Privacy Policy
The internet portal of FreewayCamper GmbH and the booking portal integrated therein (hereinafter collectively referred to as “website”) are operated by FreewayCamper GmbH, Thomas-Wimmer-Ring 14, 80538 Munich (hereinafter referred to as “FreewayCamper” or “we”). We attach great importance to the protection of your personal data. For this reason, data protection at FreewayCamper has a high priority, and we strictly adhere to the legal provisions of the European Data Protection Policy and the United States Federal Data Protection Act in collecting, processing and using data.
1. Collection, processing and use of personal data
The processing of your personal data is based on the following legal basis:
1.1 Contractual relationship pursuant to Art. 6 (1) letter b of GDPR
We process the personal data voluntarily communicated to us (first name and last name, e-mail address, mobile phone number) pursuant to Article 6 (1) letter b GDPR for the contractual processing of ticket orders, for carrying out transportation, for opening a customer account or within the context of pre-contractual measures.
We save the mobile phone number voluntarily communicated to us in order to establish contact in special events, delayed returns or other unusal activities. For the required payment processing, the following data is additionally required: For the credit card payment of a booked trip, FreewayCamper requires your full name, e-mail address and credit card data.
1.2 Legitimate interests pursuant to Art. 6 (1) letter f of GDPR
The necessary data is forwarded to FWC - FreewayCamper GmbH in order to carry out administrative activities (IT services, customer service, accounting, etc.) and to efficiently design the internal administration of our company. In this respect, we process the necessary data in accordance with Art. 6 (1) letter f and, as applicable, letter b GDPR, for the following purposes:
The data stored for the contract processing and for carrying out the bookings is forwarded to the local rental stations/camper owmer and other third parties (e.g., service providers for IT, transport, customer service, sending emails and newsletters, and payment processing) in the course of registration and for processing the ticket sale. In justified cases (e.g., damage to the campers), we reserve the right to forward the customer data to the respective rental station/camper owener. The data forwarded in this way may only be used by our service providers to fulfil their task and not for other purposes. Insofar as orders are processed, processing takes place in compliance with the requirements for order processing pursuant to Art. 28 of GDPR.
In addition to processing ticket orders, FWC - FreewayCamper GmbH also uses your data for advertising purposes and for market and opinion research to inform you about offers tailored to your interests via regular mail or newsletters. To this end, we conduct advertising scoring for interest-based advertising based on legitimate interests pursuant to Art. 6 (1) letter f of GDPR. You may withdraw consent for the use of your data for advertising purposes, market and opinion research and advertising scoring can be countermanded at any time by a communication to FreewayCamper GmbH, Thomas-Wimmer-Ring 14, 80538 Munich or to e-mail adress info@freeway-camper.com with title "Privacy Policy".
In the context of payment processing, your data may be forwarded to the following payment service providers. The credit card number or other bank details are not stored at FreewayCamper and forwarded directly to the payment service provider:
Payments are processed by our partner heidelpay GmbH, Vangerowstraße 18, 69115 Heidelberg. To prevent and detect fraud, we send your IP address to our partner heidelpay GmbH, Vangerowstraße 18, 69115 Heidelberg. Your IP address is stored by heidelpay GmbH in this context. All data is transmitted in encrypted form.
Heidelpay GmbH is a payment institution within the meaning of the Payment Services Supervisory Act (Zahlungsdiensteaufsichtsgesetz [ZAG]) and is registered with the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht [BaFin]), Graurheindorfer Str. 108, 53117 Bonn (registration number 122914).
The payment method PayPal is processed by PayPal (Europe) S.à r.l. & Cie, P.C.A., 5th Floor, 22-24 Boulevard Royal, L-2449 Luxembourg. You can find additional information about PayPal data protection in the Data Protection Declaration of PayPal.
This website uses an online booking system provided by treeme GmbH, Via Cantonale, CH-6633 Lavertezzo, Switzerland. Planyo can be contacted at www.planyo.com, (hereinafter referred to as “Planyo”). This website also uses “cookies”, which are text files stored on your computer that make it easier for you to use the online booking system. The information generated by the cookies about your use of this website (including your IP address) is transmitted to one of Planyo’s servers in the EU or Swiss.
3. Newsletter
You have the option to subscribe to our newsletter through our website or after booking your camper. FreewayCamper collects data when you subscribe to the newsletter. The newsletter includes current offers, special promotions, seasonal contests, product news, tips & tricks for camping, travel packages, and travel interviews from our customers.
The data processing is based exclusively on your consent (Art. 6 para. 1 lit. a DSGVO) until you revoke it. Data collected is:
- Data that you provide to us when you subscribe to the newsletter via our website (e-mail address, first name, zip code/city, content preferences).
- Data you provide after booking a camper (email address, name, address), provided that after booking you have decided to subscribe to the newsletter and give us your consent by clicking on the confirmation link sent to the email address you provide.
- Data proving your consent to receive the newsletter (IP address, timestamp of consent).
- Data about the use of the newsletter (openings, clicks on included links, accessibility of the e-mail address, type of end device used).
To ensure that no mistakes have been made when entering the e-mail address, we use the so-called double opt-in procedure: After you have entered your e-mail address in the registration field, we will send you a confirmation link. Alternatively, after a successful camper booking, you will receive an e-mail from us in which you can agree to marketing communications via our newsletter. In this case, we will also send you a confirmation link. Only when you click on this confirmation link, your e-mail address will be added to our distribution list.
Your newsletter data is transmitted to the external service provider Mailchimp, whose software enables us to manage all our newsletter contacts and design appealing newsletters. It thus acts on our behalf and FWC is the data controller. Based in the U.S., Mailchimp is committed to complying with the EU-U.S. Privacy Shield Agreement and Standard Contractual Clauses (the "SCCs"). Here you can find more concrete information about Mailchimp's Privacy Policy, European Data Export Compliance at Mailchimp, and Mailchimp Transparency Report.
You can revoke the use of your email address at any time by sending a message to unsubscribe@freeway-camper.com or via the unsubscribe link of the newsletter. You can find the unsubscribe link at the end of each newsletter.
We delete your data 6 months after the revocation of your consent.
4. Data security
We protect the privacy of users on our website and the connected systems using technical and organisational measures. To ensure secure transfer of personal data, we use the encryption protocol TLS (RSA-2048 is used as the underlying encryption method for the public key infrastructure.) This procedure is used successfully throughout the World Wide Web. All personal data (name, address, payment data, etc.) are thereby encrypted and consequently securely transmitted on the internet. You can see via a symbol (closed padlock) in the lower window bar of your browser that you are in a secure area.
5. Data transfers to third countries
Data is processed on principle in Germany or countries of the European Union. Where processing in third countries is planned in certain cases, processing shall only be carried out if the appropriateness of the level of data protection in the third country has been established by the EU Commission under Art. 45 of GDPR or on the basis of standard EU contractual clauses.
6. Data storage period
We store the data as long as it is required for the respective processing purposes (e.g., contract processing, advertising purposes) and for fulfilling the trade and tax legal retention provisions pursuant to Art. 6 (1) letter c of GDPR and Section 257 (1) of the German Commercial Code (Handelsgesetzbuch [HGB]) and Section 147 (2) of the Tax Code (AO).
7. Contact details of the person responsible
The entity responsible for processing personal data is FWC - FreewayCamper GmbH, Thomas-Wimmer-Ring 14, 80538 Munich, email address info@freeway-camper.com, represented by the Managing Director Nikolai Voitiouk-Blum.
8. Information and complaint rights
Pursuant to the General Data Protection Regulation, you have a right to free information about your stored data and, where applicable, a right to rectification, erasure, restriction of processing, and a right to data portability (Art. 20 GDPR) and to objection with regard to your stored data. For such matters, please contact FWC - FreewayCamper GmbH, Thomas-Wimmer-Ring 14, 80538 Munich or e-mail us at data.protection@freeway-camper.com.
You can contact our data protection officer at data.protection@freeway-camper.com.
In addition, you have a right to complain about data protection to the supervisory agency responsible for us.
9. Use of cookies
When you visit our website, information is stored in the form of a cookie (small text files stored on your browser). Information about your use of the website is saved there (identification ID, visit date, etc.). With the use of cookies, we facilitate the use of our online offer through various service functions (such as the recognition of previous visits) and consequently can better adapt the internet offer to your needs. You can stop the storage of cookies and delete existing cookies by making the appropriate changes to your browser settings. The help function of most browsers tells you how to change these settings. If you do not accept cookies, this may affect the service functions of the internet offer. We therefore recommend that the cookie function be left switched on.
In addition, we use third-party cookies for retargeting and remarketing technologies to optimise our web offerings as well as interest-based marketing purposes. The stored surfing behaviour is analysed using an algorithm, so that targeted interest-related product recommendations in the form of advertising banners or advertisements can then be displayed on third party websites. Without the express consent of the person concerned, the pseudonymised user profiles will not be combined with the personal data of the user of the pseudonym.
Comprehensive information about how to accomplish this on a wide variety of browsers can be found on the following websites: youronlinechoices, Network Advertising Initiative and/or Digital Advertising Alliance. You can also find information there about how to delete cookies from your computer as well as general information about cookies.
Manage your cookie preferences
We use different kinds of cookies:
In transient cookies, which are also known as temporary or "session cookies" are cookies that are deleted after you leave our online offer and close the browser. Such cookies are e.g. language settings or the content of the order stored.
Persistent or permanent cookies are saved even after the browser is closed. Here e.g. login status or entered search terms are stored. We use such cookies among other things for reach measurement and marketing purposes. Persistent cookies are automatically deleted after a predetermined duration, which may differ depending on the cookie. However, you can delete these cookies in the security settings of your browser at any time.
In addition to so-called "first-party cookies", which are set by us in our responsibility for data processing, also called "third-party cookies" are used, which are offered by other suppliers. About the use of "third-party cookies" and about cooperation with external companies who provide services for us, such as web tracking or reach measurement, we inform you below. There you will be informed about the possibility of objection in relation to individual cookies.
9.1 Google AdWords
To optimise our web offerings as well as for product recommendations, we use the technology provided by Google Limited („Google“) (Gordon House, Barrow Street, Dublin 4, Ireland, „Google“) to create pseudonymised user profiles about the surfing behaviour of the website visitors for marketing purposes. For this purpose, cookies may be used, which make it possible to recognise an internet browser on a return visit. The stored surfing behaviour is analysed using an algorithm, so that targeted interest-related product recommendations in the form of advertising banners or advertisements can then be displayed on third party websites. Without the express consent of the person concerned, the pseudonymised user profile will not be combined with the personal data of the user of the pseudonym. The creation of pseudonymised user profiles for interest-based advertising/ad preferences can be refused at any time by visiting the https://www.google.com/setting... page. You can find more information about interest-related advertising at http://www.google.com/policies... Facebook Custom Audiences
This website uses the Retargeting-Pixel Custom Audience of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA. With the help of the Remarketing Pixel, it is possible to use the visitors of our website as a target group for the advertisements of Facebook ads. For this purpose, a Facebook cookie is stored on your PC. Please refer to the data protection (privacy settings) provisions of Facebook for information about the purpose and scope of data collection as well as the further processing and use of data by Facebook and your options for privacy settings at https://facebook.com/policy.ph... and https://www.facebook.com/ads/settings. You can object to the use of Custom Audiences www.youronlinechoices.com/de/p... or for users with a Facebook account here.
9.3. Google Analytics
This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies”, text files, which are stored on your computer and enable analysis of your use of the website. In addition, this website uses the Google AMP Client ID API to link user activities to AMP pages with those on non-AMP pages via Google Analytics. The Google tracking codes of this website use the “_anonymizeIp()” function. As a result, the IP address within Member States of the European Union or in other States of the Agreement on the European Economic Area is only processed further abbreviated to exclude a direct personal reference. The complete IP address is only transmitted to a server from Google in the USA in exceptional cases and abbreviated there. On behalf of the operator of this website, Google uses this information to evaluate your use of this website, create reports about the website activities and provide other services connected with use of the website and Internet for the website operator. The IP address transmitted from your browser within the context of Google Analytics will not be associated with other Google data. You can prevent storage of cookies on your computer via the corresponding setting of your browser software. However, we advise that this may mean that you are you unable to use all functions of this website to their full extent. You can also prevent Google recording data generated by a cookie with respect to your use of the website (incl. IP address) as well as Google processing of this data by downloading and installing the browser plugin available via the following link: http://tools.google.com/dlpage... adjust
This website/app also uses, among other things, the analysis technology “adjust” of adjust GmbH (“adjust”). adjust runs the analysis using the IP and Mac addresses of users, however, only used in an anonymised form. This makes it impossible to draw conclusions about a natural person. By using this website/app for analysis purposes, you declare your consent to the anonymised data collected being processed in the manner described above and for the purpose cited above. You may object, at any time, to the collection and storage of data by adjust, with effect for the future. Do so by clicking on the following link: https://www.adjust.com/opt-out... Webtrekk
For the statistical evaluation of the websites, we use the technologies of Webtrekk GmbH, Robert-Koch-Platz 4, 10115 Berlin. With the help of Webtrekk’s services, we collect statistical information about the use of our website. Webtrekk GmbH was certified by TÜV in the Web Controlling area. In particular, the collection and processing of tracking data was checked and certified with respect to data protection compliance and data security. Information transmitted by your browser is collected and evaluated in the context of the use of this website. This is done by cookie technology and pixels, which are incorporated on each web page. Direct reference to people is excluded at all times. The data collected in this way is used to create anonymous user profiles that form the basis for web statistics. Without the express consent of the person concerned, data collected with Webtrekk technology is not used to identify the user of this website personally and is not linked with personal data via the holder of the pseudonym at any time.
Permission for Webtrekk to collect and store data may be revoked at any time with future effect. For more information on data protection at Webtrekk, please visit the following link: http://www.webtrekk.com/index/... AdClear Campaign Tracking
We use the services of AdClear GmbH, Robert-Koch-Platz 4, 10115 Berlin (“AdClear”) to collect statistical information for campaign tracking and consequently optimise the service offering for our customers accordingly. Cookies are also used for this purpose. Data is collected in a purely anonymous form. Personal data will not be sent to AdClear. AdClear GmbH is certified for data protection in the field of campaign tracking systems by TÜV Saarland.
If you disagree with the data collection by the AdClear Campaign Tracking, a cookie with the name “adclearoptout” is set for this.
You have not refused permission for data collection by AdClear.
Refuse permission for data collection by AdClear.
9.7 Adtriba
Data is collected and stored on this website using technologies from AdTriba GmbH – Beim Schlump 13a, 20144 Hamburg (https://www.adtriba.com/) and this data is used to create pseudonymised usage profiles. These usage profiles are used to analyse visitor behaviour and are evaluated to improve and adapt the design of our website as required. Cookies may be used for this purpose. Cookies are small text files stored on the device used by visitors to the site and so allow them to be recognised the next time they visit our website. The pseudonymised usage profiles are not combined with personal data about persons to whom these pseudonyms have been assigned without express consent that must be given separately.
9.8 Tapad
Cross-App and Cross-Device Reporting
Company collects and uses cross-app and cross-device information for reporting purposes. Company does not collect PII via its technology, including across apps and devices. Company uses certain techniques to enable its tracking technology to track users across apps and devices, including cookie and ID Syncing and similar practices.
9.9 AB Tasty
This website also uses the AB TASTY SAS web analytics service AB Tasty, which is used for A/B and multivariate tests. This service uses cookies to identify a visitor’s browser and analyse the use of this website. Cookies do not collect any personal data. You can find more information about how AB Tasty processes your data at https://www.abtasty.com/terms-.... This page also provides guidance on how to disable tracking at any time.
9.10 Hotjar
To improve your user experience on our internet pages we use software by Hotjar (http://www.hotjar.com, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe). Using the software, we can measure and evaluate user behaviour (mouse movements, clicks, keystrokes, scroll height, etc.) on our websites. For this purpose, cookies are placed on users’ terminals and data from users such as browser information, operating system, time spent on the page, etc. can be stored. You can find more information about the processing of data by hotjar at http://www.hotjar.com/privacy. You can object to the use of Hotjar’s services at https://www.hotjar.com/opt-out... Sojern
The SOJERN cookie collects information about your travel activities and preferences of online travel partner sites and shows you personalized and relevant ads when you browse other websites and social media platforms. SOJERN may also enable storing conversion information used for tracking, reporting and to optimize the performance of SOJERN campaigns. You can learn about SOJERN and unsubscribe https://www.sojern.com/privacy... more.
9.12 Snowplow
This website/app uses Snowplow Opensource, an analysis technology of Snowplow Analytics Limited (The Rome Building, 32-38 Scrutton Street, London, EC2A 4RQ, United Kingdom). With the help of this analysis technology, we collect statistical data about the use of our website. Information which your browser transmits is collected and evaluated in the context of the use of this website. This is done by cookie technology and pixels, which are incorporated into each web page. The data collected in this way are used to create usage profiles that form the basis for web statistics. You can prevent cookies being stored on your computer via a corresponding setting of your browser software. However, we point out that you might not be able to use all functions of this website to their full extent in this case. You can also prevent FreewayCamper from collecting the data generated by the cookie with respect to your use of the website, as well as the processing of this data by FreewayCamper, by objecting to such collection and processing using the following link: data.protection@freeway-camper.com
9.13 Criteo
This website uses the retargeting pixel Criteo, 32 rue Blanche, 75009 Paris, France. With the help of the remarketing pixel, it is possible Criteo to use the visitors of our website as a target group for advertising. For this purpose a Criteo cookie is stored on your PC. For more information about the scope and purpose of data collection and further processing and use of data by Criteo and your settings options for protecting your privacy please see the privacy policy under Criteo https://www.criteo.com/privacy... -on-internet-browsers / https://www.criteo.com/privacy...-on-internet-browsers/. The use of cookies you can object under www.youronlinechoices.com/de/p....
10. Social Plugins
Our website uses social plugins of the social networks Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, Twitter, Inc., 795 Folsom St., Suite 600 San Francisco, CA 94107, USA, Pinterest, Inc., 635 High Street, Palo Alto, CA, USA, and Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.
The plugins are located on our product page and are disabled in their initial state. If you click the appropriate button, then you are prompted in a new window to sign in to the social media provider. In this case, a cookie is placed on your computer. If you click on the button or are not logged on to the respective social media provider no cookie will be placed on your computer.
If you are a user of the respective social media provider and are logged in and click the button, this information is sent to your profile at the respective social media provider. If you interact with the plug-ins, for example by pressing the “Like” button on Facebook or by posting a comment, the corresponding information is also transmitted directly from your browser to the social network and stored there. Please refer to the data protection (privacy settings) provisions of the following providers for information about the purpose and scope of data collection as well as the further processing and use of data by the provider as well as your rights and setting options for protecting your privacy:
Facebook: http://www.facebook.com/policy.php
Twitter: http://twitter.com/privacy
Pinterest: http://about.pinterest.com/privacy
Instagram: http://instagram.com/about/leg... and Facebook are jointly responsible for the operation of the Facebook page, and we use anonymous statistical data provided by Facebook on the basis of Art. 6 para. 1 lit. f GDPR for the analysis of our Facebook page. The collection and processing of these data is the responsibility of Facebook. Further information about the collection and processing of these data and your rights to Facebook can be found in the privacy policy statement* on our Facebook page.
11. Updates and changes
The Privacy Statement must be adapted from time to time to reflect the actual circumstances and the legal situation. Please always check the Privacy Statement before you make use of our offerings and ensure you are up to date in respect of possible changes or updates.