FAIRWAY 2 HOTEL Apps and Website
As of March 2026
1. Data Controller
The controller responsible for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:
FAIRWAY 2 HOTEL e.U. – Owner Andreas Brantner
Ölzeltgasse 15
1230 Vienna
Austria
Email: [email protected]
2. General information on data processing
This privacy policy informs you about what personal data we collect and process when you:
use the FAIRWAY 2 HOTEL website
use the FAIRWAY 2 HOTEL mobile app
FAIRWAY 2 HOTEL offers users access to digital vouchers for golf courses and hotels in several European countries.
The processing of personal data takes place exclusively in accordance with the applicable legal provisions, in particular the General Data Protection Regulation (GDPR).
We do not sell personal data to third parties.
3. Categories of data processed
3.1 Contact details
The following data may be collected during registration or when using certain functions:
First name and surname
Email address
This data is used to create, manage and use your user account.
3.2 Account data
The following account data may be processed when using the app:
User ID (unique user identifier)
Authentication provider (e.g. Apple Login, Google Login or email login)
Language setting
3.3 Device data
The following information may be processed for the technical provision and secure use of the app:
Device identifier (e.g. iOS Vendor ID or Android ID)
Device name and model
Operating system and version
App version
Push token for push notifications
This data is used to ensure the technical functionality, security and stability of the application.
3.4 Location data
The app may access your location to display golf clubs or hotels in your vicinity.
The following data may be used for this purpose:
GPS coordinates (latitude and longitude)
Location data is processed exclusively locally on your device and is not transmitted to our servers.
3.5 Purchase data
The following data may be processed for in-app purchases or subscriptions:
Transaction ID
Purchase receipt
Subscription status
Voucher redemption data
This data is required to verify purchases and manage vouchers.
Payment processing is handled by:
Apple App Store
Google Play Store
PayPal
Stripe
3.6 Usage data
To improve our services, the following usage data may be processed:
pages visited
Search queries
Favourites
Filter settings
Interactions within the app
3.7 Diagnostic data
To ensure technical stability and for error analysis, the following data may be processed:
Crash reports
Error logs
Performance data
4. Purpose and legal basis of processing
The processing of personal data is carried out on the basis of Article 6 of the GDPR for the following purposes:
Purpose | Legal basis |
|---|---|
Registration and user login | Article 6(1)(b) GDPR – Performance of a contract |
Provision of app functions | Art. 6(1)(b) GDPR – Performance of a contract |
Management of vouchers | Art. 6(1)(b) GDPR – Performance of a contract |
Analysis of usage (analytics) | Art. 6(1)(a) GDPR – legitimate interest |
Measurement of advertising effectiveness | Art. 6(1)(a) GDPR – Consent |
Error analysis and performance monitoring | Art. 6(1)(f) GDPR – legitimate interest |
5. Third-party providers used
Our app and website use the following external services.
PostHog (Analytics)
Purpose: Analysis of user behaviour and app usage.
PostHog is used as a cloud service. Data processing takes place via the PostHog EU Cloud, with servers located in the European Union.
Processed data may include:
Interactions within the app
Anonymised usage data
User ID
Provider: PostHog, Inc.
Further information:
https://posthog.com/privacy
Sentry (error analysis)
Purpose: Analysis of errors and monitoring of the app’s technical performance.
Sentry is used as a cloud service. Data processing takes place via the Sentry EU Cloud, with servers located in Germany.
Processed data may include:
Crash logs
Device information
Performance data
Provider: Functional Software, Inc. (Sentry)
Further information:
https://sentry.io/privacy/
Meta Conversions API
Purpose: To measure and optimise the effectiveness of advertising campaigns.
Certain events are transmitted from our servers to Meta for the analysis of campaign performance:
Purchase
CompleteRegistration
Data is transmitted exclusively on the server side – no advertising IDs or tracking SDKs are used on your device.
Further information:
https://www.facebook.com/privacy/policy/
Mapbox
Purpose: Display of maps and golf club locations.
More information:
https://www.mapbox.com/legal/privacy
Apple App Store / Google Play Store
Purpose: Processing and validation of in-app purchases.
Expo Push Service
Purpose: Delivery of push notifications.
The following data may be processed:
Push tokens
Device information
App version
Further information:
https://expo.dev/privacy
6. Measurement of advertising effectiveness
To measure the success of advertising campaigns, certain events (e.g. purchases, registrations) are transmitted to Meta on the server side via the Meta Conversions API.
No device-specific advertising IDs are collected or transmitted. The app does not use Apple’s App Tracking Transparency (ATT), as no device-based tracking takes place.
This processing takes place exclusively with your consent, which can be changed or withdrawn at any time in the app settings.
7. Consent Management
When the app is launched for the first time, users can decide whether to allow the following data processing:
Measurement of advertising effectiveness (Meta Conversions API)
Consent can be changed or withdrawn at any time in the app settings.
8. Data storage
Local storage on the device
The following data may be stored locally.
AsyncStorage:
Settings
Filter settings
Consent status
Personal notes
Secure Store:
Authentication tokens
Offline keys
Server-side storage
The following data is stored on our servers:
Account details
Purchase history
Voucher redemptions
Server location:
Hetzner Online GmbH (Denmark)
9. Retention period
Personal data is only stored for as long as is necessary for the respective purpose.
Account data is stored for as long as the user account is active and is deleted no later than 30 days after the account is deleted.
Purchase and billing data may be stored for up to 7 years due to statutory retention obligations.
Analytics data is anonymised or deleted after 12 months at the latest.
Crash and performance data are stored for a maximum of 90 days.
Push tokens are stored for as long as the app is installed or until the user account is deleted.
10. Your rights
Under the GDPR, you have the following rights:
Access to stored data (Art. 15 GDPR)
Rectification of inaccurate data (Art. 16 GDPR)
Erasure of your data (Art. 17 GDPR)
Restriction of processing (Art. 18 GDPR)
Data portability (Art. 20 GDPR)
Objection to processing (Art. 21 GDPR)
Withdrawal of consent (Art. 7 GDPR)
To exercise your rights, please contact:
11. Account deletion
You can delete your account directly in the app at any time.
To do so, go to:
App → Profile → Account & Security → Delete Account
Alternatively, you can also request deletion via our website or by email.
For further information, please visit:
https://fairway2hotel.at/account-loeschung/
12. Push notifications
The app can send push notifications.
The following data may be processed in this context:
Push tokens
Device information
Platform (iOS or Android)
Push notifications are only activated with the user’s explicit consent.
You can deactivate these at any time in your device settings.
13. Data transfer to third countries
Some of our service providers may process data outside the European Union, in particular in the USA.
In such cases, the transfer is based on appropriate safeguards in accordance with Article 44 et seq. of the GDPR, in particular the European Commission’s Standard Contractual Clauses.
14. Children
The FAIRWAY 2 HOTEL app is not intended for children under the age of 16.
We do not knowingly collect personal data from children.
15. Changes to this Privacy Policy
We reserve the right to amend this privacy policy in the event of changes to our services or legal requirements.
You can find the current version at:
https://fairway2hotel.at/datenschutzerklaerung/
16. Right to lodge a complaint
You have the right to lodge a complaint with a data protection supervisory authority.
Competent authority in Austria:
Austrian Data Protection Authority
Barichgasse 40–42
1030 Vienna
https://www.dsb.gv.at
17. Contact
If you have any questions regarding data protection, please contact:
FAIRWAY 2 HOTEL e.U. – Owner Andreas Brantner
Ölzeltgasse 15
1230 Vienna
Austria
Email:
[email protected]