Privacy Policy
Introduction
With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. This data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender specific.
As of: 05 June 2023
Table of contents
- Introduction
- Responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- Data processing in third countries
- Deletion of data
- Use of cookies
- Provision of the online offer and web hosting
- Contact and inquiry management
- Web analysis, monitoring and optimization
- Presences in social networks (social media)
- Plugins and embedded functions and content
- Changes and updates to the privacy policy
- Rights of the data subjects
- Definitions
Responsible
Ilknur Puchegger
Bachzeile 3/1/2
7035 Steinbrunn
E-mail address:
info@solea.at
Phone:
+43 650 790 8847
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
Types of data processed
- Contact details.
- Content data.
- Usage data.
- Meta/communication data.
Categories of data subjects
- communication partner.
- users.
Purposes of processing
- Provision of contractual services and customer service.
- Contact requests and communication.
- Security measures.
- Reach measurement.
- Tracking.
- Managing and responding to inquiries.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Article 6 (1) sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) - Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Austria. This includes in particular the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act - DSG). The Data Protection Act contains in particular special regulations on the right to information, the right to rectification or deletion, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to it, input, transfer, ensuring availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): We use SSL encryption to protect the data you transmit via our online service. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transmission of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations exist (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Deletion of data
The data we process is deleted in accordance with legal requirements as soon as the consents to processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Our privacy policy may also contain further information on the storage and deletion of data, which applies primarily to the respective processing operations.
Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service that they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to users and contains information on the respective cookie usage.
Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her 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 or preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via the settings in their browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ .
Provision of the online offer and web hosting
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called "web host") or obtain from other sources; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
Contact and inquiry management
When you contact us (e.g. via contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to answer the contact inquiries and any requested measures.
The answering of contact inquiries as well as the administration of contact and inquiry data within the framework of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering inquiries and maintaining user or business relationships.
- Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: communication partners.
- Purposes of processing: Contact requests and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness; provision of contractual services and customer service.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
Further information on processing procedures, methods and services:
- Contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests and the interests of the communication partners in answering the requests and our statutory retention periods; legal bases: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR).
Web analysis, monitoring and optimization
Web analysis (also known as "reach measurement") is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use testing procedures to test and optimize, for example, different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a device and read from it. The information collected includes in particular websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to us or the providers of the services we use collecting their location data, location data can also be processed.
The IP addresses of the users are also 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 analysis, A/B testing and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the purposes of the respective processes.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behavior-related profiling, use of cookies); provision of our online offer and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
Further information on processing procedures, methods and services:
- Google Analytics: web analysis, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; legal basis: consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR); website: https://marketingplatform.google.com/intl/de/about/analytics/ ; data protection declaration: https://policies.google.com/privacy ; order processing agreement: https://business.safety.google/adsprocessorterms ; standard contractual clauses (guaranteeing data protection level when processing in third countries): https://business.safety.google/adsprocessorterms ; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated ; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
Presences 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 result in risks for users because it could, for example, make it more difficult to enforce user rights.
Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user's usage behavior and the resulting interests. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the user's interests. For these purposes, cookies are usually stored on the user's computers in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the user (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Instagram: social network; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://www.instagram.com ; privacy policy: https://instagram.com/about/legal/privacy .
Plugins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos or city maps (hereinafter referred to uniformly as "content").
The integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can 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 can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; provision of contractual services and customer service.
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Google Fonts (obtained from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted that is necessary for the provision of the fonts depending on the devices used and the technical environment; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://fonts.google.com/ ; Privacy Policy: https://policies.google.com/privacy .
- Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually as part of the settings on their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://cloud.google.com/maps-platform ; Privacy policy: https://policies.google.com/privacy ; Possibility of objection (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated .
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out 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, please note that the addresses may change over time and please check the information before contacting us.
Rights of the data subjects
As a 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 to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
- Right to withdraw consent: You have the right to withdraw consent at any time.
- Right to information: You have the right to request confirmation as to whether or not data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you 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 the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you violates the provisions of the GDPR.
Definitions
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are intended primarily to aid understanding. The terms are sorted alphabetically.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists in using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This enables them to, for example, better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- Tracking: "Tracking" is when the behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information with regard to the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
- Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing personal data.
- Processing: "Processing" is any operation or set of operations which is carried out with or without the aid of automated procedures in connection with personal data. The term is broad and covers practically every handling of data, be it the collection, evaluation, storage, transmission or deletion.