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Privacy policy

Your privacy is important to us. This is why we conduct all our activities in accordance with relevant legislation regarding the protection of personal data.

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as “data”) we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing 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 “online services”).

The terms used are not gender-specific.

Table of contents

Controller

Christina Roller
Siebensterngasse 43
1070 Wien

Authorised Representatives: Christina Roller

E-mail address: office@hotelkugel.at

Legal Notice: https://www.hotelkugel.at/en/impressum/

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data.
  • Employee Data.
  • Payment Data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Job applicant details.
  • Images and/ or video recordings.
  • Contact Information (Facebook).
  • Event Data (Facebook).
  • Log data.
  • Working hours data.
  • Creditworthiness Data.

Special Categories of Data

  • Health Data.
  • Religious or philosophical beliefs.
  • Trade union membership.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Prospective customers.
  • Communication partner.
  • Users.
  • Job applicants.
  • Business and contractual partners.
  • Third parties.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Web Analytics.
  • Targeting.
  • Office and organisational procedures.
  • Remarketing.
  • Conversion tracking.
  • Clicktracking.
  • Affiliate Tracking.
  • Affiliate Tracking.
  • A/B Tests.
  • Organisational and Administrative Procedures.
  • Job Application Process.
  • Feedback.
  • Heatmaps.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and usability.
  • Assessment of creditworthiness.
  • Establishment and execution of employment relationships.
  • Information technology infrastructure.
  • Financial and Payment Management.
  • Public relations.
  • Sales promotion.
  • Business processes and management procedures.

Relevant legal bases

Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) – the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.
  • Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR) – If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (2)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (2)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR.
  • Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR) – processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Austria. This includes 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 provisions on the right of access, rectification or cancellation, processing of special categories of personal data, processing for other purposes and transmission and automated decision making in individual cases.

Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data based on the Federal Act on Data Protection (referred to as “Swiss DPA”). Unlike the GDPR, for instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).

Reference to the applicability of the GDPR and the Swiss DPA: These privacy policy serves both to provide information pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms used in the GDPR are applied. In particular, instead of the terms used in the Swiss FADP such as “processing” of “personal data”, “predominant interest”, and “particularly sensitive personal data”, the terms used in the GDPR, namely “processing” of “personal data”, as well as “legitimate interest” and “special categories of data” are used. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP within its scope of application.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information that is transferred between the website or app and the user’s browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being securely and encryptedly transmitted.

Transmission of Personal Data

In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of your data.

International data transfers

Data Processing in Third Countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if the processing is done within the context of using third-party services or the disclosure or transfer of data to other individuals, entities, or companies, this is only done in accordance with legal requirements. If the data protection level in the third country has been recognized by an adequacy decision (Article 45 GDPR), this serves as the basis for data transfer. Otherwise, data transfers only occur if the data protection level is otherwise ensured, especially through standard contractual clauses (Article 46 (2)(c) GDPR), explicit consent, or in cases of contractual or legally required transfers (Article 49 (1) GDPR). Furthermore, we provide you with the basis of third-country transfers from individual third-country providers, with adequacy decisions primarily serving as the foundation. “Information regarding third-country transfers and existing adequacy decisions can be obtained from the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

EU-US Trans-Atlantic Data Privacy Framework: Within the context of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the data protection level for certain companies from the USA as secure within the adequacy decision of 10th July 2023. The list of certified companies as well as additional information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/s/. We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.

Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (Swiss DPA), we only disclose personal data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss DPA). If the Federal Council does not determine that there is an adequate level of protection (list of states: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative security measures. These measures may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or internal company data protection regulations previously recognised by the FDPIC or a competent data protection authority of another country.

Under Art. 16 of the Swiss DSG, exceptions can be made for the disclosure of data abroad if certain conditions are met, including the consent of the affected person, contract execution, public interest, protection of life or physical integrity, publicly made data or data from a legally provided register. Such disclosures always comply with the legal requirements.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory obligations or special interests require a longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or protection of the rights of other natural or legal persons, must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data specifically applicable to certain processing processes.

In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.

If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.

Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.

Further information on processing methods, procedures and services used:

  • Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:
    • 10 Years – Fiscal Code/Commercial Code – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents, booking receipts and invoices (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 1, 4 and 4a of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 Numbers 1 and 4, Paragraph 4 of the German Commercial Code (HGB)).
    • 6 Years – Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 2, 3, 5 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3, Paragraph 4 of the German Commercial Code (HGB)).
    • 3 Years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).
  • Data Retention and Deletion: The following general deadlines apply to retention and archiving according to Austrian law:
    • 10 Years – Retention period for books and records, annual financial statements, inventories, annual reports, opening balance sheets, booking receipts and invoices, as well as any necessary work instructions and other organisational documents (Austrian Federal Tax Code (BAO §132), Austrian Commercial Code (UGB §§190-212)).
    • 6 Years – Remaining business documents: Received business or trading letters, copies of sent business or trading letters, and other documents, if they are relevant for taxation. These could be hourly wage sheets, operational accounting sheets, calculation documents, price tags, and payroll documents, as long as they aren’t already booking receipts and cash register strips (Austrian Federal Tax Code (BAO §132), Austrian Commercial Code (UGB §§190-212)). .
    • 3 Years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 1478, 1480 of the Austrian Civil Code).
  • Data Retention and Deletion: The following general deadlines apply for retention and archiving according to Swiss law:
    • 10 Jahre – Aufbewahrungsfrist für Bücher und Aufzeichnungen, Jahresabschlüsse, Inventare, Lageberichte, Eröffnungsbilanzen, Buchungsbelege und Rechnungen sowie alle erforderlichen Arbeitsanweisungen und sonstigen Organisationsunterlagen (Art. 958f des Schweizerischen Obligationenrechts (OR)).
    • 10 Jahre – Daten, die zur Berücksichtigung potenzieller Schadenersatzansprüche oder ähnlicher vertraglicher Ansprüche und Rechte notwendig sind, sowie für die Bearbeitung damit verbundener Anfragen, basierend auf früheren Geschäftserfahrungen und den üblichen Branchenpraktiken, werden für den Zeitraum der gesetzlichen Verjährungsfrist von zehn Jahren gespeichert, es sei denn, eine kürzere Frist von fünf Jahren ist maßgeblich, die in bestimmten Fällen einschlägig ist (Art. 127, 130 OR). Mit Ablauf von fünf Jahren verjähren die Forderungen für Miet-, Pacht- und Kapitalzinse sowie andere periodische Leistungen, aus Lieferung von Lebensmitteln, für Beköstigung und für Wirtsschulden, sowie aus Handwerksarbeit, Kleinverkauf von Waren, ärztlicher Besorgung, Berufsarbeiten von Anwälten, Rechtsagenten, Prokuratoren und Notaren und aus dem Arbeitsverhältnis von Arbeitnehmern (Art. 128 OR).

Rights of Data Subjects

Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • 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 the legal requirements, or to request its transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the law 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, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of the data subjects under the Swiss DPA:

As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:

  • Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
  • Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers). Contract data (e.g. contract object, duration, customer category).
  • Special categories of personal data: Health Data.
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Hospitality, hotel and accommodation services: We process the data of our guests, visitors and interested parties (uniformly referred to as “guests”) in order to provide our accommodation and related services of a tourist or gastronomic nature and to invoice the services provided.

    As part of our assignment it may be necessary for us to process special categories of data within the meaning of Article 9 (1) GDPR, in particular information on the health of a person or information relating to his/her religious belief. In this case processing is carried out in order to protect the health interests of visitors (e.g. in the case of information on allergies) or otherwise to satisfy their physical or mental needs on request and with their consent.

    If necessary for the fulfillment of the contract or required by law, or agreed by guests, or it is based on our legitimate interests, we disclose or transfer the guests’ data e.g. to the service providers involved in the fulfillment of our services or from authorities, billing centers and in the area of IT, office or comparable services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Business processes and operations

Personal data of service recipients and clients – including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.

Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Log data (e.g. log files concerning logins or data retrieval or access times.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Creditworthiness Data (e.g. received credit score, estimated default probability, risk classification based on this, historical payment behaviour). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Third parties; Users (e.g. website visitors, users of online services). Employees (e.g. employees, job applicants, temporary workers, and other personnel.).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Marketing; Sales promotion; Public relations; Assessment of creditworthiness; Financial and Payment Management. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Further information on processing methods, procedures and services used:

  • Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Use of online platforms for listing and sales purposes

We offer our services on online platforms operated by other service providers. In addition to our privacy policy, the privacy policies of the respective platforms apply. This is particularly true with regard to the payment process and the methods used on the platforms for performance measuring and behaviour-related marketing.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Marketing; Business processes and management procedures. Affiliate Tracking.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Providers and services used in the course of business

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, “services”) in compliance with legal requirements. Their use is based on our interests in the proper, legal and economic management of our business operations and internal organization.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Payment Procedure

Within the framework 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 service providers for this purpose in addition to banks and credit institutions (collectively referred to as “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 carry out 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. Please refer to the terms and conditions and data protection information of the payment service providers.

The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Provision of online services and web hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).). Security measures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web hoster”); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called “server log files”. Server log files may include the address and name of the accessed web pages and files, 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 typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
  • E-mail Sending and Hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • easyname: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: easyname GmbH, Canettistraße 5/10, A-1100 Wien, Austria; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.easyname.at/en; Privacy Policy: https://www.easyname.at/download/data-protection-policy-en-v4.pdf. Basis for third-country transfers: Switzerland – Adequacy decision (Austria).

Use of Cookies

Cookies are small text files or other types of storage markers that store information on end devices and read information from them. For example, to save the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used of an online offer. Furthermore, cookies can be used for various concerns, such as 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 users, unless it is not required by law. Permission is particularly not necessary 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 them and contains information on the respective cookie usage.

Notes on the legal basis for data protection: The legal basis on which we process users’ personal data with the help of cookies depends on whether we ask them for consent. If users accept, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies are based on our legitimate interests (e.g., in a commercial operation of our online offer and its usability improvement) or, if this occurs within the fulfillment of our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are used by us in the course of this data protection declaration or within the scope of our consent and processing processes.

Storage Duration: Regarding the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a site. Similarly, user data collected via cookies can be used for reach measurement. Unless we provide users with explicit information about the nature and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and the storage duration can be up to two years.

General notes on revocation and objection (Opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing according to legal requirements, also via the privacy settings of their browser.

  • Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

  • Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users’ consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users’ devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device.If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • BorlabsCookie: Cookie Consent Management: Procedures for obtaining, recording, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, accessing, and processing information on users’ devices as well as their processing; Service provider: Executed on servers and/or computers under our controllership; Website: https://borlabs.io/borlabs-cookie/. Further Information: An individual user ID, language as well as types of consent and the time of their submission are stored on the server and in the cookie on the user’s device.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy policy.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Web Analysis, Monitoring and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called “cookies”) or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited and elements used there as well as 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 or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for data processing is consent. Otherwise, user data will be processed on the basis of 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.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Remarketing; Affiliate Tracking; Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); A/B Tests; Feedback (e.g. collecting feedback via online form); Heatmaps (“Heatmaps” are mouse movements of the users, which are combined to an overall picture.); Provision of our online services and usability; Targeting (e.g. profiling based on interests and behaviour, use of cookies); Clicktracking; Conversion tracking (Measurement of the effectiveness of marketing activities). Marketing.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Analytics: We use Google Analytics to perform measurement and analysis of the use of our online services by users based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers.
    In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses. Analytics does provide coarse geo-location data by deriving the following metadata from IP addresses: City (and the derived latitude, and longitude of the city), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU-based traffic, IP-address data is used solely for geo-location data derivation before being immediately discarded. It is not logged, accessible, or used for any additional use cases. When Analytics collects measurement data, all IP lookups are performed on EU-based servers before forwarding traffic to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security measures: IP Masking (Pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff. Further Information: https://business.safety.google/adsservices/ (Types of processing and data processed).
  • Information on recipients of consent and cookie-less analytics: Information on recipients of consent: The consent given by users in the context of a consent dialogue (also known as “Cookie Opt-In/Consent”, “Cookie Banner”, etc.) serves multiple purposes. Firstly, it helps us to fulfil our obligation to obtain consent for the storage and reading of information on and from the end-user’s device (in accordance with ePrivacy Directives). Secondly, it covers the processing of users’ personal data in accordance with data protection requirements. Additionally, this consent is also applicable to Google, as the company is required by the Digital Markets Act to obtain consent for personalised services. Therefore, we share the status of consents given by users with Google. Our consent management software informs Google about whether consents have been given or not. The aim is to ensure that user consents—or their absence—are taken into account when using Google Analytics and integrating features and external services. Thus, user consents and their revocation can be dynamically adjusted within our online offerings through Google Analytics and other Google services, depending on user selection.
    Cookieless Analysis: We utilise the advanced implementation of consent mode of Google Analytics. This means that if users do not give consent for the storage and reading of information on their end devices – particularly regarding cookies – no cookies or similar information will be stored on the user’s devices. Likewise, no user profiles will be created.In this case, Google’s code generates a random identification number on the user’s end device and transmits it to Google (known as a “ping”). There is no storage of the identification in the browser, in apps, or other devices used by the user. This identification number is unique for each website visit, so that users’ behaviour or interests cannot be tracked across devices or websites. Only a minimum amount of information about user activity is sent. This includes details about consent status and information for conversion measurement, i.e., whether a user was directed to our online service via a Google advertisement.Additionally, where available, the following information may be transmitted: a) Function-related information such as headers (technical details transmitted by the browser), b) Timestamps (date and time of access), c) User-Agent (information about the browser and device used, web only), d) Referrer URL (the URL of the page from which the user arrived), e) Aggregated/pseudonymous information: This includes an indication of whether the current or a previous page in the user’s navigation history contains information about ad clicks in its URL (e.g., GCLID/DCLID, specific tracking codes from Google), a random number generated with each page view, and details about the platform used by the website owner for consent management (e.g., developer ID); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de; Privacy Policy: https://policies.google.com/privacy. Basis for third-country transfers: Switzerland – Adequacy decision (Ireland).
  • Google Signals (Google Analytics function): Google signals are session data from sites and apps that Google associates with users who have signed in to their Google accounts, and who have turned on Ads Personalization. This association of data with these signed-in users is used to enable cross-device reporting, cross-device remarketing, and cross-device conversion export to Ads. These are the areas where more information is gathered when Google Signals is activated (but only for users with Ads Personalization enabled): Cross Platform reporting – Connection of data about devices and activities from different sessions using your User-ID or Google-signals data providing an understanding of user behavior at each step of the conversion process, from initial contact to conversion and beyond; Remarketing with Google Analytics – Creation of remarketing audiences from Google Analytics data, and sharing of those audiences with linked advertising accounts; Demographics & Interests: Google Analytics collects additional information about demographics and interests from users who are signed in to their Google accounts and who have turned on Ads Personalization; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://support.google.com/analytics/answer/7532985?hl=en; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Further Information: https://business.safety.google/adsservices/ (Types of processing and data processed).
  • Google Analytics Audiences: We use Google Analytics to specifically present ads, placed through Google’s advertising services and those of its partners, to users who have already shown interest in our online offering or exhibit certain characteristics (e.g., interests in specific topics or products determined based on the websites they have visited). We transmit this data to Google as part of what is known as “Remarketing” or “Google Analytics Audiences”. The purpose of using Remarketing Audiences is to ensure that our ads align as closely as possible with the potential interests of the users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Legal Basis: https://business.safety.google/adsprocessorterms/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Data Processing Conditions for Google Advertising Products and standard contractual clauses for data transfers to third countries: https://business.safety.google/adsprocessorterms .
  • Google Tag Manager: We use Google Tag Manager, a software provided by Google, which enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that serve to record and analyse visitor activities. This technology assists us in improving our website and the content offered on it. Google Tag Manager itself does not create user profiles, store cookies with user profiles, or perform any independent analyses. Its function is limited to simplifying and making the integration and management of tools and services we use on our website more efficient. Nevertheless, when using Google Tag Manager, users’ IP addresses are transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set in this process. However, this data processing only occurs if services are integrated via the Tag Manager. For more detailed information about these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
  • Hotjar Observe: Software for the analysis and optimization of online services based on pseudonymously performed measurements and analyses of user behavior, which may include in particular A/B tests (measurement of the popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online service (as so-called heat maps and recordings); Service provider: Hotjar Ltd., 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.hotjar.com; Privacy Policy: https://www.hotjar.com/legal/policies/privacy; Basis for third-country transfers: Switzerland – Adequacy decision (Malta); Retention period: The cookies that Hotjar uses have a different “lifetime”; some last up to 365 days, some only last during the current visit; cookie policy: https://www.hotjar.com/legal/policies/cookie-information. Opt-Out: https://www.hotjar.com/legal/compliance/opt-out.
  • Visual Website Optimizer: Visual Website Optimizer – Testing and optimization; Service provider: Wingify Software Private Limited, 404, Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://vwo.com. Privacy Policy: https://vwo.com/privacy-policy/.
  • SmartBear: Stability and error monitoring for applications; Service provider: SmartBear Software Inc., General Counsel, Legal Dept., Mayoralty House, Flood Street, Galway, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://smartbear.com/; Privacy Policy: https://smartbear.com/privacy/; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).

Online Marketing

We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedure is used by which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed.

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of 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 the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Notes on revocation and objection:

We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called “opt-out”). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://www.youradchoices.ca/choices.

c) USA: https://www.aboutads.info/choices.

d) Cross-regional: https://optout.aboutads.info.

  • Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Event Data (Facebook) (“Event Data” is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), login information, and Contact Information (such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a maximum of two years, the Custom Audiences created from them with the deletion of our Facebook account); Contact Information (Facebook) (“Contact Information” is data that (clearly) identifies data subjects, such as names, email addresses and phone numbers, that can be transmitted to Facebook, e.g. via Facebook pixels or uploads for matching purposes to form Custom Audiences. After the matching to create target groups, the Contact Information is deleted).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Affiliate Tracking; Marketing; Profiles with user-related information (Creating user profiles); Provision of our online services and usability; Remarketing. Clicktracking.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Meta Pixel and Custom Audiences (Custom Audiences): With the help of the Meta-Pixel (or equivalent functions, to transfer Event-Data or Contact Information via interfaces or other software in apps), Meta is on the one hand able to determine the visitors of our online services as a target group for the presentation of ads (so-called “Meta ads”). Accordingly, we use Meta-Pixels to display Meta ads placed by us only to Meta users and within the services of partners cooperating with Meta (so-called “audience network” https://www.facebook.com/audiencenetwork/ ) who have shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Meta (so-called “custom audiences”). With the help of Meta-Pixels, we also want to ensure that our Meta ads correspond to the potential interest of users and do not appear annoying. The Meta-Pixel also enables us to track the effectiveness of Meta ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Meta ad (known as “conversion tracking”); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Further Information: User event data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Advanced matching for the Meta-Pixel: In addition to the processing of Event Data in the context of the use of the Meta-Pixel (or equivalent functions, e.g. in apps), Contact Information (data identifying individual persons, names, email addresses and telephone numbers) is also collected by Meta within our online offer or transmitted to Meta. The processing of contact information serves to form target groups (so-called ” Custom Audiences”) for the display of content and advertising information based on the presumed interests of users. The collection, or transmission and matching with data available on Meta is not in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, in the storage of passwords). After the matching to create target groups, the Contact Information is deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR); Privacy Policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further Information: https://www.facebook.com/legal/terms/data_security_terms.
  • Meta – Custom Audiences from File: Creation of target groups for marketing purposes – We submit Contact Information (names, email addresses and phone numbers) to Meta in list form for the purpose of creating Custom Audiences for content and advertising information based on the presumed interests of users. The transmission and matching with data available on Meta is not in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, in the storage of passwords). After the matching to create target groups, the Contact Information is deleted; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
  • Facebook Ads: Placement of ads within the Facebook platform and analysis of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Opt-Out: We refer to the privacy and advertising settings in the users’ profiles on the Facebook platforms, as well as to Facebook’s consent procedures and contact options for exercising access and other data subject rights, as described in Facebook’s privacy policy. Further Information: User event data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Google Ad Manager: We use the service “Google Ad Manager” to place ads in the Google advertising network (e.g. in search results, videos, websites, etc.). The Google Ad Manager stands out because ads are displayed in real time based on users’ presumed interests. This allows us to display ads for our online offering to users who may have a potential interest in our offering or who have previously shown interest, and measure the success of the ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/; Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms. where Google acts as processor, Data Processing Conditions for Google Advertising Products and standard contractual clauses for data transfers to third countries: https://business.safety.google/adsprocessorterms apply.
  • Google Ads and Conversion Tracking: Online marketing process for purposes of placing content and advertisements within the provider’s advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
  • Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that adds users who use an online service to a pseudonymous remarketing list so that users can be shown ads on other online services based on their visit to the online service
    ; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
  • Enhanced Conversions for Google Ads: When users click on our Google ads and subsequently use the advertised service (so-called “conversion”), the data entered by the user, such as email address, name, residential address or telephone number, may be transmitted to Google. The hash values are then matched with existing Google accounts of the users to better evaluate and improve their interaction with the ads (e.g., clicks or views) and thus their performance; Legal Basis: Consent (Article 6 (1) (a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.
  • Instagram Ads: Placement of ads within the Instagram platform and analysis of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Opt-Out: We refer to the data protection and advertising settings in the user’s profile on the Instagram platform as well as Instagram’s consent procedure and Instagram’s contact options for exercising information and other data subject rights in Instagram’s privacy policy. Further Information: User event data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Microsoft Advertising: Online marketing process for purposes of placing content and advertisements within the provider’s advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://about.ads.microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/en-us/privacystatement; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Opt-Out: https://account.microsoft.com/privacy/ad-settings/. Further Information: https://help.ads.microsoft.com/#apex/ads/en/ext60212.
  • UTM Parameter: Analysis of sources and user actions based on an extension of web addresses referring to us with an additional parameter, the “UTM” parameter. For example, a UTM parameter “utm_source=platformX &utm_medium=video” can tell us that a person clicked the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. posting, link, image and video). With the help of this information, we can, for example, check our visibility on the Internet or the effectiveness of our campaigns; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Customer Reviews and Ratings

We participate in review and rating procedures to evaluate, optimise and advertise our performance. If users rate us via the participating rating platforms or methods or otherwise provide feedback, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective provider.

In order to ensure that the evaluators have actually made use of our services, we transmit, with the consent of the customer, the necessary data relating to the customer and the service or products used to the respective rating platform (this includes the name, e-mail address, order number or article number). This data is used solely to verify the authenticity of the user.

  • Processed data types: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history). Contact data (e.g. postal and email addresses or phone numbers).
  • Data subjects: Service recipients and clients; Users (e.g. website visitors, users of online services); Prospective customers. Business and contractual partners.
  • Purposes of processing: Feedback (e.g. collecting feedback via online form); Marketing; Affiliate Tracking; Provision of contractual services and fulfillment of contractual obligations; Conversion tracking (Measurement of the effectiveness of marketing activities). Provision of our online services and usability.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Customer Reviews: Service for obtaining and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: In the context of obtaining customer reviews, an identification number and time for the business transaction to be evaluated, in the case of review requests sent directly to customers, the customer’s e-mail address and its country of residence information as well as the review information itself are processed; Further information on types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
  • Booking.com Affiliate Program: Affiliate marketing partner program; Service provider: Booking.com B.V., Herengracht 597, 1017 CE Amsterdam, Netherlands; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.booking.com; Privacy Policy: https://www.booking.com/content/privacy.html. Basis for third-country transfers: Switzerland – Adequacy decision (Netherlands).
  • TripAdvisor: ————— BITTE ÜBERSETZEN —————; Service provider: Tripadvisor LLC, 400 1st Avenue, Needham, MA 02494 USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.tripadvisor.com/. Privacy Policy: https://tripadvisor.mediaroom.com/us-privacy-policy.

Profiles in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the 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 entail risks for users, e.g. by making it more difficult to enforce users’ rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Instagram: Social network, allows the sharing of photos and videos, commenting on and favouriting posts, messaging, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
  • Facebook Pages: Profiles within the social network Facebook – We are jointly responsible (so called “joint controller”) with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see “Things that you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How we use this information?” Facebook also collects and uses information to provide analytics services, known as “page insights,” to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook (“Information about Page-Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
  • Pinterest: Social network, allows for the sharing of photos, commenting, favouriting and curating of posts, messaging, subscribing to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.pinterest.com; Privacy Policy: https://policy.pinterest.com/en/privacy-policy. Basis for third-country transfers: Switzerland – Adequacy decision (Ireland).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Opt-Out: https://myadcenter.google.com/personalizationoff.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. 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 technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Fonts (Provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online services; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Google Maps APIs and SDKs: Interfaces to the map and location services provided by Google, which, for example, allow the addition of address entries, location determinations, distance calculations or the provision of supplementary information on locations and other places; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).

Management, Organization and Utilities

We use services, platforms and software from other providers (hereinafter referred to as ” third-party providers”) for the purposes of organizing, administering, planning and providing our services. When selecting third-party providers and their services, we comply with the legal requirements.

Within this context, personal data may be processed and stored on the servers of third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on processes, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.

  • Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organisational procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Processing of data in the context of employment relationships

In the context of employment relationships, the processing of personal data aims to effectively manage the establishment, execution, and termination of such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.

The data processing covers various aspects ranging from contract initiation to termination. Included are the organization and management of daily working hours, management of access rights and permissions, as well as handling personnel development measures and staff appraisals. The processing also serves payroll accounting and management of wage and salary payments, which represent critical aspects of contract execution.

Additionally, the data processing considers legitimate interests of the responsible employer, such as ensuring workplace safety or capturing performance data for evaluating and optimizing operational processes. Moreover, the data processing includes disclosing employee data in external communication and publication processes where necessary for operational or legal purposes.

The processing of this data always takes place with due regard for the applicable legal frameworks, aiming always to create and maintain a fair and efficient working environment. This also includes considering the privacy of affected employees, anonymizing or deleting data after fulfilling the processing purpose or according to legal retention periods.

  • Processed data types: Employee Data (Information about employees and other individuals in an employment relationship); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Working hours data (e.g. start of work time, end of work time, actual working hours, target working hours, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Images and/ or video recordings (e.g. photographs or video recordings of a person); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Log data (e.g. log files concerning logins or data retrieval or access times.).
  • Special categories of personal data: Health Data; Religious or philosophical beliefs. Trade union membership.
  • Data subjects: Employees (e.g. employees, job applicants, temporary workers, and other personnel.).
  • Purposes of processing: Establishment and execution of employment relationships (Processing of employee data in the context of the establishment and execution of employment relationships); Business processes and management procedures; Provision of contractual services and fulfillment of contractual obligations; Public relations; Security measures. Office and organisational procedures.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR); Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR). Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

  • Time Recording: Processes for recording employees’ working hours include both manual and automated methods, such as the use of punch clocks, time tracking software, or mobile apps. Activities involved include entering clock-in and clock-out times, break times, overtime, and absences. To verify and validate the recorded working hours, they are compared with deployment or shift schedules, checked for absences, and approved for overtime by supervisors. Reports and analyses are generated based on the recorded working hours to provide work time records, overtime reports, and absence statistics for management and the human resources department; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Authorization Management: Procedures required for the definition, management, and control of access rights and user roles within a system or an organisation (e.g., creation of authorisation profiles, role- and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Special categories of personal data: Special categories of personal data are processed in the context of employment relationships or to fulfil legal obligations. The processed special categories of personal data include information concerning the health, trade union membership, or religious affiliation of employees. This data may be transferred to health insurance companies or processed for assessing the employees’ work capacity, for corporate health management, or for declarations to the tax authorities; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Sources of Processed Data: Personal data received during the application process and/or employment relationship will be processed. Furthermore, where required by law, personal data will be collected from other sources. These may include financial authorities for tax-related information, the respective health insurance company for information on work incapacity, third parties such as employment agencies, or publicly accessible sources like professional social networks in the context of application procedures; Legal Basis: Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Purposes of Data Processing: The personal data of employees are primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, the processing of this data is necessary to fulfil legal obligations in the field of tax and social security law. In addition to these primary purposes, the data of employees are also used to meet regulatory and supervisory requirements, to optimise processes of electronic data processing, and to compile company-internal or cross-company data, possibly including statistical data. Moreover, the data of employees may be processed for the assertion of legal claims and defense in legal disputes; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Transmission of Employee Data: The data of employees is processed internally only by those departments that require it to fulfil operational, contractual, and legal obligations. The transfer of data to external recipients only occurs if it is legally required, or if the affected employees have given their consent. Possible scenarios for this can include requests for information from authorities or in the case of asset formation benefits. Furthermore, the controller may transfer personal data to further recipients as far as this is necessary for fulfilling his contractual and legal obligations as an employer. These recipients can include: a) banks b) health insurance companies, pension insurance institutions, providers of old-age provisions and other social insurance carriers c) authorities, courts (e.g., tax authorities, labour courts, further supervisory authorities within the framework of fulfilling reporting and information obligations) d) tax and legal advisors e) third-party debtors in the case of wage and salary garnishments f) other entities to which legally obligatory declarations must be made.
    In addition, data can be transferred to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples include details in the sender area of emails or letterheads as well as creating profiles on external platforms; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Payroll and wage accounting: Procedures required for calculating, disbursing, and documenting wages, salaries, and other remuneration for employees (e.g., recording of working hours, calculation of deductions and surcharges, remittance of taxes and social security contributions, preparation of payroll statements, management of wage accounts, reporting to the tax authorities and social security institutions); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR).
  • Deletion of Employee Data: Employee data are deleted under Austrian law when they are no longer necessary for the purpose for which they were collected, unless they must be retained or archived due to legal obligations or the employer’s interests. The following retention and archiving obligations are observed:
    1. Data regarding payroll tax and levy obligations under § 132 Abs 1 Federal Tax Code (BAO) – 7 years. The period begins at the end of the calendar year relevant to the data.
    2. Limitation of the obligation to pay social security contributions under § 68 Social Security Code (ASVG) – 3 or 5 years. The period generally begins on the day the contributions are due, or from the day of reporting if no report was filed.
    3. Retention periods in social insurance – 7 years under the Commercial Code (UGB).
    4. Entitlement to holiday under § 4 Abs 5 Holiday Act (UrlG) – 2 years from the end of the holiday year in which the holiday entitlement arose. The period starts 2 years after the end of the holiday year.
    5. Claims for holiday compensation under § 1486 Z 5 General Civil Code (ABGB) – 3 years. The period begins from the date the final claims are due, i.e., the last working day.
    6. Records and reports on workplace accidents under § 16 Worker Protection Act (ASchG) – at least 5 years. The period begins from the day of the workplace accident.
    7. Records on the provision of temporary workers under § 13 Abs 3 Act on Temporary Agency Work (AÜG) – 5 years. The period begins on the day the last wage claim of the temporary worker is due.
    8. Register of minors under § 26 Abs 2 Youth Employment Act (KJBG) – 2 years. The period begins two years after the last entry in the new register.
    9. Claims for compensation due to discriminatory termination of employment under §§ 15 Abs 1a and 29 Abs 1a Equal Treatment Act (GlBG) and § 7k Abs 1 in conjunction with Abs 2 Z 3 Employment of Disabled Persons Act (BEinstG) – 6 months. The period begins from the date of receipt of the termination.
    10. Claims of the employer or employee from a premature termination of the employment relationship under § 34 Employees Act (AngG) or § 1162d General Civil Code (ABGB) – 6 months. The period begins from the date the claims are due, typically from the day the termination notice is received.
    11. Entitlement to an employment reference under § 1478 General Civil Code (ABGB) – 30 years. The period begins at the termination of the employment relationship.
    12. Claims for compensation due to discriminatory rejection of an application under §§ 15 Abs 1 and 29 Abs 1 Equal Treatment Act (GlBG) and § 7k Abs 1 in conjunction with Abs 2 Z 1 Employment of Disabled Persons Act (BEinstG) – 6 months. The period begins from the day the rejection is received, or 7 months from the receipt of the application.
    13. Claims for reimbursement of interview expenses under § 1486 Z 5 General Civil Code (ABGB) – 3 years. The period begins on the day the expenses were incurred.
    14. Liability for severance claims and company pensions after a business transfer under § 6 Abs 2 Company Pension Act (AVRAG) – 5 years. The period begins at the time of the business transfer.
    15. Claims for compensation due to discriminatory rejection of a promotion under §§ 15 Abs 1 and 29 Abs 1 Equal Treatment Act (GlBG) and § 7k Abs 1 in conjunction with Abs 2 Z 1 Employment of Disabled Persons Act (BEinstG) – 6 months. The period begins from the day the promotion rejection is received.
    16. Claims for compensation due to discriminatory treatment in remuneration, voluntary social benefits, training and further education measures or other working conditions under §§ 15 Abs 1 and 29 Abs 1 Equal Treatment Act (GlBG) and § 7k Abs 1 in conjunction with Abs 2 Z 5 Employment of Disabled Persons Act (BEinstG) – 3 years. The period begins at the point the right could first have been exercised and the objective possibility to sue was given.
    17. Claims for compensation due to discriminatory harassment under §§ 15 Abs 1 and 29 Abs 1 Equal Treatment Act (GlBG) and § 7k Abs 1 in conjunction with Abs 2 Z 4 Employment of Disabled Persons Act (BEinstG) – 1 year. The period begins from the time the discrimination was recognized.
    18. Claims for compensation due to discriminatory rejection of an application under §§ 15 Abs 1 and 29 Abs 1 Equal Treatment Act (GlBG) and § 7k Abs 1 in conjunction with Abs 2 Z 1 Employment of Disabled Persons Act (BEinstG) – 6 months. The period begins from the day the rejection is received, or 7 months from the receipt of the application.
    19. Claims for compensation due to sexual harassment under § 15 Abs 1 Equal Treatment Act (GlBG) – 3 years. The period begins from the time the discrimination was recognized.
    20. Claims for reimbursement of interview expenses under § 1486 Z 5 General Civil Code (ABGB) – 3 years. The period begins on the day the expenses were incurred.
    21. Claims of the employee for wages or reimbursement of expenses as well as of the employer for advances made on these under § 1486 Z 5 General Civil Code (ABGB) – 3 years. The period begins upon the due date of the respective claims.
    22. Limitation of prosecution for underpayment under § 31 Abs 1 Administrative Penal Act (VStG) in conjunction with § 29 Abs 4 Wage and Social Dumping Prevention Act (LSD-BG) – 3 years. The period begins upon the due date of the wages.
    23. Damage claims of the employer against the employee from employee liability for slight negligence under § 6 Employee Liability Act (DHG) – 6 months. The period begins from the day they can be asserted.
    24. Damage claims of the employer against the employee from employee liability for gross negligence or intentional misconduct and other damage claims of the employer under § 1489 General Civil Code (ABGB) – 3 years or 30 years. The period begins with the shorter term from knowledge of damage and perpetrator, and with the longer term from the occurrence of damage.

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  • Obligation to Provide Data: The person in charge informs the employees that the provision of their data is required. This is generally the case when the data are necessary for the establishment and execution of the employment relationship, or when their collection is mandated by law. The provision of data may also be required when employees assert claims or are entitled to claims. The implementation of these measures or fulfilment of services depends on the provision of such data (for example, providing data for the receipt of wages); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Publication and Disclosure of Employee Data: The data of employees will only be published or disclosed to third parties if it is necessary for the performance of work tasks according to the employment contract. This applies, for example, when employees are named as contact persons in correspondences, on the website, or in public registers following an agreement or specified job description, or if their field of work includes representative functions. Similarly, this may occur if representation or communication with the public takes place as part of performing these tasks, such as image recordings during public relations activities. Otherwise, employee data is published only with their consent or based on the legitimate interests of the employer, for example, in the case of stage or group photographs taken during a public event; Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Job Application Process

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information contained therein.

In principle, the required information includes personal information such as name, address, a contact option and proof of the qualifications required for a particular employment. Upon request, we will be happy to provide you with additional information.

Where available, applicants are welcome to submit their applications via our online form, which is securely encrypted to the latest standards. Alternatively, applications can also be sent to us by email. However, we kindly remind you that emails are not inherently encrypted over the Internet. While emails are usually encrypted in transit, they are not encrypted on the servers from which they are sent and received. Therefore, we cannot assume responsibility for the security of the application during its transmission from the sender to our server.

Processing of special categories of data: To the extent that special categories of personal data (Article 9(1) GDPR, e.g., health data, such as disability status or ethnic origin) are requested from applicants or communicated by them during the application process, their processing is carried out so that the controller or the data subject can exercise rights arising from employment law and the law of social security and social protection, in the case of protection of vital interests of the applicants or other persons, or for purposes of preventive or occupational medicine, for the assessment of the employee’s work ability, for medical diagnosis, for the provision or treatment in the health or social sector, or for the management of systems and services in the health or social sector.

Ereasure of data: In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, to which applicants are entitled at any time. Subject to a justified revocation by the applicant, the deletion will take place at the latest 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 duty of proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Admission to a talent pool – Admission to a talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
  • Data subjects: Job applicants.
  • Purposes of processing: Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR).

Changes and Updates

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Supervisory authority competent for us:

Österreichische Datenschutzbehörde
Barichgasse 40-42,
1030 Wien

Terminology and Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

  • A/B Tests: A/B tests are designed to improve the usability and performance of online services. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the contents or labels of the navigation elements can differ. The behaviour of users, e.g. prolonged visits to the site or more frequent interaction with the elements, can then be used to determine which of these sites or elements are more responsive to users’ needs.
  • Affiliate Tracking: Affiliate tracking logs links that the linking websites use to refer users to websites with products or other offers. The owners of the respective linked websites can receive a commission if users follow these so-called “affiliate links” and subsequently take advantage of the offers (e.g. buy goods or use services). To this end, it is necessary for providers to be able to track whether users who are interested in certain offers subsequently follow the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are otherwise stored, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identification of the owner of the website on which the affiliate link was located, an online identification of the respective offer, an online identifier of the user, as well as tracking specific values such as advertising media ID, partner ID and categorizations
  • Clicktracking: Clicktracking allows users to keep track of their movements within an entire website. Since the results of these tests are more accurate if the interaction of the users can be followed over a certain period of time (e.g. if a user likes to return), cookies are usually stored on the computers of the users for these test purposes.
  • Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.
  • Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.
  • Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
  • Employees: As employees, individuals are those who are engaged in an employment relationship, whether as staff, employees, or in similar positions. Employment refers to a legal relationship between an employer and an employee, established through an employment contract or agreement. It entails the obligation of the employer to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various stages, including establishment, where the employment contract is concluded, execution, where the employee carries out their work activities, and termination, when the employment relationship ends, whether through termination, mutual agreement, or otherwise. Employee data encompasses all information pertaining to these individuals within the context of their employment. This includes aspects such as personal identification details, identification numbers, salary and banking information, working hours, holiday entitlements, health data, and performance assessments.
  • Heatmaps: “Heatmaps” are mouse movements of the users, which are combined to an overall picture, with the help of which it can be recognized, for example, which web page elements are preferred and which web page elements users prefer less.
  • Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.
  • Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.
  • Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.
  • Payment Data: Payment data comprise all information necessary for processing payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.
  • Personal Data: “personal data” means any information relating to an identified or identifiable natural person (“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: The term “processing” covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Remarketing: Remarketing” or “retargeting” is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Targeting: “Tracking” is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
  • Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.