Our Data Policy


Gorki Apartments Data Protection Statement


1. Scope of Validity

We take the protection of your personal data very seriously and treat your personal data confidentially and in accordance with the applicable data protection regulations and this data protection statement. 


With the following information, we would like to offer users of this website clarification on the nature, scope and purpose of the collection and use of personal data by us. The legal bases of the data protection are to be found, inter alia, in the German Federal Data Protection Act (BDSG), the Telemedia Act (TMG) and in the European General Data Protection Regulation.


2. Who is responsible for data processing and who can I contact?

The responsible body within the sense of data protection law is:


HRS Boardinghouse Betriebs-GmbH

Weinbergsweg 25,

10119 Berlin,



Tel.: +49 (0)30 48496480


3. What data do we use?

In principle, you can visit this website without informing us of your identity unless you send us an e-mail or send a message using the contact form, register or make a booking via this website. In these cases, we shall only process the data required for responding to your request or for the provision of our services. What data is collected, is clear from the respective input forms. The necessary items of information are marked as mandatory fields. Where we ask you for further information, this shall be voluntary information.


3.1 Making contact via our website / registration 

If you make contact or register with us by phone, by post, e-mail or via our website, we shall process your personal data for the purpose of responding to your requests, the provision of information and, if necessary, the sending of information material upon demand.

This shall concern in particular your surname and first name, your contact information, such as phone numbers, e-mail and fax, and possibly the name of the company / institution or organisation for which you work. In some cases, we will entrust a contract processor with the processing.

The legal basis for the processing of personal data Article 6 (1) f) GDPR. The data shall be treated confidentially and shall not be passed on to third parties.

Our legitimate interest in the processing of your personal data lies in providing you with the information you have requested.

Your data shall be deleted after the expiry of the statutory limitation periods and any resulting claims.


 3.2 Newsletter service
On our website, it is possible to subscribe to a free newsletter. In doing so, the data from the input screen during registration for the newsletter (first and last name, e-mail address and country) is transmitted to us.

If you would like to receive the newsletter, we shall require a valid e-mail address from you and information that will allow us to verify that you are the owner of the specified e-mail address or that the owner of such agrees to receive the newsletter. When you subscribe to the newsletter, we shall also save your IP address and the date of the registration. This storage shall serve solely to provide evidence in the event that a third party should misuse the e-mail address and register for receipt of the newsletter without the knowledge of the entitled person.

This data shall be used only for the purposes of the newsletter service and shall not be passed on to third parties. The legal basis for the data processing is your consent and thus Art. 6 (1) a) GDPR. In some cases, we shall entrust a contract processor with the processing.

Your consent to the storage of your personal data and the use of such for the forwarding of the newsletter may be revoked at any time. The revocation can be issued via a link in the newsletter itself or by sending a message to the above contact options (see 9.2 special note on revocation in accordance with Article 7 (3) GDPR).

If you unsubscribe to the newsletter, your data shall be permanently deleted.

3.3 Reservation via our website

If you make a booking via our website www.gorkiapartments.com , we shall process your personal data.

This shall involve your surname and first name, you title and academic degree where applicable, your address, contact information, such as your e-mail address and phone number and your credit card details.

The processing is performed for purposes of clear identification of the contractual partner and the initiation, implementation, administration and settlement of contracts, the issuing of invoices/credit notes, the administration and enforcement of claims and compliance with statutory requirements and data protection law (Article 6 (1) b) and c) GDPR). Where necessary, we shall process your data beyond the actual fulfilment of the contract in order to safeguard our legitimate interests or those of third parties for purposes of the assertion of legal claims and of defence in the case of legal disputes, for direct advertising, and in order to guarantee IT security. Furthermore, we shall process your data in order to be able to better design our offers on an individual basis or to more closely match your needs (Article 6 (1) f) GDPR).

In some cases, we shall entrust a contract processor with the processing. The data shall be treated confidentially and shall not be passed on to third parties.

We shall store the data for the duration of the contractual relationship with the customer. Should the data no longer be required to fulfil the contractual relationship, we shall delete the data after the expiry of the statutory limitation periods, any resulting claims and the relevant statutory retention obligations. 


3.4 Cookies

Our website uses cookies. Cookies are text files which are stored in the internet browser or by the internet browser on the user’s computer system. If a user retrieves a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic character string, which allows unique identification of the browser when the website is revisited.

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 (1) f) GDPR.

The purpose of the use of technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser can be recognized again even after a change of page. We do not use the user data collected by technically necessary cookies users to create user profiles or to provide visitors to our pages with advertising. The information generated by the cookie about your use of this website shall not be passed on to third parties.

Cookies are stored on your computer and transmitted by this to our site. Therefore, as a user you have full control over the use of cookies. You have the option to prevent the use of cookies. To do this, you must change the corresponding settings in your internet browser (e.g. Internet Explorer, Firefox, Mozilla, Opera, Safari, etc.). Previously stored cookies can be deleted at any time. This can also be automated. If cookies are disabled for our website, it is possible that not all of the features of the website will be usable to their full extent.


3.5. Access data / server log files

The provider (or its webspace provider) collects data on every access to the offer (so-called server log files). Access data includes:

  • name of the retrieved web page,
  • date and time of the access,
  • quantity of data transmitted,
  • notification of successful retrieval,
  • duration of the visit,
  • browser type and version,
  • the user’s operating system,
  • referrer URL (the page visited previously),
  • IP address and requesting domain

The provider uses the log data only for statistical purposes and for purposes of the security and optimisation of the offer. The provider reserves the right, however, to subsequently check the log data, should concrete evidence exist regarding a legitimate suspicion of unlawful use. The legal basis for the temporary storage of the data and log files is Art. 6 (1) f) GDPR.

The data shall be deleted as soon as it is no longer required for the achievement of the purpose of the collection of such. Where the data is collected for the provision of the website, this shall be the case once the respective session is finished. The data stored in the log files shall be deleted after 30 days at the latest.


The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. It shall therefore not be possible to object to this.

3.6 Are decisions made automatically including profiling?

We generally do not use any automated decision-making including profiling in accordance with Article 22 GDPR. In the event that we deploy profiling for targeted marketing within the framework of our activities, you shall be informed of such separately.

4. Upselling e-mail 

Data transfer to UpsellGuru GmbH
The UpsellGuru GmbH, Unterm Hagen 35 59939 Olsberg, collects the following personal data to send the guests a pre-email with up-selling possibilities for a specific reservation or stay.
Encrypted data will be transmitted to UpsellGuru GmbH: last name, first name, e-mail address, day of arrival, day of departure, status of reservation, language, title, title, booked room category.
You can revoke your consent at any time under info@gorkiapartments.de for the future.

5. Payment

Maestro, Visa, Mastercard, American Express

If you execute the payment by credit card, the payment is handled by the payment provider Concardis GmbH, Helfmann-Park 7, 65760 Eschborn / Germany. The required data (card number, validity and check number are forwarded in encrypted form to the payment provider and are not visible to the website operator.) The electronic payment method by credit card is PCI-DSS certified and offers the highest possible data security to the customer.


On our website we offer u.a. Payment via PayPal. Provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).

If you choose to pay via PayPal, the payment details you enter will be sent to PayPal.

The transmission of your data to PayPal is based on Art. 6 para. 1 lit. b DSGVO (contract execution).


6. Integration of services, third-party content and references

It may be the case that third-party content, such as YouTube videos, maps from Google Maps, RSS feeds or graphics from other websites may be integrated within this online offer. This shall always presuppose that the providers of such content (hereinafter referred to as the "Third Party Providers") become aware of the IP address of the user. Because without the IP address, they would not be able to send the content to the respective user's browser. The IP address is thus required for the presentation of such content. We strive to only use such content, where the respective provider uses the IP address solely for the delivery of the content. However, we have no influence on whether the third-party provider stores the IP address for statistical purposes, for example. To the extent that we are aware of such, we shall explain this to the user.

In the case of direct or indirect references to other websites ("hyperlinks") which lie outside of our area of responsibility, an obligation to assume liability would take effect exclusively where we had knowledge of the contents and where it would have been technically and reasonably possible to prevent the use in the event of illegal content.

We hereby expressly declare that, at the time of the link being made, no illegal contents were recognisable on the linked pages. We have no influence on the current and future design, contents or authorship of the linked/networked pages.

We therefore expressly dissociate ourselves herewith from all contents of all linked/networked pages which were changed after the link was made. This statement shall apply to all links and references made within the own website and for external entries in our guest books, discussion forums, link directories, mailing lists and all other forms of databases, to whose contents external write accesses are possible. Liability for illegal, incorrect or incomplete contents and especially for damages resulting from the use or non-use of information presented on such a basis shall rest solely with the provider of the page to which the reference was made, not with the person/entity who merely refers to the respective publication via links.

Permanent control of the contents of the linked pages is not reasonable without concrete evidence of a violation of the law. Should we become aware of any violations of the law, we shall immediately remove such links.

7. Which third-party modules, plug-ins and tools are used on the website?

7.1 Plug-ins

  • YouTube

Our website uses plug-ins from the Google-operated website, YouTube. The operator of the pages is YouTube, LLC., 901 Cherry Ave, San Bruno, CA 94066, USA.

In order to increase the protection of your data when you visit our website, the YouTube plug-in is integrated into the site by means of a so-called "2-Click" or "Shariff" solution. This integration ensures that when you retrieve a web page containing the YouTube plug-in, no connection is immediately made to the YouTube servers. Only when you click on the “activate video” button does your browser establish a direct connection to the YouTube servers. In doing do, the YouTube server is informed regarding which of our pages you have visited.

If you are logged in to your YouTube account, you shall allow YouTube to assign your surfing behaviour directly to your personal profile. You can avoid this by logging out of your YouTube account.

The use of YouTube is in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 (1) f) GDPR.

For further information on how user data is handled, please refer to the YouTube data protection statement at: https://www.google.de/intl/de/policies/privacy

  • Facebook, Twitter, Instagram, Pinterest and Spotify

Furthermore, our website also contains so-called "social plug-ins" from online social networks

  • Facebook.com (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland)
  • Twitter.com (Twitter Inc. Twitter, Inc. 1355 Market St, Suite 900, San Francisco, CA 94103, USA),
  • Instagram.com (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland)
  • Pinterest.com (Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland)
  • Spotify.com (Spotify AB Regeringsgatan 19 SE-111 53 Stockholm Schweden)
  • Whatsapp.com (WhatsApp Ireland Limited 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland).

In order to increase the protection of your data when you visit a website within our internet presence, the plug-ins are integrated into the site by means of a so-called "2-Click" or "Shariff" solution. This integration ensures that when you retrieve a web page containing such plug-ins, no connection is immediately made to the Facebook, Twitter, Instagram and Pinterest servers. Only when you activate the plug-ins and thus give your consent to the transfer of data does your browser establish a direct connection to the Facebook, Twitter, Instagram and Pinterest servers.

The content of the respective plug-in is transmitted directly to your browser and is integrated into the website. The plug-in then transmits data (including your IP address) to the operators of the named social networks. We have no influence on the amount of data that the social networks collect with the assistance of plug-ins. To our knowledge, Facebook, Twitter, Instagram and PINTEREST always obtain information on which of our web pages you have currently and previously called up. By calling up the plug-ins, Facebook, Twitter, Instagram and Pinterest then also receive the information that your browser has accessed the relevant page of our website, even if you do not have a profile in the social networks in question or are not currently logged in. This information (including your IP address) is transmitted directly by your browser to a Facebook, Twitter, Instagram or Pinterest server in the USA and is stored there. The information may possibly be published on the respective social network and be shown to your contacts. Because of the transmission abroad, we refer to Point 7 of this data protection statement.

For information on the purpose and scope of the data collection and further processing and use of the data by the named social networks and your rights in this respect and settings options for protecting your privacy, please refer to the data protection notices at:

  • http://www.facebook.com/policy.php
  • https://twitter.com/privacy
  • HTTPS://HELP.INSTAGRAM.COM/155833707900388
  • https://policy.pinterest.com/de/privacy-policy

If you are a member of one of the social networks, and you would like to limit the collection of data on our web pages and the merging of your user data with the data stored in the respective social network, you should log out there before you visit our website.


7.2 Analysis tools and advertising

Google Analytics
If you have given your consent, this website uses Google Analytics 4, a web analytics service provided by Google LLC. The responsible party for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").

Scope of processing
Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected by means of the cookies about your use of this website is generally transferred to a Google server in the USA and stored there.

Google Analytics 4 has IP address anonymization enabled by default. Due to IP anonymization, your IP address will be shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

During your website visit, your user behavior is recorded in the form of "events". Events can be:

  • Page views
  • First visit to the website
  • Start of session
  • Your "click path", interaction with the website
  • Scrolls (whenever a user scrolls to the bottom of the page (90%))
  • clicks on external links  
  • internal search queries 
  • interaction with videos
  • file downloads
  • seen / clicked ads
  • language settings

Also recorded:

  • Your approximate location (region)
  • your IP address (in shortened form)
  • technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
  • your internet service provider
  • the referrer URL (via which website/advertising medium you came to this website)

Purposes of processing
On behalf of the operator of this website, Google will use this information to evaluate your use of the website and to compile reports on website activity. The reports provided by Google Analytics serve to analyse the performance of our website.

Recipients of the data are/may be:

  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor under Art. 28 DSGVO).
  • Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
  • Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

It cannot be ruled out that US authorities may access the data stored by Google.

Third country transfer
Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, we have concluded
 EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against access by authorities.

Duration of storage
The data sent by us and linked to cookies are automatically deleted after 2 [OR: 14] months. The deletion of data whose retention period has been reached occurs automatically once a month.

Legal basis
The legal basis for this data processing is your consent pursuant to Art.6 para.1 p.1 lit. a GDPR [IF APLLICABLE:  Art.49a GDPR].

You can revoke your consent at any time with effect for the future by accessing the cookie settings [LINK TO CONSENT TOOL SETTINGS HERE] and changing your selection there. The lawfulness of the processing carried out on the basis of the consent until the revocation remains unaffected.

You can also prevent the storage of cookies from the outset by setting your browser software accordingly. However, if you configure your browser to reject all cookies, this may result in a restriction of functionalities on this and other websites. In addition, you can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google, by

a. not giving your consent to the setting of the cookie or
b. downloading and installing the browser add-on to disable Google Analytics

For more information on Google Analytics' terms of use and Google's privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/us/ and at https://policies.google.com/?hl=en.

Google AdSense
This website uses Google AdSense, a service for integrating advertisements of Google Inc. (“Google”). Provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

Google AdSense uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website. Google AdSense also uses so-called web beacons (invisible graphics). These web beacons can be used to evaluate information such as visitor traffic on these pages. From the evaluations, the appropriate advertising overlays for the user of our website are preselected. Adsense works in conjunction with Google Analytics. We have made sure that your IP address is anonymized by Google Analytics before being transferred to Google Ireland / USA.

The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. The storage of AdSense cookies is based on Art. 6 para. 1 lit. f DSGVO.

To stop receiving user related advertising, please follow this link: https://adssettings.google.com/ . There you can disable various types of advertising.

Google Site Tag
This website uses Google Site Tag, a service for collecting and transferring data (non-personal) to Google Analytics of Google Inc. (“Google”). Provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.
Google Site Tag uses so-called “code snippets” which are incorporated on the website. The Site Tag Manager makes it possible e.g. to provide a Google Analytics opt-out link for website visitors. The mention of this service is made for reasons of transparency.

Bing ads
We use Bing Ads (Bing Universal Event Tracking – UET) from Microsoft Corporation (One Microsoft Way, Redmond, WA 98052-6399, USA) on our website. In order to analyze and improve our online offer, a cookie is stored on the computer of the website visitor. The IP address and browser information are recorded and transmitted to the provider. The cookie contains a GUID assigned to the user’s browser and / or an ID assigned to the user as long as he is authenticated via the associated Microsoft account. The cookie expires automatically after 13 months. Remarketing measures automatically save the data to Microsoft Advertising for 6 months, but are not used by our company for these purposes. Microsoft Advertising does not sell this information to third parties, and it will not be shared with other advertisers. Bing Ads tells us only the total number of visitors who have clicked on a Bing Ad / Ad and were then redirected to the Conversion page. For our hotel there is a legitimate interest to use Bing Ads for the optimization of advertising measures according to legal basis Art. 6 (1) f GDPR.

You can control and oppose the use of Microsoft’s interest-based advertising data by visiting the Microsoft opt-out page: https://about.ads.microsoft.com/en-gb/resources/policies/opt-out-of-the-microsoft-advertising-optimization-program

For more information about privacy and cookies on Microsoft Bing Ads, please refer to the Microsoft Privacy Policy: https://privacy.microsoft.com/en-us/privacystatement.

FAQ: https://help.ads.microsoft.com/#apex/3/en/53056/2/#exp69

Microsoft is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation: https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.


8. Rights of the persons concerned

In accordance with Article 15 GDPR, you have the right to request information about the personal data stored by us about you at any time and free of charge.

Furthermore, in accordance with Article 16 GDPR you may request the rectification of incorrect data and, in accordance with Article 17 GDPR, the deletion of personal data, unless the processing is required for the exercise of the right to freedom of expression and information, for compliance with a legal obligation or for the assertion, exercise or defence of legal claims.

Furthermore, in accordance with Article 18 GDPR, you have the right to request the blocking or restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you reject the deletion and we no longer require the data, but you require this for the assertion, exercise or defence of legal claims, or you have lodged an objection to the processing in accordance with Article 21 GDPR.

Insofar as the conditions of Article 20 GDPR exist, you shall have the right to obtain the personal data with which you have provided us in a structured, common and machine-readable format and to request transmission to another responsible body.

If you are of the opinion that the processing of your personal data by us is not in conformity with applicable law, in accordance with Art. 77 GDPR, you may ultimately raise a complaint with a supervisory authority.

9. Special note on the right of objection in accordance with Article 21 GDPR

Based on reasons related to your specific situation, you have the right to submit an objection at any time to the processing of personal data affecting you, which takes place in accordance with Article 6 (1) f) GDPR (legitimate interest in a processing of personal data based on a balancing of interests).

Should you object to the processing of personal data, we shall no longer process your personal data, unless we can prove urgent legitimate reasons for said processing, which outweigh your interests, rights and freedoms or that the processing serves the assertion, exercise or defence of legal claims.

The objection may be entered form-free under the heading "objection to the processing of personal data" whereby your name and your address are to be stated. This should be addressed to:

HRS Boardinghouse Betriebs-GmbH

Weinbergsweg 25,

10119 Berlin,



Tel.: +49 (0)30 48496480

JULY 2023