Privacy Policy
Introduction
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and especially on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Date: December 2023
Table of Contents
Introduction
Overview of Processing
Relevant Legal Bases
Security Measures
Transfer of Personal Data
Data Processing in Third Countries
Deletion of Data
Use of Cookies
Provision of the Online Offer and Web Hosting
Web Analysis, Monitoring, and Optimization
Presence in Social Networks (Social Media)
Plugins and Embedded Functions and Content
Rights of the Data Subjects
Definitions of Terms Overview of Processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the persons affected.
Types of Data Processed
Inventory data.
Contact data.
Content data.
Usage data.
Meta/communication data.
Categories of Persons Affected
Users.
Purposes of Processing
Provision of contractual services and customer service.
Contact inquiries and communication.
Measurement of reach.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online offer and user-friendliness.
Relevant Legal Bases
Below, you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or seat. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
Consent (Art. 6 Para. 1 S. 1 lit. a GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes. Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures that occur at the request of the data subject. Legitimate interests (Art. 6 Para. 1 S. 1 lit. f GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests or fundamental rights and freedoms of the data subject that require the protection of personal data do not override. In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection in Austria apply. This includes in particular the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains specific provisions on the right to information, the right to correction or deletion, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases.
Security Measures
In accordance with legal requirements and considering the state of technology, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection commensurate with the risk.
These 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, transfer of, ensuring availability of, and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, data deletion, and responses to data compromise. In addition, we consider the protection of personal data in the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transfer of Personal Data
In the course of our processing of personal data, it may happen that the data are transferred to other bodies, companies, legally independent organizational units, or persons, or that they are disclosed to them. Recipients of this data may include, for example, service providers entrusted 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 corresponding contracts or agreements, which serve the protection of your data, with the recipients of your data.
Data transfer within the organization: We may transfer personal data to other bodies within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of data is based on our legitimate entrepreneurial and business interests or occurs if it is necessary for the fulfillment of our contract-related obligations, or if the consent of the data subjects or a legal permission exists.
Data Processing in Third Countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing occurs in the context of using third-party services or the disclosure or transmission of data to other persons, bodies, or companies, this is done only in accordance with legal requirements.
Subject to explicit consent or transmission required by contract or law, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard contractual clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Deletion of Data
The data processed by us will be deleted in accordance with legal requirements as soon as their consent permitted for processing is revoked or other permissions lapse (e.g., if the purpose of processing these data has ceased or they are not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or to protect the rights of another natural or legal person.
Within our privacy notices, we may provide users with additional information on the deletion and retention of data that are specific to each processing process.
Use of Cookies
Cookies are small text files or other storage tags that store information on end devices and read information from end devices. For example, to save the login status in a user account, shopping cart content in an e-shop, the content viewed, or functions used of an online offer. Cookies can also be used for different purposes, e.g., for the functionality, security, and comfort of online offers as well as the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from the users, unless legally not required. Consent is not necessary, in particular, if the storage and reading of information, including cookies, are absolutely necessary to provide a telemedia service (i.e., our online offer) expressly requested by the users. The revocable consent is clearly communicated to the users and includes information about the respective cookie usage.
Notes on data protection legal bases: The data protection legal basis on which we process users’ personal data using cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies are processed based on our legitimate interests (e.g., in the commercial operation of our online offer and its improvement) or, if this occurs in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. The purposes for which we process the cookies are explained in the course of this privacy policy or in the context of our consent and processing processes.
Storage duration: Regarding the storage duration, the following types of cookies are distinguished:
Temporary Cookies (also known as Session or Session Cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes their end device (e.g., browser or mobile application). Permanent Cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user revisits a website. Similarly, data collected using cookies can be used for measuring reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and the storage duration can be up to two years. General Information on Revocation and Objection (Opt-Out): Users can revoke their given consent at any time and also object to processing in accordance with legal requirements under Art. 21 GDPR (further information on objection is provided in this privacy policy). Users can also express their objection through the settings of their browser.
Further Information on Processing Processes, Procedures, and Services:
Processing of Cookie Data Based on Consent: We use a cookie consent management procedure, in which users’ consents to the use of cookies, or the processing and providers mentioned in the context of the cookie consent management procedure, can be obtained, managed, and revoked by the users. The declaration of consent is stored to avoid having to repeat the query and to be able to prove the consent in accordance with legal obligations. The storage can occur server-side and/or in a cookie (so-called Opt-In cookie, or using comparable technologies) to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following applies: The duration of storing the consent can be up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information about the extent of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used. Provision of the Online Offer and Web Hosting
To be able 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 can utilize infrastructure and platform services, computing capacity, storage space, database services, security services, and technical maintenance services.
The data processed in the context of providing the hosting offer may include all information concerning users of our online offer that is incurred during use and communication. This regularly includes the IP address, which is necessary to deliver the contents of online offers to browsers, and all entries made within our online offer or on websites.
Types of Processed Data: Content data (e.g., entries in online forms); Usage data (e.g., visited webpages, interest in content, access times); Meta/communication data (e.g., device information, IP addresses). Affected Persons: Users (e.g., website visitors, users of online services). Purposes of Processing: Provision of our online offer and user-friendliness; performance of contractual services and customer service. Legal Bases: Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f GDPR). Further Information on Processing Processes, Procedures, and Services:
Collection of Access Data and Log Files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). Server log files can include the address and name of the retrieved webpages and files, the date and time of access, transferred data volumes, notification of successful retrieval, browser type along with 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 can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Deletion of Data: Logfile information is stored for a maximum of 30 days and then deleted or anonymized. Data required for further storage for evidence purposes are excluded from deletion until the final clarification of the respective incident. WordPress.com: Hosting platform for blogs/websites; Service provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data Processing Agreement: concluded with provider: https://wordpress.com/support/data-processing-agreements/.
Web Analytics, Monitoring, and Optimization
Web analytics, also known as “reach measurement,” evaluates the visitor traffic of our online offerings. It can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With reach analysis, for instance, we can identify the most popular times for using our online offerings or their functions or content, or invite for reuse. We can also track which areas need optimization.
In addition to web analytics, we can also use testing procedures to test and optimize different versions of our online offerings or their components.
Unless stated otherwise, profiles, i.e., data summarized for a usage process, can be created for these purposes, and information can be stored and read out in a browser or on an end device. The collected data primarily includes visited web pages and used elements, as well as technical information like the browser used, the computer system, and usage times. If users have consented to the collection of their location data by us or the providers of the services we use, location data can also be processed.
Users’ IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, clear data of users (such as email addresses or names) are not stored in the context of web analytics, A/B testing, and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the purposes of the respective procedures.
Notes on Legal Basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed based on our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Types of Data Processed: Usage data (e.g., visited websites, interest in content, access times); Meta/communication data (e.g., device information, IP addresses). Affected Persons: Users (e.g., website visitors, users of online services). Purposes of Processing: Reach measurement (e.g., access statistics, detection of returning visitors); Profiles with user-related information (creation of user profiles). Security Measures: IP masking (pseudonymization of the IP address). Legal Bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR); Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f GDPR). Further Information on Processing Processes, Procedures, and Services:
Google Analytics 4: Reach Measurement and Web Analytics – We use Google Analytics 4, a version of Google Analytics, to conduct user analysis based on a pseudonymous user identification number. This identification number does not contain clear data, such as names or email addresses. It is used to assign analysis information to a user, for example, to identify which content users have accessed during a session, or whether they revisit our online offering. Pseudonymous profiles of users are created with information from the use of various devices. The users’ IP address is by default shortened by the last two digits; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Standard Contractual Clauses (Ensuring data protection level in third countries): https://business.safety.google/adsprocessorterms; Opt-out option (Opt-Out): Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; More information: https://privacy.google.com/businesses/adsservices (Types of processing and the processed data).
Presences in Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context to communicate with users active there or to offer information about us.
We point out that in doing so, user data may be processed outside the European Union, which could pose risks for users, for example, making it difficult to enforce users’ rights.
Furthermore, user data within social networks are typically processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These usage profiles can, in turn, be used to, for example, place advertisements inside and outside the networks that presumably correspond to users’ interests. For these purposes, cookies are usually stored on the users’ computers, where the users’ behavior and interests are saved. Furthermore, data in the usage profiles can be stored independently of the devices used by users (especially if the users are members of the respective platforms and are logged in).
For a detailed presentation of the respective processing forms and the options to object (Opt-Out), we refer to the privacy statements and information provided by the operators of the respective networks.
Also, in the case of information requests and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to users’ data and can take direct measures and provide information. If you still need assistance, you can contact us.
Types of Data Processed: Contact data (e.g., email, phone numbers); Content data (e.g., entries in online forms); Usage data (e.g., visited websites, interest in content, access times); Meta/communication data (e.g., device information, IP addresses). Affected Persons: Users (e.g., website visitors, users of online services). Purposes of Processing: Contact requests and communication; Feedback (e.g., collecting feedback via online form); Marketing. Legal Bases: Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f GDPR). Further Information on Processing Processes, Procedures, and Services:
Instagram: Social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacy; Opt-out option (Opt-Out): https://adssettings.google.com/authenticated.
Plugins and Embedded Features and Content
We integrate functional and content elements into our online offering, which are sourced from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include graphics, videos, or city maps (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the users, as they could not send the content to their browsers without the IP address. The IP address is thus required for the display of these contents or functions. We endeavor to use only those contents whose respective providers use the IP address solely for the delivery of the contents. 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 include technical information about the browser and operating system, referring web pages, visit time, and other information about the use of our online offering, as well as be connected with such information from other sources.
Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Types of Data Processed: Usage data (e.g., visited websites, interest in content, access times); Meta/communication data (e.g., device information, IP addresses); Inventory data (e.g., names, addresses); Contact data (e.g., email, phone numbers); Content data (e.g., entries in online forms). Affected Persons: Users (e.g., website visitors, users of online services). Purposes of Processing: Provision of our online offering and user-friendliness; Marketing; Profiles with user-related information (creation of user profiles). Legal Bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b GDPR); Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f GDPR). Further Notes on
Processing Processes, Procedures, and Services:
Google Fonts: The procurement of fonts (“Google Fonts”) from the provider Google is for the purpose of a technically secure, maintenance-free, and efficient use of fonts with regard to currency and loading times, their uniform presentation, and consideration of potential licensing restrictions. Google is informed of the user’s IP address so that Google can provide the fonts in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, used hardware) are transmitted, which are necessary for the provision of the fonts depending on the used devices and the technical environment. ; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
Instagram Plugins and Content: This includes content such as images, videos, or texts and buttons with which users can share content from this online offering within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not the further processing) of “Event Data” that Facebook collects via Instagram functions (e.g., embedding functions for content) executed on our online offering, or receives as part of a transmission for the following purposes: a) Display of content and advertising information that presumably corresponds to the users’ interests; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of features and content (e.g., improving recognition of which content or advertising information presumably corresponds to the users’ interests). We have concluded a specific agreement with Facebook (“Controller Addendum,” https://www.facebook.com/legal/controller_addendum), which particularly regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subjects’ rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: When Facebook provides us with measurements, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous for us), this processing is not carried out as part of the joint responsibility, but based on a data processing agreement (“Data Processing Terms,” https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms), and, with regard to processing in the USA, based on standard contractual clauses (“Facebook EU Data Transfer Addendum,” https://www.facebook.com/legal/EU_data_transfer_addendum). The users’ rights (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
YouTube Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Opt-out option (Opt-Out): Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
Rights of Data Subjects
As data subjects under the GDPR, you have various rights, which are particularly derived from Articles 15 to 21 of the GDPR:
Right to object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing. Right to withdraw consent: You have the right to withdraw your consent at any time. Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements. Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you. Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data. Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common, and machine-readable format in accordance with legal requirements, or to request its transmission to another controller. Right to lodge a complaint with a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, particularly in the Member State in which you normally reside, the supervisory authority of your place of work, or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR. Competent supervisory authority for us:
Austrian Data Protection Authority Barichgasse 40-42 1030 Vienna
Phone: +43 1 52 152-0
Email: dsb@dsb.gv.at
Definitions
In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are mainly defined in Article 4 of the GDPR. The legal definitions are binding. The following explanations are intended primarily for understanding. The terms are sorted alphabetically.
Personal data: “Personal data” are all information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Profiles with user-related information: The processing of “profiles with user-related information,” or simply “profiles,” includes any type of automated processing of personal data consisting in using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). For the purposes of profiling, cookies and web beacons are often used. Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the visitor traffic of an online offering and can include the behavior or interests of visitors in certain information, such as the contents of websites. With the help of reach analysis, website owners can, for example, find out when visitors visit their website and what content they are interested in. This allows them to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering. Controller: The “controller” is the natural or legal person, authority, institution, or other body that alone or jointly with others decides on the purposes and means of processing personal data. Processing: “Processing” is any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and includes virtually any handling of data, whether it be collection, evaluation, storage, transmission, or deletion.