Data Protection Policy
Last updated on September 1, 2023
Introduction and consent
Anyone who browses the fribourg.ch website is deemed to have accepted this Data protection policy by having made a deliberate decision to use the website and view its pages and content.
The website draws the attention of new visitors to the existence of this tacit consent using a dynamic banner, which appears at the bottom of their browsing window. This banner contains a link that refers to this Data protection policy.
Division of responsibilities between the partners responsible for the website
This Data protection policy applies to the whole of the website located at fribourg.ch. The website is the result of a partnership between several partner entities, as listed below. Each partner is responsible for the content published and data collected on the specific part of the website for which it has responsibility. In other words, each web page belongs to and falls under the responsibility of a specific partner entity.
The website is organised into a number of segments, each managed by a partner entity. The entity responsible for a particular page (with its contact details) is mentioned in the footer of each page for which it has responsibility. In addition, the logo for the entity responsible is also shown (in most cases) to the top left of the pages that belong to it.
Each entity has its own legal notice page, which provides its contact details and the third parties with which the entity concerned collaborates and shares data collected on the website.
All partner entities have signed up to this Data protection policy. They offer all the same guarantees to users of the website located at fribourg.ch, which is why this Data protection policy applies to the whole of the site.
Users of the website acknowledge that in order to exercise their rights, they must make direct contact with the entity responsible for the web pages for which they wish to exercise their rights or ask a question. If they have interacted with pages belonging to several partner entities, they may, of course, contact each entity concerned individually.
Partner entities of the fribourg.ch website
A full list of partner entities of the fribourg.ch website can be found below.
Click on the corresponding link to access the legal notice for a specific entity.
- Fribourg Tourist Board (Union fribourgeoise du Tourisme)
- Fribourgissima Image Fribourg (in French)
- Association Touristique de la Broye
- Fribourg Tourisme et Région
- Association régionale du Lac
- Schwarzsee-Senseland Tourismus
- Organisation touristique régionale de Romont et sa région
- La Gruyère Tourisme
- Les Paccots – La Veveyse Tourisme
Third parties with access to data
Entities with routine access to the data collected
Each of the partners responsible for the fribourg.ch website collaborates with a series of third-party service providers, which have access to all or some of the data collected on the website on a routine and continuous basis. The type of access depends on the role of the third party concerned (technical management of the website, marketing agency, IT manager, etc.).
The legal notice page specific to each partner mentions the name and website of the suppliers concerned. Please refer to this information.
Entities with occasional access to specific data
Most of the content featured on fribourg.ch relates to promoting tourism in the canton of Fribourg and its tourist regions. As a result, the fribourg.ch website features numerous activities, events, services, etc., organised or managed by businesses, associations or other third-party entities that are not partners of the fribourg.ch site within the meaning defined above.
Data may be transferred to a third-party entity involved in managing certain activities or offers. Given the significant number and fluctuation in the entities concerned over time (organisation of a single performance, one-off offers, etc.), it is not possible to draw up an exhaustive or stable list of the third-party entities concerned in relation to this Data protection policy or the legal notice of each partner entity.
Users of this website accept that the context of collecting personal data, typically via a form, in connection with a specific activity organised by a third-party entity that is not a partner of the fribourg.ch website may make the latter a legitimate recipient of the data collected through the form in question. These data are shared for the purpose of allowing the user to participate in the activity concerned and enabling it to go ahead.
Unlike the partners responsible for the website, these entities do not collect data directly from the site (to which they do not have technical access). Moreover, it should be noted that the only data likely to be shared with them are those that are explicitly collected in connection with the activity or activities for which they are responsible.
In the specific case of data transferred under these conditions, the data protection policy of the third-party entity responsible for the activity or offer in question applies and the user of the website accepts the conditions submitting a form in connection with the activity or offer concerned.
The personal data we collect
Within the meaning of the new Swiss Data Protection Act (2023), the term personal data means any specific data that can be associated with an identified or identifiable natural person.
It should be noted that data that are anonymised and accessible solely in the form of overall statistics are not personal data within the meaning of the law, provided that the content of the data themselves does not make it possible to identify natural persons by cross-referencing characteristics.
Partners of the fribourg.ch website have made particular efforts to ensure the protection of personal data.
How and why are data collected?
The nature, type and quantity of data collected depend essentially on each user’s deliberate interactions with the website.
Some common scenarios are described below. However, it is important to note that these scenarios do not cover all possible interactions between users and the website that generate the collection of personal data, since the site comprises over 20,000 pages and a wide variety of content.
In practice, given the variety of offers and activities published on the website, it is impossible to establish an exhaustive list of all the types of personal data collected. While we have described below the type of data collected for different scenarios to give users the best possible idea of the data collected from them, we cannot claim that this information is exhaustive.
Technical data collected by the web server
A series of data are collected automatically by the server for technical reasons during any visit to the website, to be able to send pages to the user’s web browser and manage the technical interaction between the user and the pages. In this context, the IP address of the device connecting to the website is necessarily communicated to the web server, which keeps it for a period of time in a technical log with other connection data (time stamp, etc.). The data collected are therefore minimal and necessary for the website to function.
Kinsta, the hosting platform for the website, processes and has access to the following data:
- IP address
- time and date of visit
- which pages were visited
- the visitor’s browser
This information is retained for a maximum of 35 days.
Google Analytics
We also use Google Analytics, which is a solution that collects and analyses users’ interactions with the website, on every page of the site. Google Analytics collects the following types of data, in particular:
- IP address
- geographical location of the IP address
- browser characteristics
- characteristics of the operating system used
- language preferences
- type of device used
- URL of pages visited
- data relating to browsing events within web pages
- session characteristics (duration, etc.)
- the website from which the site was accessed
- the name of the internet service provider
- other data
Data collected in this way are automatically anonymised by Google and only the partners responsible for the website have access to them. These data offer them a better understanding of users’ interests so that they can improve the content and organisation of the website. It is therefore impossible for those responsible for the website to have access to an individual’s specific interactions with the site, since they can only see overall statistical summaries. Data samples that are too narrow and would enable natural persons to be identified by cross-referencing characteristics are blocked by Google. Data used as the basis for more advanced analyses are only retained for 14 months (data are also anonymised in this case).
Each partner entity has its own Google Analytics account, where it can view only the data concerning the part of the website that it controls and for which it is responsible. The Fribourg Tourist Board (Union fribourgeoise du Tourisme), which has project management rights for the technical development of the website, has overall access to Google Analytics statistics for the whole of the site.
The statistics collected and analysed using Google Analytics are used to improve the user experience on the website and to gain a better understanding of what interests people who interact with the canton’s tourist offering.
Google itself uses user identification information (in particular, use of a Google account or IP address) to which it has access, but these data are processed in accordance with strict data protection standards (with ISO 27001 certification) and are protected by the US Privacy Shield Framework, which is a framework agreement between the United States and Switzerland.
Hotjar
Hotjar is a tool that is built into the website and monitors the behaviour of visitors to the site, including videos that film mouse movements during sessions, clicks, scrolling, etc. All sessions recorded by Hotjar are anonymised and no personal data are collected.
The information we obtain from Hotjar analyses allows us to understand our visitors’ interaction with our website in order to improve its ease of use and offer a better user experience.
Social media
Social media channels are used by the partners responsible for the website for advertising campaigns and distributing marketing materials. Partner entities of the fribourg.ch website have installed tracking pixels that allow certain data to be shared between Google Analytics (for the website) and social media platforms.
Each social media channel has its own data protection policy, which is available by clicking below on the name of the social network concerned.
We have listed, below the name of each social network, the names of the partner entities of the fribourg.ch website that use the social network in question.
- Fribourg Tourist Board (Union fribourgeoise du Tourisme)
- Fribourgissima
- Estavayer-le-Lac Region
- Lake Murten Region
- Schwarzsee-Senseland
- Fribourg Tourisme
- Romont Region
- La Gruyère Tourisme
- Les Paccots – La Veveyse Tourisme
- Fribourg Tourist Board (Union fribourgeoise du Tourisme)
- Fribourgissima
- Estavayer-le-Lac Region
- Lake Murten Region
- Schwarzsee-Senseland
- Fribourg Tourisme
- Romont Region
- La Gruyère Tourisme
- Les Paccots – La Veveyse Tourisme
- Fribourg Tourist Board (Union fribourgeoise du Tourisme)
- Fribourgissima
- Estavayer-le-Lac Region
- Lake Murten Region
- Fribourg Tourisme
- La Gruyère Tourisme
YouTube
- Fribourg Tourist Board (Union fribourgeoise du Tourisme)
- Fribourgissima
- Estavayer-le-Lac Region
- Lake Murten Region
- Fribourg Tourisme
- Romont Region
- La Gruyère Tourisme
- Les Paccots – La Veveyse Tourisme
X
- Fribourg Tourist Board (Union fribourgeoise du Tourisme)
- Fribourgissima
- Romont Region
- La Gruyère Tourisme
Flickr
- Fribourgissima
- Schwarzsee-Senseland
- Fribourg Tourisme
- La Gruyère Tourisme
- Fribourg Tourist Board (Union fribourgeoise du Tourisme)
- Fribourgissima
- La Gruyère Tourisme
When using contact forms
The website contains contact forms that allow users to send a message to the partners responsible for the site.
The act of completing one of these forms and clicking on the “Send” button is deemed to demonstrate the user’s intention of sharing the data submitted via the form.
In this context, the user’s first name, last name and e-mail address are typically collected to establish communication with the person concerned, in order to respond to them. Other information submitted through the form will obviously also be accessible to employees who process the message on behalf of the partner entity to which the form in question is sent.
When subscribing to a newsletter
Users of the website may subscribe to one or more newsletters offered by site partners.
In this context, the form will typically collect the following data:
- title
- first name and last name
- e-mail address
- address
- post code
- town/city
- country
- phone number
These data are used to send out the newsletter and personalise the recipient’s details.
By submitting a form of this kind, the user accepts that their data will be used to provide the service associated with the newsletter. The user accepts that the software used to manage sending out newsletters will produce specific statistics connected with the fact that the user opens or clicks on the links included in them.
We use these data for statistical purposes and to optimise the content and layout of the newsletter. This allows us to target the information and offers included in the newsletter, based on the interests of the recipient concerned.
The user has access to a link in the footer of each newsletter to allow them to unsubscribe. When a user unsubscribes from a newsletter in this way, their personal data are deleted within the next 24 hours.
When entering a competition, contest or prize draw
The website regularly offers the chance to enter competitions, online games or prize draws.
In this context, the form collects a series of personal data and uses them in relation to the competition concerned, to establish entry statistics and, depending on the situation, to publish the results. The fact that the results will be published is mentioned in writing in the context of the competition concerned.
By entering the competition, a website user accepts that their personal data will be used subsequently to send them offers of products and services. In particular, the user acknowledges that their entry to the competition means that they accept that their personal data may be used to send them advertising by post, phone, email or text message/WhatsApp. Use of the personal data of competition entrants extends to the partners who sponsor the competition prizes. This means that personal data collected in relation to a competition may be transferred from the partner entity responsible for the competition to third-party entities sponsoring the competition concerned.
When placing an order or making a booking with third parties
The partners responsible for the website collaborate with numerous third-party entities that promote their own offers or the possibility of making a booking for an activity or service.
In this type of context, the user accepts that the data they submit via a form will be sent to the third-party entity explicitly mentioned on the website in connection with the activity, offer or service in question.
In this case, the user of the website acknowledges that in submitting the form in question, they accept the data protection policy of the entity concerned in terms of the processing of the related data.
Data security
Deliberate measures have been implemented, both technically and organisationally, to ensure that the personal data collected on the website are protected from unauthorised access by third parties, in order to avoid unauthorised changes or disclosures.
The website and the other systems used to manage personal data collected from it are updated regularly in order to protect these data.
The employees of the partners responsible for the website, and all suppliers with regular access to the personal data collected by the site, have been informed of this data protection policy and made aware of their role and obligations in relation to it.
Right of access, rectification, erasure and limitation of processing; right to data portability
You have the right to obtain information on the personal data collected and held about you, on request and free of charge.
You have the right to have inaccurate data corrected and to erase your personal data, provided there is no statutory obligation to archive it and no statutory authorisation in place, allowing said data to be processed.
In certain contexts, as provided by the new Swiss Data Protection Act, you have the right to limit or object to the processing of your personal data. In addition, you have the right to ask us to send you the data you have communicated to us (right to data portability).
In the scenarios described above, you must contact the partner entity with which you wish to exercise your rights.
Personal data retention and storage period
Partner entities of the fribourg.ch website undertake not to retain personal data for more than 12 months.
The website makes certain offers that have a contractual value. In this context, evidence of this type of commercial interaction is retained for 10 years in accordance with Swiss tax legislation.
Responsibility of the user
As a user of the website, and insofar as you send us personal data, you undertake, by accepting this data protection policy, that the data you provide to us are accurate, detailed, complete and up to date. Accordingly, the user is responsible for the accuracy of all data entered and must keep the information provided up to date in order to reflect their actual situation. We are not responsible for verifying the accuracy of the data sent to us, or checking whether their content has changed.
If you send us personal data concerning third parties, the user guarantees that they have informed the persons or entities concerned of the conditions of this data protection policy and obtained their consent to submit the personal data concerned.
The user is responsible for any false or inaccurate information they may have provided on the website and, if applicable, any direct or indirect harm caused to the third party concerned or to us. If a user sends us personal data concerning a third party against the latter’s wishes, the latter may not under any circumstances make a claim against us and we decline any liability in respect of the third party concerned.
Outbound and inbound links
Links to other websites
The fribourg.ch website includes links pointing to third-party websites to offer site visitors useful and informative external resources. These links can be found on buttons or incorporated into text or banners, etc. We cannot be held liable for any of the websites concerned (except for the fribourg.ch domain) and we offer no guarantee regarding the content of the pages in question. We have no control over the sites concerned and are not responsible for monitoring, verifying or approving the information, content, products or services provided by other websites to which links point from the fribourg.ch site. It should also be noted that at times, the content of pages to which we incorporate links may be changed by the owner of the page concerned or that the latter redirects our link to another page.
Accordingly, if users of our website notice that the activities carried out on said third-party websites are illegal or contrary to high moral standards or public order, they should inform us so that we can deactivate the links concerned as soon as possible.
Links to the fribourg.ch website from other web pages
We do not authorise the creation of a link to this website from web pages that contain illegal, unlawful, degrading or obscene documents, information or content, or that are, in general, contrary to the law, high moral standards or public order, or to generally accepted social norms.
Use of cookies
Cookies are small text files or pieces of information that the website places on the user’s device (computer, tablet, phone, etc.) through the web browser used by them during their visits to the website. A cookie normally contains the name of the website it comes from, the “lifespan” of the cookie (i.e. how long it will remain on your device) and a randomly generated number. It may contain various other kinds of information to achieve the objectives described in this data protection policy.
For more information about how cookies work, please see: http://www.allaboutcookies.org/fr/ (only in French).
Why do we use cookies?
Like the vast majority of websites, we use a series of cookies so that our site can communicate with your browser to improve your user experience, for example by rendering the website faster in your browser and optimising other aspects connected with the ease of use of the site.
We also use cookies to compile anonymous statistics that help us to understand how visitors use our website. This gives us a basis for optimising the website in terms of structure, navigation, content and ease of use, but also for developing a marketing strategy based on the interests of visitors to the site.
What cookies do we use?
The cookies used by the site depend on the context. You can explore the cookies used by the pages on fribourg.ch using the website Cookie Script.
How to disable cookies
You can disable cookies in your web browser. Please note that this will impact your visits to all websites that use cookies and that the quality of your browsing experience will decline (on sites that use cookies to improve it).
Links to disable cookies, depending on your browser:
Changes to our data protection policy and applicable law
The Fribourg Tourist Board (Union fribourgeoise du Tourisme), Fribourgissima Image Fribourg and partner tourist regions reserve the right to amend this data protection policy at any time and without notice, to ensure that it is up to date and reflects the current practices of website partner entities. The current version published on the website applies.
This data protection policy is governed by and must therefore be interpreted in accordance with Swiss law. You agree to refer all disputes arising from your use of this website to the sole jurisdiction of the Swiss courts. The place of jurisdiction is Fribourg (city).
