Imprint

Table of contents

• Controller
• Contact information of the Data Protection Officer
• Overview of processing operations
• Relevant legal bases
• Security Precautions
• Transmission of Personal Data
• General Information on Data Retention and Deletion
• Rights of Data Subjects
• Performing tasks in accordance with statutes or rules of procedure
• Business services
• Business processes and operations
• Provision of online services and web hosting
• Use of Cookies
• Contact and Inquiry Management
• Communication via Messenger
• Artificial Intelligence (AI)
• Video Conferences, Online Meetings, Webinars and Screen-Sharing
• Cloud Services
• Newsletter and Electronic Communications
• Web Analysis, Monitoring and Optimization
• Profiles in Social Networks (Social Media)
• Plugins and embedded functions and content
• Processing of data in the context of employment relationships
• Changes and Updates

Controller

Austrian Fashion Association
Camille Boyer
Lindengasse 27/1
1070 Vienna

Authorised Representatives: Camille Boyer

E-mail address: contact@afa.co.at

Legal Notice: https://www.austrianfashionassociation.at/en/imprint/

Contact information of the Data Protection Officer
Camille Boyer
contact@afa.co.at

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.
• Images and/ or video recordings.
• Audio recordings.
• Log data.
• Member data.
• Working hours data.

Categories of Data Subjects

• Service recipients and clients.
• Employees.
• Prospective customers.
• Communication partner.
• Users.
• Members.
• Business and contractual partners.
• Persons depicted.
• Third parties.

Purposes of Processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Direct marketing.
• Web Analytics.
• Office and organisational procedures.
• Organisational and Administrative Procedures.
• Feedback.
• Profiles with user-related information.
• Provision of our online services and usability.
• Establishment and execution of employment relationships.
• Information technology infrastructure.
• Financial and Payment Management.
• Public relations.
• Sales promotion.
• Business processes and management procedures.
• Artificial Intelligence (AI).

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.
• 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.
• Membership Agreement (Statutes) (Article 6 (1) (b) GDPR).
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.
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.
Data Transfer within the Organization: We may transfer personal data to other departments or units within our organisation or grant them access to it. If the data is shared for administrative purposes, it is based on our legitimate business and economic interests or occurs if it is necessary to fulfil our contractual obligations or if the data subjects have given their consent or a legal permission exists.

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.
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.

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).

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.
Performing tasks in accordance with statutes or rules of procedure
We process the data of our members, supporters, prospects, business partners or other persons (collectively, ” data subjects “) when we have a membership or other business relationship with them and perform our functions and are recipients of benefits and benefits. Otherwise, we process the data of data subjects on the basis of our legitimate interests, e.g. when it concerns administrative tasks or public relations.
The data processed, the type, scope and purpose and the necessity of their processing, are determined by the underlying membership or contractual relationship, from which the necessity of any data information arises (otherwise we refer to necessary data).
We delete data that is no longer required for the performance of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as it may be relevant for the purpose of conducting business and with regard to any warranty or liability obligations on the basis of our legitimate interest in their regulation. The necessity of storing the data is checked regularly; otherwise the statutory storage obligations apply.
• 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); Contract data (e.g. contract object, duration, customer category). Member data (e.g. personal data such as name, age, gender, contact details (email address, phone number), membership number, information about membership fees, participation in events, etc.).
• Data subjects: Members.
• Purposes of processing: Communication. Organisational and Administrative 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). Membership Agreement (Statutes) (Article 6 (1) (b) GDPR).
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).
• 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:
• Coaching: We process the data of our clients as well as prospects and other contractors or business partners (collectively referred to as “clients”) in order to provide them with our services. The processes carried out within the framework and for the purposes of coaching include: initiating contact and communication with clients, needs analysis to determine suitable coaching measures, planning and conducting coaching sessions, documenting coaching progress, capturing and managing client-specific information and data, scheduling and organising appointments, providing coaching materials and resources, invoicing and payment management, post-processing and follow-up of coaching sessions, quality assurance and feedback processes.
The processed data, its nature, scope, purpose, and the necessity of its processing are determined by the underlying contractual relationship with the client.
Insofar as it is necessary for fulfilling our contract, protecting vital interests or legally required, or if there is consent from the clients, we disclose or transfer the clients’ data in compliance with professional legal requirements to third parties or agents such as authorities, billing centers as well as in the field of IT, office or comparable services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
• Consulting: We process the data of our clients as well as prospects and other commissioning parties or contractual partners (collectively referred to as “clients”) in order to be able to provide our services to them. The processes that are part of and for the purposes of consulting include: contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, capturing and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials, invoicing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the nature, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship with the client.
If it is necessary for our contract performance, for the protection of vital interests or legally required, or if there is consent from the clients, we disclose or transmit client data in compliance with professional legal requirements to third parties or agents such as authorities, subcontractors or in the field of IT, office or similar services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
• Online Courses and Online Training: We process the data of participants in our online courses and training sessions (collectively referred to as “participants”) in order to be able to provide them with our course and training services. The data processed, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services utilized, as well as personal preferences and results of the participants, insofar as they are part of our service offering. Processing forms also include performance evaluation and the evaluation of our services as well as those of the course and training instructors. Additionally, depending on the equipment and structure of the respective courses or learning content, further processing operations may be implemented, such as attendance tracking for documenting participation, progress monitoring for measuring and analyzing learning progress by collecting exam and test results, and analyzing interactions on learning platforms, such as forum posts and assignment submissions; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
• Event Management: We process the data of the participants of the events, events and similar activities offered or organized by us (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and to make use of the services or actions associated with their participation.

Insofar as we process health-related data, religious, political or other special categories of data in this context, this is done within the framework of disclosure (e.g. for thematically oriented events or serves health care, security or is done with the consent of the data subjects).

The necessary information is identified as such in the context of the conclusion of the agreement, booking or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any enquiries. Insofar as we gain access to information of end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; 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).
• Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners. Third parties.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Public relations; Sales promotion. Financial and Payment Management.
• 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).
• 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).
• 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).
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.).
• 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.
• Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read it from them. Cookies can also be used for different purposes, such as ensuring the functionality, security, and convenience of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. If necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We clearly inform users about the scope of the consent and which cookies are used.
Information on legal data protection bases: Whether we process personal data using cookies depends on users’ consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as outlined in this section and in the context of the respective services and procedures.
Storage duration: The following types of cookies are distinguished based on their storage duration:
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user revisits a website. Additionally, the user data collected with cookies may be used for audience measurement. Unless we provide explicit information to users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that these are permanent and may have a storage duration of up to two years.
General information on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to the processing according to legal regulations, including through 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).

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.); Users (e.g. website visitors, users of online services). Business and contractual partners.
• 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).
• WPForms: Creation of online forms, collection of user inputs, transmission of data to the server, storage and management of the submitted information; Service provider: Executed on servers and/or computers under our controllership; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://wpforms.com/. Further Information: https://wpforms.com/introducing-new-gdpr-enhancements-for-your-wordpress-forms//.

Communication via Messenger

We use messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the messenger services, encryption, use of the metadata of the communication and your objection options.
You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online services.
In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger service providers themselves. You should always use a current version of the messenger service with activated encryption, so that the encryption of the message contents is guaranteed.
However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata).
Information on Legal basis: If we ask communication partners for permission before communicating with them via messenger services, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use messenger services in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messenger services. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.
Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via messenger services at any time. In the case of communication via messenger services, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.
Reservation of reference to other means of communication: For your security, we kindly ask for your understanding that we may not respond to enquiries via messenger for specific reasons. This applies in situations where contract details require heightened confidentiality or a response via messenger does not meet formal requirements. In such cases, we recommend using more appropriate communication channels.
• 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). 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. Direct marketing (e.g. by e-mail or postal).
• Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
• 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).
Further information on processing methods, procedures and services used:
• Instagram: Messaging via the social network Instagram; 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/.
• Slack: Team communication and collaboration, real-time messaging, file and document sharing, integration with third-party tools, video and voice calls, channels for topic-specific discussions, search function for messages and files; Service provider: Slack Technologies, Inc., 500 Howard Street, San Francisco, CA 94105, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://slack.com/; Privacy Policy: https://slack.com/legal; Data Processing Agreement: https://slack.com/intl/de-de/terms-of-service/data-processing; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://slack.com/intl/de-de/terms-of-service/data-processing). Further Information: Security measures: https://slack.com/intl/en-gb/security-practices.
• WhatsApp: A communication service that enables the sending and receiving of text messages, voice messages, images, videos, documents, as well as voice and video calls over the internet. Communication is conducted through end-to-end encryption, ensuring that content is accessible only to the involved communication partners. To provide the service, the platform processes metadata (e.g., phone numbers, timestamps, device information) and may use this data for functionality enhancement, security, and service optimisation; Service provider: WhatsApp Ireland Limited, Merrion Road 4, D04 X2K5 Dublin, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal/privacy-policy-eea. Basis for third-country transfers: Data Privacy Framework (DPF).

Artificial Intelligence (AI)

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term “AI system” as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.
Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.
When using external AI systems, we carefully select their providers (hereinafter referred to as “AI providers”). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.
To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
• 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).
• Data subjects: Users (e.g. website visitors, users of online services). Third parties.
• Purposes of processing: Artificial Intelligence (AI).
• 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:
• ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information, and make predictions (“AI”, meaning “Artificial Intelligence” shall be construed in the applicable legal sense of the term); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://openai.com/chatgpt/overview/; Privacy Policy: https://openai.com/policies/privacy-policy/. Opt-Out: https://privacy.openai.com/policies?modal=select-subject.
• DeepL: Translation of texts into various languages and provision of synonyms as well as context examples. Support with the correction and improvement of texts in different languages; Service provider: DeepL SE, Maarweg 165, 50825 Köln, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.deepl.com; Privacy Policy: https://www.deepl.com/en/privacy. Data Processing Agreement: Provided by the service provider.
Video Conferences, Online Meetings, Webinars and Screen-Sharing
We use platforms and applications of other providers (hereinafter referred to as “Conference Platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “Conference”). When using the Conference Platforms and their services, we comply with the legal requirements.
Data processed by Conference Platforms: In the course of participation in a Conference, the Data of the participants listed below are processed. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific Conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ Data may also be processed by the Conference Platforms for security purposes or service optimization. The processed Date includes personal information (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information on the content-related communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the Conference Platforms, then further data may be processed in accordance with the agreement with the respective Conference Provider.
Logging and recording: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are recorded, this will be transparently communicated to the participants in advance and they will be asked – if necessary – for their consent.
Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a Conference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, should not be passed on to unauthorized third parties.
Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users’ data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
• 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); Images and/ or video recordings (e.g. photographs or video recordings of a person); Audio recordings. Log data (e.g. log files concerning logins or data retrieval or access times.).
• Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). Persons depicted.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication. 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:
• Google Hangouts / Meet: Conference and communication software; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://hangouts.google.com/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).
• Microsoft Teams: Utilisation for conducting online events, conferences, and communication with internal and external participants. Voice transmission, direct messaging, group communication, and collaboration functions are used; name, business contact details, work profile, participation as well as content (audio/video, speech, chat, files, speech transcription) are processed for purposes and interests in efficiency and productivity improvements, cost efficiency, flexibility, mobility, enhanced communication, IT security, use of a central platform as well as business operations by Microsoft. Audio signals are generally not stored unless recording is enabled. Meeting and conference recordings are stored by default for 90 days unless a different duration is specified. Chat and file contents are stored according to the policies determined by the administrator or user; there is no preset automatic deletion. Channels must be renewed every 180 days; otherwise contents are deleted. Additionally processed are system-generated logs, diagnostic and metadata as well as diagnostic data collected for product stability, security and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.microsoft.com/microsoft-teams/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Slack: Messenger and conference software; Service provider: Slack Technologies Limited, Level 1, Block A Nova Atria North, Sandyford Business District, Dublin 18, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://slack.com/; Privacy Policy: https://slack.com/intl/en-de/legal; Data Processing Agreement: https://slack.com/intl/de-de/terms-of-service/data-processing. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://slack.com/intl/de-de/terms-of-service/data-processing).
• TeamViewer: Conference and communication software; Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.teamviewer.com/en/. Privacy Policy: https://www.teamviewer.com/en/privacy-notice/.
• Zoom: Video conferences, online meetings, webinars, screen sharing, optional recording of sessions, chat function, integration with calendars and other apps; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://zoom.us; Privacy Policy: https://explore.zoom.us/en/privacy/; Data Processing Agreement: https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf).
Cloud Services
We use Internet-accessible software services (so-called “cloud services”, also referred to as “Software as a Service”) provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).
Within this framework, personal data may be processed and stored on the provider’s servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.
If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users’ devices for web analysis or to remember user settings (e.g. in the case of media control).
• 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). Images and/ or video recordings (e.g. photographs or video recordings of a person).
• Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.). Business and contractual partners.
• Purposes of processing: Office and organisational procedures; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)). Provision of contractual services and fulfillment of contractual obligations.
• 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:
• Adobe Creative Cloud: Cloud storage, cloud infrastructure services, and cloud-based application software, among others for photo editing, video editing, graphic design, web development; Service provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.adobe.com/creativecloud.html; Privacy Policy: https://www.adobe.com/privacy.html; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).
• Dropbox: Cloud storage service; Service provider: Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.dropbox.com; Privacy Policy: https://www.dropbox.com/privacy; Data Processing Agreement: https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf).
• Google Cloud Storage: Cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further Information: https://cloud.google.com/privacy.
• Microsoft 365 and Microsoft Cloud Services: Provision of applications, protection of data and IT systems, as well as the use of system-generated log, diagnostic, and metadata for contract execution by Microsoft. The data processed includes contact details (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe), as well as log and metadata. The processing is carried out for purposes of improving efficiency and productivity, cost efficiency, flexibility, mobility, enhanced communication, integration of Microsoft services, IT security and business operations of Microsoft. Data retention is determined by the respective document and company policies: up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data Processing Agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Nextcloud (hosting on own server): Cloud storage service, with operation and storage of processed data on a server managed by us; Service provider: Nextcloud GmbH, Hauptmannsreute 44a, 70192 Stuttgart, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://nextcloud.com/. Privacy Policy: https://nextcloud.com/privacy/.
Newsletter and Electronic Communications
We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration for the newsletter, these contents are decisive for the users’ consent. Normally, providing your email address is sufficient to sign up for our newsletter. However, to offer you a personalised service, we may ask for your name for personal salutation in the newsletter or for additional information if necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to demonstrate previously given consent. The processing of these data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of consent is confirmed. In case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system.
Contents:
Information about us, our services, promotions and offers.
• 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); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). 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: Communication partner (Recipients of e-mails, letters, etc.).
• Purposes of processing: Direct marketing (e.g. by e-mail or postal).
• Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
• Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
Further information on processing methods, procedures and services used:
• Measurement of opening rates and click rates: The newsletters contain a so-called “web beacons”, which is a pixel-sized file that is retrieved from our server, or the server of the dispatch service provider if one is used, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of access are collected. This information is used to technically improve our newsletter based on technical data or target audiences and their reading behavior, which can be determined by their access locations (identifiable by IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and adjust our content to them or send different content according to the interests of our users. The measurement of opening and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on user consent. Unfortunately, it is not possible to revoke success measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
• Mailchimp: Email marketing, automation of marketing processes, collection, storage and management of contact information, measurement of campaign performance, recording and analysis of recipient interaction with content, personalisation of content; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/; Data Processing Agreement: https://mailchimp.com/legal/data-processing-addendum/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider). Further Information: Special safety measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Web Analysis, Monitoring and Optimization
Web analytics (also referred to as “reach measurement”) is used to evaluate the visitor flows of our online services and may include pseudonymous values related to visitor behavior, interests, or demographic information such as age or gender. Through reach analysis, we can, for example, identify when our online services or their functions and content are most frequently used or likely to encourage repeat visits. It also enables us to determine which areas need optimization.
In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online services or their components.
Unless otherwise specified below, profiles (i.e., data combined from a usage process) may be created for these purposes, and information can be stored in and later retrieved from a browser or device. The data collected includes, in particular, visited websites and elements used on them, as well as technical information such as the browser used, the computer system, and information about usage times. If users have given consent to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.
Additionally, users’ IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analytics, A/B testing, or optimization. Instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the respective procedures.
Legal basis information: If we ask users for their consent to use third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in efficient, economic, and user-friendly services). In this context, we would also like to point out 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: Web Analytics (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (Creating user profiles).
• 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:
• Matomo (without cookies): Matomo is a data protection friendly web analysis software, which is used without cookies and in which the recognition of returning users is carried out with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; in the case of the “digital fingerprint”, user movements within our online services are recorded with the help of pseudonymised IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. User data collected through the use of Matomo is processed only by us and is not shared with third parties; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://matomo.org/. Security measures: IP Masking (Pseudonymization of the IP address).
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: Data Privacy Framework (DPF).
• Facebook Pages: Profiles within the social network Facebook – The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page (“Fanpage”). This includes, in particular, information about user behaviour (e.g., viewed or interacted content, actions taken) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations through the “Page Insights” service that give insights into how people interact with our page and its content. The basis for this is an agreement with Facebook (“Information about Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which regulates security measures and the exercise of data subjects’ rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or deletion directly to Facebook. The rights of users (particularly access, deletion, objection, complaint to a supervisory authority) remain unaffected by this. The joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited alone is responsible for further processing, including any possible transmission to Meta Platforms Inc. in the USA; 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: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
• LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data, which is used to create “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. It also includes details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as profile details of users, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have entered into a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum,” https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must comply with and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of users (particularly the right to information, deletion, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by our agreements with LinkedIn. The joint responsibility is limited to the collection of data and its transmission to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, particularly concerning the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Vimeo: Platform for the provision and delivery of video content; Service provider: Vimeo Inc., 555 West 18th Street New York, New York 10011, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://vimeo.com; Privacy Policy: https://vimeo.com/legal/privacy; Data Processing Agreement: https://vimeo.com/legal/enterprise-terms/dpa. Basis for third-country transfers: Standard Contractual Clauses (https://vimeo.com/legal/enterprise-terms/dpa).
• 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: Data Privacy Framework (DPF). 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); 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.).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online services and usability. Profiles with user-related information (Creating user profiles).
• 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:
• Vimeo Video Player: Integration of a video player; Service provider: Vimeo Inc., 555 West 18th Street New York, New York 10011, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://vimeo.com; Privacy Policy: https://vimeo.com/legal/privacy; Data Processing Agreement: https://vimeo.com/legal/enterprise-terms/dpa. Basis for third-country transfers: Standard Contractual Clauses (https://vimeo.com/legal/enterprise-terms/dpa).
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); 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.).
• 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. Security measures.
• 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).
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).
• 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.

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:
https://www.dsb.gv.at/