Privacy Policy

Yes, we also focus on sun, beach, and surfing. However, we also ensure the protection and security of your data. At this point, we want to inform you about this, not only so that you know what happens to your data but also so that you know what rights you have. And to be able to give your consent comprehensively informed where legally required.

Let’s start with the basics. Personal data refers to any data that is related to you, such as your name, age, email address, and even your IP address since it can identify you. In addition to this so-called “personal master data”, we collect, for example,

data on your bookings or orders in our shop, which are necessary for the correct provision of services
data to fulfil our legal obligations such as your consent to receive our Primesurf newsletter or other advertising data
information on the use of our telemedia offered, such as access to our website or the use of communication media for alignment purposes.

We only store and process data that we have received from you as part of our business relationship or that has been legitimately transmitted to us by third parties.

Processing such data always requires a legal basis and a defined purpose. Without these, we are not allowed to process the data. This also means that if the purpose for processing the data no longer exists, we must delete it.

In short: we are responsible for your data. Before processing it, we have thought about the purpose, legal basis, and proper security measures. “We” specifically means:

Primesurf GmbH

Kanonenberg 20

21423 Winsen (Luhe)

If you have any questions, feel free to send us an email at info[at]primesurf.com or approach us directly. As a data subject, you also have various rights that you can assert against us. This includes, in particular, the right to information. If you want to know what data we store about you and for what purpose we process it, please contact us, and we will provide the information as required. If you discover that we are storing incorrect data, whether it is because we have accidentally recorded something incorrectly or your address has changed in the meantime or similar, then we are obliged to correct this. The same applies to the deletion of data: if you notice that we are processing data that we should no longer process because the purpose no longer exists, please let us know, and we will stop processing it immediately or delete the data.

We will explain all your rights in detail below, but before that let’s see what data we process.

Data Collection on this Website

We collect various data on our website. In the following we would like to inform you about them.

Technically necessary data processing

Just by accessing this website, we already collect data, such as which browser you are using, which operating system, and from which IP address you are accessing the website. This is a technical necessity. Without IP addresses, the internet would not work. This is the first category of data: everything related to the technical aspects of accessing the website and what is required for it. This includes the cookies that are necessary for the operation of our website. Cookies are small text files that are stored on your device and contain information.

Our website is operated by Host Europe Web Hosting. This means that our website is located on a server under their sovereignty. Each time you access our website, it is logged for security purposes and is of course in our interest. After all, we want to provide you with a safe, stable, and high-performance website. Host Europe stores the following information:

Your IP address
Date and time of access
Name and URL of the retrieved file
the fact that you come from our website
the browser used and, if applicable, the operating system of your computer, as well as the name of your access provider

For the same purpose and legal basis, we also use Cloudflare Stream and CDN. Cloudflare offers the possibility to stream videos and store other files. However, since the data is not directly on our server (i.e., Host Europe’s), Cloudflare’s server is called, and they receive your IP address and the same information as when you access our server.

This means that data is transferred to other companies. In addition, we need to store data (in the form of cookies) on your terminal device so that our website functions correctly. These are listed in the Consent banner under “Essential”. This includes, for example, the language you have selected or which selection you have made in the Consent banner.

Data Processing after Consent

And that brings us to the consent banner. Besides the technically necessary cookies and external requests, there are also services for which we require your consent for usage.

Why do we need that consent? There can be two reasons. Firstly, we cannot access data on your device for functionalities that are not necessary for you as a visitor of the site, such as saving cookies for marketing purposes. Secondly, we cannot make external requests without your consent for services that are deemed unsafe by the EU for data protection purposes, such as embedding Google Maps or accessing Google Web Fonts, as the USA are currently considered an unsafe third country for data security. As you can see from our consent banner, there are three main topics:

Website Analysis (aka Google Analytics)
Marketing (aka Meta Pixel)
External requests

Google Analytics

We use Google Analytics 4, a web analysis service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). This service allows us to find out how you use our website. In addition, Google enriches this data with “demographic characteristics”, allowing for more targeted marketing actions. However, we only have access to statistical, anonymized information. Google Ireland may transfer data to its American parent company. Therefore, we require your explicit consent, which you can give (and revoke) through the consent banner. In addition, some browsers (depending on settings) may block the requests.

Meta Pixel

Meta Pixel is the same, but not from Google, but from Meta Platforms Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland (formerly Facebook). Here too, it is about analyzing website visits and based on that, remarketing. We only use this if you have given us your consent in the consent banner. Please note that Meta is likely to link all this information together (including your Facebook profile if you have one) and use it for its own purposes.

External Calls

At some places on our website, we have embedded content from external sources. For example, so that you can directly see our surf locations and check whether the weather is suitable for surfing in the next few days. We do not prepare this information ourselves, but rather have a window on the page that shows you the provider’s website directly. Our goal is to provide you with all the information you need to easily plan your events with the best possible information. Unfortunately, there are legal requirements here, because we are referring you to others, and you are giving information to them.

Therefore, you can either globally allow individual providers in the consent banner, or you will be explicitly asked at the individual places where we embed content whether you want to allow this.

Windy.App is a weather app specially designed for wind and water sports. It is operated by Windy Weather World Inc. We use it on the destinations pages to display wind statistics and forecasts.

Windguru provides current wind conditions. It is operated by Ing. Václav Horník, Taussigova 1152, Praha 8, 18200, Czech Republic.

We use IP Live Cam to display live videos on some of our destination pages. The website is operated by IPCamLive.com Ltd, Hungary, Infopark, 1117 Budapest Neumann János utca 1/B.

Legitimate Interest

As mentioned before, if none of the legal bases mentioned above apply, but we still process your data, we do so because we have a so-called “legitimate” interest in doing so.

Communication

You can contact us via our website. There is a contact form for this purpose and we look forward to every message from you. We will store the message(s) and your e-mail address for as long as we need them to process your enquiry.

At the same time, you can register to receive the Primesurf newsletter via the website to be informed exclusively and free of charge about our destinations and events, current promotions and offers and highlights from the world of kitesurfing. To send our newsletter, we use Zoho Campaigns, a service provided by Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany.

In addition to the possibility of creating newsletters, Zoho Campaigns provides analysis tools that make it possible to make statements about the success of the newsletter dispatch.

In this context, we process some of your data automatically with the aim of evaluating certain personal aspects (profiling), e.g. evaluation for targeted customer contact and needs-based advertising, including market and opinion research.

Booking Requests

As you know, we are a network of companies that operate different locations, for example. If you want to make bookings through our website, you will be redirected to another website or reach it through embedded content. You can recognize this by the URL of the page starting with “booking.” If necessary, you will be redirected to the pages of our partner companies. Here, too, the URL of the page changes because you switch the domain (this is the back part of the URL). No data is passed on in this process, we just direct you to the right booking pages. Everything else is then handled through our partner’s website, which is described below.

Contractual Data Processing or pre-contractual Data Processing

We (and our partners) use Bookinglayer as a booking platform. This was developed by a Dutch company called Timtim BV especially for vacation events. The address is: TimTim BV, Stationsweg 23, 9671 AM in Winschoten. This is used to manage the entire booking process. We process this data to be able to fulfill the contract with you (your booking).

When organising raffles, we use personal data, for example for sending prizes.

We store data that you enter in our online shop as part of your order for contract processing, order dispatch and warranty purposes. Our online shop runs on the online shop software Shopify from the provider of the same name Shopify Inc, 151 O’Connor Street, Ground floor, Ottawa, ON, K2P 2L8, Canada.

Categories of recipients

In order to fulfil the intended purposes, the data required in each case may be accessed across departments within our company (including across national borders). Processors employed by us may also receive data for certain purposes, e.g. for IT services, document destruction and marketing.

Your Rights – this Time in Detail

We have briefly mentioned this before, but the legislator obliges us to inform you in detail about your rights regarding data protection. We are happy to comply with this obligation here. Before we begin, it should also be noted that all of this sounds very technical – and we have tried not to use legal jargon. Communication is key, here and on the water. Therefore, simply approach us if you have any questions about data protection, comments, or if you have an issue where we can support you.

Information, Deletion, and Correction

Under the applicable legal provisions, you have the right to obtain, at any time and free of charge, information about your stored personal data, their origin and recipients, and the purpose of data processing, and, if applicable, the right to correct or delete this data.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You can revoke any consent given to us at any time. From the point of revocation, we may not and will not process your data any further.

Right to Object to Data Processing

This may sound a bit technical: revocation, objection. In both cases, however, it is about you requesting that we no longer process your data. As described above, in the first case, you have previously given your consent, and in the second case, we have processed your data based on legitimate interest, and you are now objecting to it. In principle, you may always contact us if you believe that we should no longer process your data – regardless of the wording used.

This also applies, in particular, if we send you advertising and you no longer wish to receive it.

Right to Restriction of Processing

There may be reasons why you do not want us to continue processing your data. This includes, in particular, the deletion of this data. This is related, for example, to the rights mentioned above. If we have incorrect data, you can request that we do not use this data until it is corrected. Or you object to the processing, and we have to examine whether there are interests that are so important that we still have to continue processing the data. We cannot think of a suitable example right now.

However, the classic case here is: you need the data to assert legal claims. Whether against us or third parties is irrelevant, but then you could demand that we keep this data beyond its actual storage period.

Right of Appeal to the Competent Supervisory Authority

In case of violations of the applicable data protection laws you have the right to complain to the supervisory authority. For us (Primesurf GmbH), this is the Landesdatenschutzbeauftragte of Lower Saxony.

Obligation to provide data

You only need to provide the personal data that is required for the establishment, performance and termination of a contract or that we are legally obliged to collect. If you do not wish to provide us with the necessary information and documents, we may not enter into or continue the business relationship you have requested.

Change to our Privacy Policy

We reserve the right to adjust this privacy policy from time to time so that it always complies with the current legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. The new privacy policy will then apply to your next visit.