We process your personal data exclusively in accordance with the provisions of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Note: For ease of reading, the term “data” is generally used, even though personal data is meant. Legal provisions without further specification refer exclusively to those of the GDPR, unless otherwise stated. Below, we inform you in accordance with the requirements of the GDPR regarding the nature, scope, and purpose of data collection as well as its use:

I. Name and Address of the Data Controller

The data controller is:

gbd Holding ZT GmbH
Steinebach 13
6850 Dornbirn, Austria
Tel: +43 5572 235 68
office.holding@gbd.group
www.gbd.group

II. General Information on Data Processing

1. Scope of Processing

We collect and use our users’ personal data only to the extent necessary to provide a fully functional website and to deliver our content and services. As a general rule, we collect and use our users’ personal data only with their consent. An exception applies in cases where obtaining prior consent is not possible for practical reasons and the processing of the data is permitted by law.

2. Legal basis for the processing of personal data

To the extent that we obtain your consent for the processing of personal data, Article 6(1)(a) serves as the legal basis. When processing data necessary to fulfill a contract with you, Article 6(1)(b) serves as the legal basis. This also applies to processing operations necessary for the implementation of pre-contractual measures. To the extent that processing is necessary to comply with a legal obligation to which we are subject, Article 6(1)(c) serves as the legal basis. If the processing is necessary to protect a legitimate interest of our company or a third party, and your interests and fundamental rights do not override the aforementioned interest, Article 6(1)(f) serves as the legal basis.

3. Data Deletion and Retention Period

Your data will be deleted or blocked as soon as the purpose for which it was stored no longer applies. Data may also be stored if required by European or national regulations, laws, or other provisions to which we are subject. Data will also be blocked or deleted when a retention period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract.

III. Provision of the Website and Creation of Log Files

1. Description and Scope of Data Processing

Every time our website is accessed, our system automatically collects data and information from the accessing computer’s system. The following data is collected: • Information about the browser type and version used, the user’s operating system, the user’s Internet service provider, the user’s IP address, the date and time of access, websites from which the user’s system accesses our website, and websites accessed by the user’s system via our website

2. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Article 6(1)(f).

3. Purpose of data processing

The system temporarily stores the IP address in order to deliver the website to the user’s computer. To do this, the user’s IP address must be stored for the duration of the session. The data is stored in log files to ensure the website functions properly. In addition, the data helps us optimize the website and ensure the security of our IT systems. The data is not analyzed for marketing purposes in this context. These purposes also constitute our legitimate interest in data processing pursuant to Article 6(1)(f).

4. Duration of storage

The data is deleted as soon as it is no longer necessary for the purpose for which it was collected. In the case of data collected for the purpose of providing the website, this occurs when the respective session ends. In the case of data stored in log files, this occurs after seven days at the latest. Storage beyond this period is possible. In this case, the users’ IP addresses are deleted or anonymized so that the client making the request can no longer be identified.

5. Right to Object and Request Rectification

The collection of data for the purpose of providing the website and the storage of such data in log files is essential for the operation of the website. Consequently, users do not have the option to object.

IV. Use of Cookies

1. Description and Scope of Data Processing

Our website uses cookies. Cookies are text files that are stored in or by the web browser on the user’s computer system. When a user visits a website, a cookie may be stored on the user’s operating system. This cookie contains a unique string of characters that allows the browser to be uniquely identified when the website is visited again. We use cookies on our website that enable us to analyze users’ browsing behavior. The following data may be transmitted:

• Search terms entered
• Frequency of page views

The user data collected in this manner is anonymous. Therefore, it is not possible to link the data to the user accessing the site. The data is not stored together with any other personal data of the users. When visiting our website, users are informed via an information banner about the use of cookies for analytical purposes. In this context, there is also a note on how the storage of cookies can be prevented in the browser settings. The following cookies are used and are related to Google Universal Analytics:

• gat
• gid
• ga

2. Legal basis for data processing

The legal basis for processing your data using technically necessary cookies is Article 6(1)(f). For cookies used for analytical purposes, the legal basis is Article 6(1)(a), provided you have given your consent.

3. Purpose of data processing

The purpose of using cookies that are not technically necessary is to analyze users’ browsing behavior. All features of our website are available even without the use of these cookies. Analytical cookies are used to improve the quality of our website and its content. These cookies allow us to understand how the website is used, enabling us to continuously optimize our services. These purposes also constitute our legitimate interest in processing your data pursuant to Article 6(1)(f).

 

4. Duration of Storage, Right to Object, and Right to Erasure

Cookies are stored on the user’s computer and transmitted to our site by the user. As a user, you therefore have full control over the use of cookies. By changing the settings in your web browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. There are several ways to manage cookies. The Help button on the toolbars of most browsers shows you how to stop accepting cookies, how to be notified when a new cookie is set, and how to block cookies. If you block cookies, you may not be able to register, log in, or use the services to their full extent.

V. Newsletter

1. Description and Scope of Data Processing

On our website, you can subscribe to a free newsletter. When you sign up for the newsletter, the data entered in the form is transmitted to us. Specifically, we need your email address, your first and last name along with your title, and information indicating whether the address is a personal or business address. In addition, the following data is collected during registration:

• IP address of the requesting computer
• Date and time of registration

Your consent to the processing of your data will be obtained during the registration process, and you will be directed to this privacy policy.

In connection with the data processing required to send our newsletter, we share data with third parties by sending our newsletter via the services of MailChimp, operated by Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. These emails contain web beacons, also known as tracking pixels. This allows us to determine whether the emails have been opened or whether the links contained in the emails have been clicked. We use this information to improve our email service and analyze which information is read or clicked on most frequently. We link this data to the actions you take on our website. The newsletter provider MailChimp stores the information collected in this way on its server in the USA. MailChimp is authorized to share your user data with third parties in certain cases. You can opt out of this tracking at any time by clicking the separate link provided in each email or by notifying us via the email address [webservices@gbd.group].

Mailchimp is a Privacy Shield-certified company. These data transfers are permitted under the European Commission's Adequacy Decision (EU) 2016/1250.

For information on the purpose and scope of data collection, as well as the further processing and use of data by MailChimp, and your related rights and privacy settings, please refer to the Privacy Policy at mailchimp.com/legal/privacy and MailChimp’s Terms of Service at mailchimp.com/legal/terms.

When you delete the email, the web beacon is also automatically deleted. Our standard text emails do not contain web beacons. With the exception of our use of the Mailchimp newsletter tool, your data is used exclusively for sending the newsletter and is not shared with third parties.

2. Legal basis for data processing

The legal basis for processing your data after you subscribe to the newsletter is Article 6(1)(a) if the user has given consent.

3. Purpose of data processing

We collect your email address for the purpose of sending you the newsletter.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user’s email address will therefore be stored for as long as the newsletter subscription remains active. Other data collected during the registration process is generally deleted after a period of seven days.

5. Right to Object and Request Rectification

Users may unsubscribe from the newsletter at any time. A link for this purpose is included in every newsletter. When the email is deleted, the web beacon is also automatically deleted. Our standard text emails do not contain web beacons. This also allows users to withdraw their consent to the storage of the personal data collected during the registration process.

VI. Web Analytics Services

1. Scope of Processing

We use various tools on our website to analyze our users’ browsing behavior. The software places a cookie on the user’s computer (see above for information on cookies). When individual pages of our website are accessed, the following data is stored:

(1) Two bytes of the IP address of the user's system

(2) The webpage that was accessed

(3) The website from which the user accessed the current webpage (referrer)

(4) The subpages that are accessed from the current webpage

(5) Time spent on the website

(6) The frequency with which the website is visited

 

Google Universal Analytics

We use various web analytics services, including Google Analytics from Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. These analytics services use “cookies,” which are text files stored on your computer that enable an analysis of your use of the website. The information generated by the cookie about your use of this website (including your IP address) is transmitted to the servers of the web analytics services (in Google’s case, to the U.S.) and stored there. These analytics services will use this information to evaluate your use of the website, to compile reports on website activity for the website operators, and to provide other services related to website and internet usage. The IP address transmitted by the user’s browser as part of Google Analytics will not be merged with other Google data.

You can prevent cookies from being stored by adjusting your browser settings accordingly; however, please note that in this case, you may not be able to use all features of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link (tools.google.com/dlpage/gaoptout?hl=de).

For more information on our Terms of Use and Privacy Policy, please visit www.google.com/analytics/terms/de.html or www.google.de/intl/de/policies/.

Please note that Google Analytics on this website has been enhanced with the "anonymizeIp" code to ensure that IP addresses are collected anonymously (a process known as IP masking).

 

Google Remarketing

We use Google Remarketing technology, a service provided by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States. This feature allows us to target you as a website visitor with advertising by displaying personalized, interest-based ads when you visit other websites in the Google or DoubleClick Display Network. To analyze your website usage, demographic characteristics, and interests, Google uses cookies that are stored on your computer. To analyze your website usage—which is a prerequisite for the use of interest-based ads—Google uses cookies that are stored on your computer. The information generated by the cookie is transmitted to a Google server, stored there, and can be analyzed by us for statistical purposes and used to create interest-based ads. Google may transfer this information to third parties where required by law or where such third parties process the data on Google’s behalf.

You may object to the collection and storage of data at any time with future effect. You can disable the use of cookies by Google by visiting the page www.google.com/policies/technologies/ads/ to opt out of Google advertising. Alternatively, you can disable the use of cookies by third-party providers by visiting the Network Advertising Initiative’s opt-out page at www.networkadvertising.org/managing/opt_out.asp. For more information on Google’s privacy policy, please visit www.google.com/intl/de/privacy.

Facebook Custom Audience

We use Facebook's "Custom Audience" technology, a service provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. The data collected through the integration of cookies, web beacons, or similar third-party technologies allows us to measure and design our advertising activities on Facebook more effectively and, for example, to display posts or advertisements only to visitors of our website. To collect this data, we use exclusively cookies, web beacons, and similar, proven, and widely used third-party technologies. We do not share lists containing personal data with Facebook or upload such data to Facebook. The data collected in this process is transmitted to Facebook only in encrypted form. We cannot view any personal data of individual users.

For more information, please see Facebook’s Privacy Policy at www.facebook.com/about/privacy. If you do not wish to have your data collected via “Custom Audience,” you can disable “Custom Audience” here.

We use these web analytics services to continuously improve our features and services. Only non-personal data is used for analysis and reporting purposes. We do not combine this data with any other personal data.

Privacy Policy for the Use of Facebook

Our website incorporates plugins from the social network Facebook, located at 1601 South California Avenue, Palo Alto, CA 94304, USA. You can recognize the Facebook plugins by the Facebook logo or the “Like” button on our site. You can find an overview of the Facebook plugins here: https://developers.facebook.com/docs/plugins/. When you visit our pages, the plugin establishes a direct connection between your browser and the Facebook server. This informs Facebook that you have visited our site using your IP address. If you click the Facebook “Like” button while logged into your Facebook account, you can link the content of our pages to your Facebook profile. This allows Facebook to associate your visit to our pages with your user account. Please note that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it is used by Facebook. For more information, please refer to Facebook’s privacy policy at https://www.facebook.com/policy.php. If you do not want Facebook to associate your visit to our pages with your Facebook user account, please log out of your Facebook account.

2. Legal basis for the processing of personal data

The legal basis for the processing of users' personal data is Article 6(1)(f).

3. Purpose of data processing

Processing users’ personal data allows us to analyze their browsing behavior. By evaluating the data collected, we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. These purposes also constitute our legitimate interest in processing the data pursuant to Article 6(1)(f). By anonymizing the IP address, we adequately take into account users’ interest in the protection of their personal data.

4. Duration of storage

The data will be deleted as soon as it is no longer needed for our record-keeping purposes.

5. Right to Object and Request Rectification

Cookies are stored on the user’s computer and transmitted to our site by the user. As a result, you, as the user, have full control over the use of cookies. You can disable or restrict the transmission of cookies by changing the settings in your web browser. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, you may no longer be able to use all of the website’s features to their full extent.

We offer our users the option to opt out of the analytics process on our website. To do so, please follow this link (https://www.gbd.group/opt-out). This will set an additional cookie on your system that signals to our system not to store the user’s data. If the user deletes the corresponding cookie from their system in the meantime, they must set the opt-out cookie again. For more information on the privacy settings of the web analytics tools we use, please refer to the above explanations.

VII. User Rights (Data Subject Rights)

If we process your personal data, you are a data subject within the meaning of the GDPR, and you have the following rights vis-à-vis us as the data controller:

1. Right to access information

You may request confirmation from us as to whether we are processing personal data concerning you. If such processing is taking place, you may request the following information from us:

The purposes and categories of personal data being processed, including the recipients or categories of recipients to whom your data has been or will be disclosed, as well as the planned duration of storage of the data concerning you. If we use profiling technologies, we have provided you with meaningful information about the logic involved, as well as the scope and intended effects of such processing on you. Furthermore, we have informed you of your right to lodge a complaint with the data protection authority. You also have the right to request information regarding whether the data concerning you is transferred to a third country or to an international organization.

2. Right to rectification

You have the right to have your data corrected and/or completed if the data we process about you is inaccurate or incomplete. If applicable, we will correct the data without delay.

3. Right to restriction of processing

You may request that the processing of your data be restricted under the following conditions:

(1) if you dispute the accuracy of the data concerning you for a period that allows us to verify the accuracy of your data;

(2) the processing is unlawful and you object to the erasure of your data and instead request the restriction of its use;

(3) we no longer need your data for the purposes of processing, but you need it to assert, exercise, or defend legal claims, or

(4) if you have objected to the processing and it has not yet been determined whether our legitimate grounds override your interests. If the processing of your data has been restricted, such data—apart from its storage—may be processed only with your consent or for the purpose of asserting, exercising, or defending legal claims, or to protect the rights of another natural or legal person.

If the restriction on processing has been imposed in accordance with the above conditions, we will notify you before the restriction is lifted.

4. Right to erasure

We are required to delete your data immediately if any of the following applies:

(1) Your data is no longer necessary for the purposes for which we collected it;

(2) You withdraw your consent and there is no other legal basis for the processing.

(3) You object to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds on our part for the processing, or you object to the processing pursuant to Article 21(2).

(4) Your data has been processed unlawfully.

The right to erasure does not apply if the processing is necessary

(1) to comply with a legal obligation that requires processing (e.g., with respect to government agencies and authorities), or to perform a task carried out in the public interest that has been entrusted to us;

(2) to assert, exercise, or defend legal claims.

5. Right to Information

If you have exercised your right to rectification, erasure, or restriction of processing with us, we are required to notify all recipients to whom your data has been disclosed of such rectification, erasure, or restriction of processing, unless this proves impossible or involves disproportionate effort.

You have the right to be informed about these recipients.

6. Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your data carried out pursuant to Article 6(1)(e) or (f); this also applies to profiling based on these provisions.

In such cases, we will no longer process your data unless we have compelling legitimate grounds for processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

If your data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing. If you object to the processing for direct marketing purposes, your data will no longer be processed for those purposes.

7. Right to withdraw consent under data protection law

You have the right to withdraw your consent under data protection law at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of your consent prior to its withdrawal.

8. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to file a complaint with the Data Protection Authority pursuant to § 24 et seq. of the DSG 2018 if you believe that the processing of your data violates the GDPR. The Data Protection Authority will inform the complainant of the status and outcome of the complaint, including the possibility of seeking judicial remedy.

Dornbirn, January 2020