Data protection

Privacy policy as of: 18.05.2018

1. basic information on data processing and legal bases

1.1. This privacy policy clarifies the nature, scope and purpose of the processing of personal data within our online offer and the associated websites, functions and content (hereinafter collectively referred to as “online offer” or “website”). The privacy policy applies regardless of the domains, systems, platforms and devices used (e.g. desktop or mobile) on which the online offer is executed.

1.2. We refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR) for the terms used, such as “personal data” or their “processing”.

1.3. The personal data of users processed in the context of this online offer includes inventory data (without login: e.g. the IP address. Logged in: e.g. names and addresses of customers), contract data at login (e.g. services used, payment information), usage data (e.g. the websites visited on our online offering) and content data (e.g. entries made during registration).

1.4. The term “user” includes all categories of data subjects affected by data processing. They include our business partners, customers, interested parties and other visitors to our online offering. The terms used, such as “user”, are to be understood as gender-neutral.

1.5. We only process users’ personal data in compliance with the relevant data protection regulations. This means that user data is only processed if legal permission has been granted. I.e., in particular if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) and online services, or is required by law, the consent of the user is available, as well as due to our legitimate interests (i.e. interest in the analysis, optimization and economic operation and security of our online offer within the meaning of Art. 6 para. 1 lit. a GDPR). 1 lit. f. GDPR, in particular when measuring reach, creating profiles for advertising and marketing purposes, collecting access data and using the services of third-party providers.

1.6. We would like to point out that the legal basis for consent is Art. 6 para. 1 lit. a. and Art. 7 GDPR, the legal basis for the processing for the fulfillment of our services and implementation of contractual measures Art. 6 para. 1 lit. b. GDPR, the legal basis for processing to fulfill our legal obligations Art. 6 para. 1 lit. c. GDPR, and the legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f. GDPR is.


2. safety measures

2.1. We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and to protect the data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.

2.2. The security measures include in particular the encrypted transmission of data between your browser and our server.


3. transfer of data to third parties and third-party providers

3.1. Data will only be passed on to third parties within the framework of legal requirements. We only pass on user data to third parties if this is necessary, e.g. on the basis of Art. 6 para. 1 lit. b) GDPR is necessary for contractual purposes or on the basis of legitimate interests pursuant to Art. Art. 6 para. 1 lit. f. GDPR for the economic and effective operation of our business.

3.2. If we use subcontractors to provide our services, we take appropriate legal precautions and appropriate technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal regulations.

3.3. If content, tools or other means from other providers (hereinafter jointly referred to as “third-party providers”) are used within the scope of this privacy policy and their registered office is located in a third country, it can be assumed that data will be transferred to the countries in which the third-party providers are based. Third countries are countries in which the GDPR is not directly applicable law, i.e. generally countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if there is an adequate level of data protection, user consent or other legal permission.


4. provision of contractual services

4.1. We process inventory data (e.g. IP addresses), contract data upon registration (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with the GDPR. Art. 6 para. 1 lit b. GDPR.

4.2. Users can register for re.comm. As part of the registration process, users are provided with the required mandatory information. Registration is not public and user data cannot be indexed by search engines. Users can request the deletion of their data in writing at any time. Users’ data will be deleted at their request, subject to their retention for commercial or tax law reasons. Art. 6 para. 1 lit. c GDPR is necessary. We are entitled to irretrievably delete all user data stored during the term of the contract.

4.3. In the context of registrations and renewed logins as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of the users to protect against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with. Art. 6 para. 1 lit. c GDPR.

4.4. We process usage data (e.g., the websites visited on our online offering, interest in our events) and content data (e.g., entries made during registration) for advertising purposes in a user profile, e.g., to provide users with event information based on the services they have used to date.


5. making contact

5.1. When contacting us (via contact form or e-mail), the user’s details are used to process the contact request and its handling in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. b) GDPR is processed.

5.2. User data is only stored internally and is not passed on to third parties, unless there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. c GDPR, passed on.


6. collection of access data and log files

6.1. We collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

6.2. Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.


7. cookies reach measurement

7.1. Cookies are pieces of information that are transferred from our web server or third-party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.

7.2. We use “session cookies”, which are only stored for the duration of the current visit to our online presence (e.g. to enable the storage of your login status or the shopping cart function and thus the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close the browser, for example.

7.3. Users are informed about the use of cookies in the context of pseudonymous reach measurement in this privacy policy.

7.4. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

7.5. You can object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).


8. google analytics

8.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analysis service provided by Google Inc. GDPR) Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

8.2. Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

8.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

8.4. We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

8.5. The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

8.6. You can find further information on data use by Google, setting and objection options on the Google websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.de/settings/ads (“Manage information that Google uses to show you advertising”).


9. facebook social plugins

9.1 We may use social plugins (“plugins”) of the social network facebook.com on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR). GDPR) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognizable by one of the Facebook logos (white “f” on a blue tile, the terms “Like”, “Gefällt mir” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

9.2. Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

9.3. When a user accesses a function of this online offering that contains such a plugin, their device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offering. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

9.4. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plugins, for example by clicking the Like button or leaving a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out and store their IP address. According to Facebook, only an anonymized IP address is stored in Austria.

9.5. The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and setting options to protect the privacy of users can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.

9.6. If a user is a Facebook member and does not want Facebook to collect data about them via this online service and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

9.7 You can view Facebook’s privacy policy at any time at https://www.facebook.com/privacy/explanation. If you have any questions about Facebook’s data policy, you can use the following contact form https://www.facebook.com/help/contact/2061665240770586. You can contact Facebook’s data protection officer online (https://www.facebook.com/help/contact/540977946302970) or at Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.


10. newsletter

10.1. The following information explains the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

10.2. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Our newsletters also contain information about our events (e.g. Caesar, Immobilienball, re.comm) or companies.

10.3. Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can log in with other people’s e-mail addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

10.4. Dispatch service provider: The newsletter is sent by Active Campaign, ActiveCampaign, LLC, 1 N Dearborn, 5th Floor, Chicago, IL 60601, United States, hereinafter referred to as the “dispatch service provider”. You can view the data protection provisions of the shipping service provider here: https://www.activecampaign.com/privacy-policy/

10.5. Furthermore, the mailing service provider may, according to its own information, use this data in pseudonymous form, i.e. without allocation to a user, to optimize or improve its own services, e.g. to technically optimize the mailing and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or pass it on to third parties.

10.6. Registration data: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.

10.7. Statistical survey and analyses – The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the server of the mailing service provider when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. Although this information can be assigned to individual newsletter recipients for technical reasons, it is neither our intention nor that of the mailing service provider to monitor individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

10.8. The use of the shipping service provider, the performance of statistical surveys and analyses and the logging of the registration process are based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves both our business interests and the expectations of users.

10.9. Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consent to its dispatch by the dispatch service provider and the statistical analyses will expire. A separate revocation of the dispatch by the dispatch service provider or the statistical evaluation is unfortunately not possible. You will find a link to unsubscribe from the newsletter at the end of each newsletter. Each event has its own newsletter and must be canceled separately. If you have only registered for a specific newsletter and cancel this registration, your personal data relating to this newsletter will be deleted.


11. integration of third-party services and content

11.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR), we use content or service offers from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

11.2. The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):

– External fonts from Google, Inc, https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated by calling up a Google server (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.

– Videos from the “YouTube” platform of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.


12. rights of the users

12.1. Users have the right, upon request and free of charge, to receive information about the personal data that we have stored about them.

12.2. In addition, users have the right to rectification of inaccurate data, restriction of processing and erasure of their personal data, if applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to lodge a complaint with the competent supervisory authority.

12.3. Users can also revoke their consent, in principle with effect for the future.

13. deletion of data

13.1. The data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the user’s data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.

13.2. According to legal requirements, the data is stored for 6 years in accordance with § 257 para. 1 HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).


14. right of objection

Users can object to the future processing of their personal data in accordance with the legal requirements at any time. The objection may be made in particular against processing for direct marketing purposes.


15. changes to the privacy policy

15.1. We reserve the right to amend the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. If user consent is required or components of the privacy policy contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.

15.2. Users are requested to inform themselves regularly about the content of the privacy policy.


16. further questions?

If you have any questions regarding the collection, processing and use of your personal data, please contact us at the e-mail address below.

epmedia advertising agency GmbH

Wienerbergstrasse 11

1100 Vienna

E-mail: office@epmedia.at