T: +43 1 479 95 27
F: +43 1 479 95 27 — 10
Types of data processed
- Inventory data (e.g., personal master data, names or addresses)
- Contact details (e.g., e‑mail, phone numbers)
- Content data (e.g., text input, photographs, videos)
- Usage data (e.g., websites visited, interest in content, access times)
- Meta/communication data (e.g., device information, IP addresses)
Categories of affected persons
Visitors and users of the online offer (in the following we also refer to the data subjects as “users”).
Purpose of processing
- Providing the online offer, its functions and contents
- Responding to contact requests and communicating with users
- Range measurement/marketing
In addition, we process
- Contract data (e.g., subject matter of the contract, term, customer category)
- Payment details (e..B„ bank details, payment history)
- Employee health data (social insurance)
From our customers, interested parties and business partners for the provision of contractual services, service and customer care, marketing, advertising and market research as well as the employees regarding payroll and social security, whereby their sensitive data is only encrypted and transmitted securely.
“Personal Data” means any information relating to an identified or identifiable natural person (‘the data subject’); Identifiable is a natural person who can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more specific characteristics that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
“Processing” means any operation or series of operations carried out with or without the help of automated procedures in connection with personal data. The term goes far and covers virtually every use of data.
‘pseudonymisation’ means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.
‘profiling’ means any form of automated processing of personal data, which consists in the use of such personal data to assess certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to work performance, economic situation, health, personal preferences, interests, reliability, behaviour, whereabouts or relocation of that natural person.
‘Responsible person’ means the natural or legal person, authority, body or other body which decides, alone or jointly with others, on the purposes and means of the processing of personal data.
‘processor’ means a natural or legal person, authority, body or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Article 13 GDPR, we shall inform you of the legal bases of our data processing operations. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, unless the legal basis is specified in the Data Protection Declaration, the following applies:
The legal basis for obtaining consent sits is Article 6(3). 1 lit. a and Article 7 GDPR;
The legal basis for processing for the performance of our services and the implementation of contractual measures as well as answering inquiries is Art. 1 lit. b GDPR;
The legal basis for processing in order to fulfil our legal obligations is Art. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6℗ of the data is used. 1 lit. d GDPR as the legal basis.
The legal basis for the processing necessary to carry out a task which is in the public interest or in the exercise of official authority delegated to the controller is Article 6(3). 1 lit. e GDPR.
The legal basis for processing in order to safeguard our legitimate interests is Art. 1 lit. f GDPR.
The processing of data for purposes other than those for which it was intended is determined in accordance with the requirements of Article 6(p. 4 GDPR.
The processing of special categories of data (in accordance with Article 9(1) GDPR) is determined in accordance with the requirements of Article 9(1) of the GDPR. 2 GDPR.
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, the scope, the circumstances and the purposes of the processing, as well as the different probability and severity of the risk to the rights and freedoms of natural persons.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, disclosure, security of availability and separation. In addition, we have established procedures that ensure the exercise of data subjects’ rights, deletion of data and response to compromise of the data. Furthermore, we take into account the protection of personal data already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technical design and through data protection-friendly presets.
Cooperation with processors, joint managers and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transmit them to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if the transfer of the data to third parties, as to payment service providers, is required for the fulfilment of the contract), users have consented to this, or on the basis of our legitimate interests (e.g. , web hosts, etc.).
If we disclose, transmit or otherwise grant access to other companies in our group of companies, this is done, in particular for administrative purposes, as a legitimate interest and in addition on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if we process it in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this will only be done if it is done in order to fulfil our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual authorisations, we process or leave the data in a third country only if the legal requirements are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of an EU-compliant level of data protection (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations.
Rights of data subjects
You have the right to request confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copy of the data in accordance with the legal requirements.
They have accordingly. the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
In accordance with the statutory requirements, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with the statutory requirements.
You have the right to request that the data concerning you, which you have provided to us, be received in accordance with the statutory requirements and request their transmission to other controllers.
They also have the right to lodge a complaint with the competent supervisory authority in accordance with the legal requirements.
You have the right to revoke consents given with effect for the future.
Right to object
You can object at any time to the future processing of the data concerning you in accordance with the statutory requirements. The opposition may be made in particular against the processing for direct marketing purposes.
Cookies and right of objection in the case of direct marketing
“Cookies” means small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes their browser. In such a cookie, for example, the contents of a shopping cart can be stored in an online shop or a login status. Cookies are called “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved if the users visit them after several days. Similarly, such a cookie may store the interests of users who are used for range measurement or marketing purposes. “Third-party cookie” means cookies that are offered by providers other than the person responsible for the online offer (otherwise, if it is only its cookies, it is called “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the scope of our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional limitations of this online offer.
Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with the legal requirements. Unless expressly stated in the context of this data protection declaration, the data stored by us will be deleted as soon as they are no longer necessary for their purpose and the deletion is not precluded by legal retention obligations.
Unless the data is deleted because it is necessary for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractors”) in accordance with Art. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed here, the nature, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.
The data processed includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e‑mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
In principle, we do not process special categories of personal data, unless these are components of commissioned or contractual processing or employee data due to legal obligations.
We process data that is necessary for the establishment and performance of the contractual services and point out the necessity of their disclosure, unless this is evident for the contractual partners. Disclosure to external persons or companies is only made if it is required under a contract. When processing the data provided to us in the context of an order, we act in accordance with the instructions of the clients as well as the legal requirements.
As part of the use of our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of the users in the protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is in accordance with the prosecution of our claims. Art. 6 Abs. 1 lit. GDPR or there is a legal obligation to do so in accordance with the Art. 6 Abs. 1 lit. c. GDPR.
The data shall be deleted if the data are no longer necessary for the fulfilment of contractual or statutory duties of care and for the handling of any warranty and similar obligations, whereby the need for the retention of the data is checked every three years; the statutory retention obligations shall apply.
Administration, Financial Accounting, Office Organization, Contact Management
We process data in the context of administrative tasks as well as the organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the context of the provision of our contractual services. The basis for processing is Art. 1 lit. c. GDPR, Art. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and the provision of our services. The erasure of the data with regard to contractual services and contractual communication corresponds to the information referred to in these processing activities.
We disclose or transmit data to the tax administration, consultants, such as tax advisors or auditors, as well as other fee agencies and payment service providers.
Furthermore, on the basis of our business interests, we store information about suppliers, organizers and other business partners, e.g. for the purpose of contacting us later. We store this majority company-related data permanently.
Data protection notices in the application process
We process the applicant data only for the purpose and within the framework of the application process in accordance with the legal requirements. The processing of the applicant’s data is carried out in order to fulfil our (pre)contractual obligations within the framework of the application procedure within the meaning of Art. 1 lit. b. GDPR Art. 1 lit. f. GDPR if data processing becomes necessary for us, e.g. in the context of legal proceedings (in Germany, in addition, Section 26 bdSG applies).
The application process requires applicants to provide us with the applicant data. The necessary applicant data are marked, if we offer an online form, otherwise result from the job descriptions and in principle this includes the information about the person, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and certificates. In addition, applicants may voluntarily provide us with additional information.
By submitting the application to us, the candidates agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set out in this data protection declaration.
Insofar as, in the context of the application process, special categories of personal data within the meaning of Article 9(9) of the Application Process are voluntary. 1 GDPR, their processing shall be additionally carried out in accordance with Article 9(9) of the 2 lit. b GDPR (e.g. health data, such as severely disabled or ethnic origin). Insofar as special categories of personal data within the meaning of Article 9(9) of the application procedure are 1 GDPR is requested from applicants, their processing is additionally carried out in accordance with Article 9(9) of the 2 lit. a GDPR (e.g. health data, if it is necessary for the practice of the profession).
If provided, applicants can submit their applications to us using an online form on our website. The data will be transmitted to us in encrypted form according to the state of the art. Furthermore, applicants can send us their applications via e‑mail. However, we kindly ask you to note that e‑mails are not sent encrypted and that applicants themselves have to provide encryption. We therefore cannot assume any responsibility for the transmission of the application between the sender and the receipt on our server and therefore recommend to use an online form or the postal mail. Instead of applying via the online form and e‑mail, applicants still have the opportunity to send us the application by post.
The data provided by the applicants can be further processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the data of the applicants will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which candidates are entitled to do at any time.
Subject to a justified revocation of the candidates, the deletion takes place after the expiry of a period of six months, so that we can answer any follow-up questions regarding the application and comply with our obligations to prove this under the Equal Treatment Act. Invoices for possible travel expenses are archived in accordance with the tax regulations.
Retrieving profile images from Gravatar
We use the Gravatar service of Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and in particular in the blog.
Gravatar is a service where users can log in and store profile pictures and their email addresses. If users with the respective e‑mail address leave posts or comments on other online presences (especially in blogs), their profile pictures can be displayed next to the posts or comments. For this purpose, the e‑mail address provided by the users is transmitted encrypted to Gravatar in order to check whether a profile is stored for it. This is the sole purpose of transmitting the e‑mail address and it is not used for other purposes, but is subsequently deleted.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 1 lit. f) GDPR, as with the help of Gravatar we offer the post and comment writers the opportunity to personalize your posts with a profile picture.
If users do not want a user image associated with your email address with Gravatar to appear in the comments, you should use an email address for commenting, which is not stored with Gravatar. We would also like to point out that it is also possible to use an anonymous or no e‑mail address if the users do not want their own e‑mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system.
When contacting us (e.g. via contact form, e‑mail, telephone or via social media), the user’s details for processing the contact request and its processing in accordance with Art. 6 sec. 1 lit. b. (within the framework of contractual/pre-contractual relations), Art. 6 sec. 1 lit. f. (other enquiries) GDPR will be processed. Users’ information can be stored in a customer relationship management system (“CRM system”) or similar request organization.
We will delete the requests if they are no longer required. We review the necessity every two years; In addition, the statutory archiving obligations apply.
With the following information we inform you about the contents of our newsletter as well as the registration, shipping and statistical evaluation procedure as well as your rights of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send newsletters, e‑mails and other electronic notifications with advertising information (hereinafter “Newsletter”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our products and accompanying information (e.g. safety instructions), offers, promotions and our company.
Double opt-in and logging:
The registration for our newsletter takes place in a so-called double opt-in procedure. I.e. You will receive an e‑mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign e‑mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation time, as well as the IP address. The changes to your data stored by the shipping service provider will also be logged.
Registration details: To register for the newsletter, it is sufficient to provide your e‑mail address. Optionally, we ask you to include a name in the newsletter for personal address.
The sending of the newsletter and the success measurement associated with it are based on the consent of the recipients in accordance with the Art. 6 Abs. 1 lit. a, Art. 7 GDPR i.V.m. Section 107 para. 2 TKG or if consent is not required, based on our legitimate interests in direct marketing in accordance with Art. 6 Abs. 1 according to GDPR i.V.m. Section 107 para. 2 & 3 TKG.
The registration procedure is logged on the basis of our legitimate interests in accordance with the Art. 6 Abs. 1 lit. f GDPR. Our interest is focused on the use of a user-friendly and secure newsletter system that serves our business interests as well as meets the expectations of our users and also allows us to prove consent.
Cancellation/revocation — You can cancel the receipt of our newsletter at any time, i.e. revokeyourd your consents. A link to cancel the newsletter can be found at the end of each newsletter. We may store the e‑mail addresses that have been sent out for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense of claims. An individual request for cancellation is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Hosting and e‑mailing
The hosting services we use are intended to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e‑mail, security and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer. Art. 6 Abs. 1 lit. f GDPR in the i.V.m. Art. 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 1 lit. f. GDPR data about each access to the server on which this service is located (so-called server logfiles). The access data includes the name of the retrieved website, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security reasons (e.g. to investigate abuse or fraud) for a maximum period of 7 days and then deleted. Data, the further retention of which is necessary for the purpose of proof, is excluded from deletion until the relevant incident is finally clarified.
Jetpack (WordPress Stats)
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 sec. 1 lit. f. GDPR), we use the plugin Jetpack (here the subfunction “Wordpress Stats”), which includes a tool for statistical evaluation of visitor access and from Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses so-called “cookies”, text files that are stored on your computer and which enable an analysis of your use of the website.
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 sec. 1 lit. f. GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).
We use the online marketing method Google “Doubleclick” to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.). Double Click is characterized by the fact that ads are displayed in real time based on the presumed interests of the users. This allows us to display ads for and within our online offering in a more targeted way, in order to present users only with ads that potentially correspond to their interests. If, for example, a user is shown advertisements for products for which he has been interested in other online offers, this is called “remarketing”. For these purposes, when we and other websites on which the Google advertising network is active, a code from Google is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With the help of these, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). This file records which websites the user visited, which content he is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visit time as well as further information on the use of the online offer.
The IP address of the users is also recorded, which is truncated within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is transferred completely to a Google server in the USA and shortened there. The above information may also be linked by Google to such information from other sources. If the user subsequently visits other websites, he or she may be shown ads tailored to him or her according to his/her presumed interests on the basis of his user profile.
The data of the users are processed pseudonymously within the framework of the Google advertising network. This means that Google, for example, does not store and process the user’s name or e‑mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specific identified person, but for the cookie owner, regardless of who that cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the UNITED States.
Online social media presences
We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them about our services there.
We would like to point out that users’ data can be processed outside the European Union. This can create risks for users, as this could, for example, make it more difficult to enforce users’ rights. With regard to US providers certified under the Privacy Shield, we would like to point out that they are committed to complying with EU data protection standards.
Furthermore, users’ data are usually processed for market research and advertising purposes. For example, user profiles can be created from the usage behaviour and the resulting interests of the users. The user profiles can in turn be used to display advertisements inside and outside the platforms, for example, which presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the user’s usage behaviour and the interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of the personal data of the users takes place on the basis of our legitimate interests in effective information of the users and communication with the users in accordance with Art. 6 sec. 1 lit. f. GDPR. If the users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 sec. 1 lit. a., Art. 7 GDPR.
For a detailed presentation of the respective processing operations and the opt-out, we refer to the following linked information of the providers.
Even in the case of requests for information and the assertion of user rights, we would like to point out that these can be asserted most effectively by the providers. Only the providers have access to the data of the users and can take direct action and provide information. If you still need help, you can contact us.
Integration of third-party services and content
Within our online offer, we use third-party content or service offerings based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 sec. 1 lit. f. GDPR) content or service offerings from third parties in order to integrate their contents and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third parties to this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those content whose respective providers use the IP address only for the delivery of the content. Third parties 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, among other things, technical information about the browser and operating system, referring websites, visiting time and other information on the use of our online offer, as well as being linked to such information from other sources.
Using Facebook Social Plugins
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 sec. 1 lit. f. GDPR) we use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thereby provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a feature of this online offer that contains such a plugin, his device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated by the user into the online offer. User profiles of the users can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore informs the users according to our state of knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example by pressing the Like button or making a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and store his IP address. According to Facebook, only an anonymized IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his/her member data stored on Facebook, he must log out of Facebook before using our online offer and delete his cookies. Further settings and contradictions to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.