With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data" for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the "Online Offer").
The terms used are not gender-specific.
Status: March 16, 2020
DI Brigitte Amort
Authorized representative: DI Brigitte Amort
E-mail address: email@example.com
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
In the following, we share the legal bases of the General Data Protection Regulation (DSGVO) on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
National data protection regulations in Austria: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act - DSG). In particular, the Data Protection Act contains special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases.
We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, which includes US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. The primary purpose of a cookie is to store information about a user during or after their visit within an online service. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as "user IDs").
The following cookie types and functions are distinguished:
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.
If we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Economic analyses and market research: For business reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. regarding services used. The analyses serve only us and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take the privacy of the users into consideration and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).
Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution.
The necessary data are marked as such in the context of the order or comparable acquisition process and include the data required for delivery or provision and invoicing as well as contact information in order to be able to contact you if necessary.
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions for this purpose (collectively "payment service providers").
The data processed by the Payment Service Providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to complete the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the data protection information of the payment service providers.
For payment transactions, the terms and conditions and data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of revocation, information and other data subject rights.
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. In all other respects, please refer to the information on the processing of visitors to our Publication Medium within this Privacy Notice.
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests, to process users' details for the purpose of spam detection.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects.
When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the inquiring person is processed to the extent necessary to respond to the contact requests and any measures requested.
The response to the contact requests in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of legitimate interests in responding to the requests.
We use messenger services for communication purposes and therefore ask you to observe the following information on the functionality of messengers, encryption, use of communication metadata and your options to object.
You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of messages is not viewable, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we also point out to our communication partners that the messenger providers cannot view the content, but they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.
Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis of our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use Messenger in relation to our contractual partners as well as in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communicating via Messengers. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume to have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer enquiries via Messenger. This is the case if, for example, contractual internals require special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels.
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. If, in the context of a registration for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Apart from that, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.
Deletion and restriction of processing: We may store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. Processing of this data will be limited to the purpose of possible defence of claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal basis: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.
Content: Information about us, our services, promotions and offers.
Performance measurement: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us rather to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the performance measurement is not possible, in which case the entire newsletter subscription must be cancelled, or it must be contradicted.
We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.
After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
We process personal data of participants in sweepstakes and contests only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, implementation and handling of the sweepstakes, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the sweepstakes or the protection of our interests against abuse through possible collection of IP addresses when submitting sweepstakes entries).
If contributions from participants are published as part of the sweepstakes (e.g. as part of a vote or presentation of the sweepstakes entries or the winners or reporting on the sweepstakes), we point out that the names of the participants may also be published in this context. Participants may object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the usage and data protection provisions of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants within the scope of the competition and that inquiries with regard to the competition should be directed to us.
The participants' data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries regarding the competition are to be expected. As a general rule, participants' data will be deleted no later than 6 months after the end of the competition. Winners' data may be retained for longer, e.g. in order to answer queries about the prizes or to be able to fulfil the prize obligations; in this case, the retention period depends on the type of prize and is up to three years in the case of goods or services, for example, in order to be able to process warranty claims. Furthermore, the participants' data may be stored for a longer period, e.g. in the form of reporting on the competition in online and offline media.
If data was also collected for other purposes within the scope of the competition, its processing and the retention period will be governed by the data protection information on this use (e.g. in the case of registration for the newsletter within the scope of a competition).
We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, "content") based on users' potential interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) are stored within the scope of the online marketing procedure, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the profiles of the users with the aforementioned data. We ask that you note that users may make additional arrangements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
Facebook pixel: With the help of the Facebook pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. The Facebook Pixel also allows us to track the effectiveness of Facebook Ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook Ad (known as "conversion measurement").
Services used and service providers:
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users, because, for example, it could make it more difficult to enforce the rights of the users. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with EU data protection standards.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the computers of the users, in which the usage behavior and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Services used and service providers:
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or functionality. We endeavour to use only such content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.
Services used and service providers:
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that addresses may change over time and please check the details before contacting us.
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 of the GDPR:
This section provides you with an overview of the terms used in this Privacy Notice. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.
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