals affected by the review of recordings shall be notified in writing immediately after the video images have been secured, regarding the circumstances that led to the review. In exceptional cases, thisobligation to inform maybe postponed to a later date (e.g., in the case of specific investigations by law enforcementauthorities). If, following an initial assessment by amemberofmanagement, a criminally relevant eventis determined to have beenrecorded by the video surveillance system, these recordings may be forwarded to law enforcement authorities (e.g., state police, public prosecutor’s office). No other disclosure of video recordings to third parties takes place. Every review of recordings and any potential disclosure is documented in an audit-compliant manner for at least 12 months (logging). No later than 730 days after the recordings are no longer required for the preservation of evidence, they are deleted, unless a corresponding provision in the law prescribes a longer retention period.
Labeling (pictograms)
The use of video cameras is indicated by clearly visible signs at the entrances.
16. final notes on the privacy policy
We may update this privacy policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current privacy policy on our website.