Privacy Policy
Revised on November 29, 2022
I. Overview
If we may welcome you as a customer, interest or business partner, please read from point III.
When you visit our website, please read from point II.
II. What data do we process when you visit our website?
Welcome to our website! Please familiarize yourself with how we process your personal data when you visit our website (Articles 13 and 14 of the GDPR; Section 165 (3) of the Telecommunications Act).
When you visit our website, the following data may be processed:
Browser type,
operating system,
Country,
Date,
Time and duration of access,
IP address* and pages visited on our website including entry and exit pages, contact page on website,
Contact page on website,
Device Data: We may store personal data from your device. Such data includes geolocation data, IP address, unique identifiers (e.g., MAC address),
Data you enter via a contact form,
Data in the course of sending the newsletter.
The processing of this data is necessary to ensure the security of the website and its technical functionality. This data is collected partly via technical cookies. These technical cookies are used only to the extent necessary (Section 165 (3) of the Telecommunications Act (TKG)). The processing of this data is justified by our legitimate interest in operating our website (Article 6 (1) (f) GDPR).
To operate our website, it may be necessary for us to disclose your data to the following recipients:
Recipient data: Host Europe Limited
Purpose of data processing: Website hosting
Legal basis for data processing: Overriding legitimate interest
(Article 6 (1) (f) GDPR)
Headquarters: Germany
Basis for transfer to a third country**: Within the EU
Recipient data: MailChimp, Inc
Purpose of data processing: Newsletter provider
Legal basis for data processing: Consent (Article 6 (1) (a) GDPR)
Headquarters: USA
Basis for transfer to third countries: Standard data protection clauses according to Art. 46 (2) (c) GDPR
Recipient data: Facebook (Instagram); (Meta, Inc)
Purpose of data processing: Social media provider
Legal basis for data processing: Consent (Article 6 (1) (a) GDPR)
Headquarters: USA
Basis for transfer to a third country: Art. 49 (1) (a) GDPR
Recipient data: Linkedin (Microsoft, Inc)
Purpose of data processing: Social media provider
Legal basis for data processing: Consent (Article 6 (1) (a) GDPR)
Headquarters: USA
Basis for transfer to a third country: Art. 49 (1) (a) GDPR
Recipient data: TikTok
Purpose of data processing: Social media provider
Legal basis for data processing: Consent (Article 6 (1) (a) GDPR)
Headquarters: China
Basis for transfer to a third country: Art. 49 (1) (a) GDPR
Recipient data: Alphabet, Inc (Google Analytics, Google Drive; Gmail)
Purpose of data processing: Statistical analysis of the website and advertising; document storage and collaborative work; email provider
Legal basis for data processing: Consent (Article 6 (1) (a) GDPR); legitimate interest pursuant to Article 6 (1) (f) GDPR;
Headquarters: USA
Basis for transfer to third countries: Standard data protection clauses according to Art. 46 (2) (c) GDPR
II.1. Overview of the “technical” cookies used
The above-mentioned data is stored via so-called "cookies***." Cookies are text files stored on your computer that enable analysis of website usage. They are used to recognize and temporarily store data about website visitors. We generally only use cookies to the extent necessary to communicate with you via the website.
These technical cookies are activated as soon as you visit our homepage.
The following cookies are used on our platform based on our predominantly legitimate interest (Art. 6 (1) (f) GDPR):
Name of the cookie:_cf_bm
Purpose of the cookie: This cookie is used to distinguish between humans and bots.
Duration of storage: 1 day
Name of the cookie: embed/v3/counters.gif
Purpose of the cookie: Used to implement forms into the website.
Duration of storage: Session
II.2. Overview of the advertising cookies used
In addition to the "technical cookies" described above, we also use so-called advertising cookies (including "statistical cookies"). These advertising cookies enable us to better understand and evaluate your interests. Advertising cookies allow us to combine your browsing behavior with data from other websites beyond the boundaries of our website. This enables us to better understand the interests of our website visitors and address them more specifically.
We respect that not every visitor to the website wants this. Therefore, we only process your data in the context of advertising cookies if you consent to it (Article 6 (1) (a) GDPR). You can revoke this consent at any time; the data processing carried out up to the time of revocation remains justified.
Name of the cookie: _hssc
Purpose of the cookie: Statistical purposes
Duration of storage: 1 day
Recipient's country of residence: USA
How it works: Indicates whether the cookie data needs to be updated in the visitor's browser
Name of the cookie: _hssrc
Purpose of the cookie: Statistical purposes
Duration of storage: Session
Recipient's country of residence: USA
How it works: Used to recognize the visitor's browser when they return to the website.
Name of the cookie: _hstc
Purpose of the cookie: Statistical purposes
Duration of storage: 179 days
Recipient's country of residence: USA
How it works: Sets a unique ID for the session. This allows the website to collect data about visitor behavior for statistical purposes.
Name of the cookie: hubspotuk
Purpose of the cookie: Statistical purposes
Duration of storage: 179 days
Recipient's country of residence: USA
How it works: Sets a unique ID for the session. This allows the website to collect data about visitor behavior for statistical purposes.
Name of the cookie: _ptg.gif
Purpose of the cookie: Advertising purposes
Duration of storage: Session
Recipient's country of residence: USA
Name of the cookie: _ga; (Google) – Google Analytics
Purpose of the cookie: Statistical purposes
Duration of storage: 399 days
Recipient's country of residence: USA
How it works: Registers a unique ID that is used to compile statistical data about website usage.
Name of the cookie: _ga_# (Google) – Google Analytics
Purpose of the cookie: Statistical purposes
Duration of storage: 399 days
Recipient's country of residence: USA
How it works: Collects data on how often a visitor visits the website.
Name of the cookie: _gid (Google)
Purpose of the cookie: Statistical purposes
Duration of storage: 1 day
Recipient's country of residence: USA
How it works: Registers a unique ID that is used to compile statistical data about how visitors use the website.
Name of the cookie: _gat (Google)
Purpose of the cookie: Statistical purposes
Duration of storage: 1 day
Recipient's country of residence: USA
How it works: Certain data is sent to Google Analytics only once per minute. The cookie has a lifespan of one minute. As long as it is set, certain data transfers are blocked.
III. For what purposes do we process your data if you are our customer or have a business relationship with us?
In the course of our business relationship with customers and business partners, we process data based on contractual obligations (processing of the contractual relationship with you, pre-contractual obligations, invoicing of services, dispatch of documents, communication for the purpose of processing the contract) and legal obligations (legally required retention within the meaning of Section 132 BAO) (Article 6 (1) (b) and (c) GDPR) as well as on the basis of our legitimate interests or on the basis of legitimate interests of third parties (Article 6 (1) (f) GDPR), namely:
- for the purpose of internal administration and management of your business case to the extent necessary (e.g. processing your business case, forwarding your business case to various departments, filing, archiving purposes, correspondence with you);
- for the purpose of delivering orders;
- In case of due diligence (assessment by investors);
Assertion and defense of legal claims
To the extent necessary in each case. Your data is processed to initiate, maintain, and process our business relationships. If you do not provide us with this data, we will unfortunately not be able to process your transaction.
If necessary, we process your data based on your voluntary, express consent (Art. 6 (1) (a) GDPR).
IV. How long will your data be stored?
We will only store your data for as long as necessary for the purposes for which we collected it. In this context, statutory retention periods must be observed (for example, for tax reasons, contracts and other documents arising from our contractual relationship must generally be retained for a period of seven years (Section 132 of the Federal Fiscal Code (BAO)). In justified individual cases, such as for the assertion and defense of legal claims, we may also store your data for up to 30 years after the end of the business relationship. We store data from interested parties for up to one year from the time of the last contact by the interested party.
V. Who might receive your data?
In the course of our business relationship, it may be necessary for us to transmit your data to the following recipients:
Recipient: CP International Logistik GmbH
Purpose: Logistics and delivery company
Legal basis: legitimate interest
Country: Austria
Recipient: Insurance companies
Purpose: Insurance of transports
Legal basis: Legal and contractual necessity
Country: Austria
Recipient: auditors and tax consultants
Purpose: Tax advice
Legal basis: Contractual necessity
Country: Austria
Basis for transfer to third country: Within the EEA
Recipient: Erste Bank
Purpose: Payment processing
Legal basis: Contractual obligation
Country: Within the EEA
Basis for transfer to third country: Within the EEA
Recipients: Lawyers, courts, dispute resolution
Purpose: Pursuit and defense of legal claims
Legal basis: Overriding legitimate interests
Country: Austria
Basis for transfer to third country: Within the EEA
Recipient: Online collaboration tools (Zoom, Microsoft Teams)
Purpose: Conducting online meetings
Legal basis: Overriding legitimate interests
Country: USA
Basis for transfer to third countries: Standard data protection clauses according to Art. 46 (2) (c) GDPR
Recipient: Funding agencies
Purpose: Proof of financial management
Legal basis: Legal and contractual necessity
Country: Austria
Basis for transfer to third country: Within EU
Recipient: HubSpot, Inc.
Purpose: e-commerce platform; E-commerce
Legal basis: Overriding legitimate interests
Country: USA
Basis for transfer to third countries: Standard data protection clauses according to Art. 46 (2) (c) GDPR
Recipient: Canva Pty Ltd.
Purpose: Creation of designs, creative services
Legal basis: Overriding legitimate interests
Country: Australia
Basis for transfer to third countries: Standard data protection clauses according to Art. 46 (2) (c) GDPR
VI. Collection of data from other sources (Article 14 GDPR)
In the course of a business relationship, or the initiation of one, it is naturally necessary to conduct research on the business partner. This is done only to the extent necessary for this purpose. In this context, data may be retrieved and processed from the following sources:
Our company does not obtain data from third-party sources.
VII. Does automated decision-making or profiling take place (Article 13 (2) (f) GDPR)?
No automated decision-making or profiling takes place in our company.
VIII. What rights do you have regarding data processing?
We would like to inform you that, provided the legal requirements are met:
- Have the right to request information about which of your data we process (see Art. 15 GDPR in detail).
- Have the right to request the rectification or completion of inaccurate or incomplete data concerning you (see Art. 16 GDPR in detail).
- Have the right to erasure of your data (see Art 17 GDPR in detail).
- You have the right to object to the processing of your data that is necessary to protect our legitimate interests or those of a third party (see Art. 21 GDPR for details). This applies in particular to the processing of your data for advertising purposes.
- Have the right to receive the data you have provided in a structured, commonly used and machine-readable format.
If we process your data based on your consent, you have the right to revoke this consent at any time by email. This will not affect the legality of the data processing carried out up to that point (Article 7 (3) GDPR).
IX. What rights of complaint do you have?
Should, contrary to expectations, your right to lawful processing of your data be violated, please contact us by post or email. We will endeavor to address your concerns promptly. You also have the right to lodge a complaint with your local data protection supervisory authority.
The address of the Austrian Data Protection Authority is:
Austrian Data Protection Authority
Barichgasse 40-42,
1030 Vienna
X. How can you contact us?
If you have any further questions about the processing of your data, please feel free to contact our data protection coordinator using the contact details below.
XI. Responsible
The responsible party within the meaning of Art 4 Z 7 GDPR is:
Circularful GmbH
Leystrasse 50, Top 23
1200 Vienna
Austria
+43 664 533 90 81
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*An IP address is a number assigned to a device. This IP address allows devices to communicate over the internet. Each IP address contains information about the internet service provider used and the physical location of the device. This allows information about the device's user to be obtained.
**“Third country” includes all states except (1) the Member States of the European Union and (2) the Member States of the European Economic Area, i.e., in addition to the EU Member States, Iceland, Liechtenstein and Norway.
***You can prevent cookies from being saved by selecting the appropriate settings in your browser. However, please note that if you do this, you may not be able to use the full functionality of this website.
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Author of this privacy policy : Dr. Tobias Tretzmuller, LL.M .; www.digital-recht.at
Any use of this privacy policy, or even parts of it, without the consent of the author constitutes a copyright infringement.
