DATA PRIVACY STATEMENT
DATA PROTECTION IS IMPORTANT TO US!
Objective and Responsibility
- This Data Privacy Statement is to inform you about the nature, scope and purpose of the processing of personal data related to our online service and the related websites, features and contents (hereinafter collectively referred to as “online service” or “website”). Details of these processing activities can be found in section 2.
- Details of data processing for the purpose of carrying out our business processes are described in section 3.
- The online service is provided by VIER PFOTEN International, Linke Wienzeile 236, A-1150 Vienna, Austria – hereinafter referred to as “provider”, “we” or “us” – who is also legally responsible under the data protection law.
- Our online service is hosted by WEMINDD B.V. (Mindd Agency / Eemlandstraat 28, 5018DE Tilburg, The Netherlands) via DigitalOcean LLC. The server location is Amsterdam.
- You can reach out to our Data Protection Officer using the e-mail address email@example.com.
- The term “user” encompasses all customers, interested people, employees and visitors of our online service.
We collect and process personal data based on the following legal grounds:
- Consent in accordance with Article 6 paragraph 1 (a) General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
- Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to Article 6 paragraph 1 (b) GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
- Processing to fulfil a legal obligation in accordance with Article 6 paragraph 1 (c) GDPR, meaning that e.g. the processing of data is required by law or other provisions.
- Processing in order to protect legitimate interests in accordance with Article 6 paragraph 1 (f) GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.
Data Subject Rights
You have the following rights with regards to the processing of your data through us:
- The right to lodge a complaint with a supervisory authority in accordance with Article 13 paragraph 2 (d) GDPR and Article 14 paragraph 2 (e) GDPR.
- Right of access in accordance with Article 15 GDPR
- Right to rectification in accordance with Article 16 GDPR
- Right to erasure („right to be forgotten“) in accordance with Article 17 GDPR
- Right to restriction of processing in accordance with Article 18 GDPR
- Right to data portability in accordance with Article 20 GDPR
- Right to objection in accordance with Article 21 GDPR
Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.
The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.
Security of Processing
- We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
- These security measures include in particular the encrypted transfer of data between your browser and our server.
Transfer of Data to Third Parties, Subcontractors and Third Party Providers
- A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
- If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
- If we use content, tools or other means from other companies (hereinafter collectively referred to as “third party providers“) whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.
Processing activities within the scope of our online service
Collection of Information on the Use of the Online Service
- When using our online-service, information may be transferred automatically from the browser of the user to us; this information includes the name of the accessed website, file, date and time of the access, amount of data transferred, notification about successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
- The processing of this information takes place based on legitimate interests in accordance with Article 6 paragraph 1 (f) GDPR (e.g. to optimize the online service) as well as to ensure the security of processing in accordance with Article 5 paragraph 1 (f) GDPR (e.g. for the defence and clarification purposes of cyberattacks)
- This information will be automatically deleted 30 days after the termination of the connection, unless any other retention periods require otherwise.
- The collection of the data and the storage of the data in log files is essential for the provision of the online service. Therefore users are not entitled to the options of erasure, objection or correction.
- Google acts on our behalf within the framework of order processing in accordance with Article 28 GDPR. We have concluded a data protection agreement with Google that contains the EU standard data protection clauses.
- We use Google Analytics with IP anonymization enabled.
- Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you during future website visits. 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, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
- The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 26 months. Other data remains stored in aggregated form indefinitely.
- For more information on data usage by Google, settings and revocation options, please visit Google’s websites:
https://policies.google.com/technologies/partner-sites?hl=en (“Data use by Google when you use our partners’ websites or apps”).
https://policies.google.com/technologies/ads (“Data use for advertising purposes”)
https://adssettings.google.com/authenticated (“Manage information Google uses to serve ads to you”).
Google Tag Manager
- We use the Google Tag Manager on our website. The Google Tag Manager is a service of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
- Through the Google Tag Manager, we can integrate various codes and services on our website in an orderly and simplified manner. The Google Tag Manager implements the tags or “triggers” the embedded tags. When a tag is triggered, Google may process information (including personal data) and process it. In doing so, it cannot be ruled out that Google also transmits the information to a server in a third country.
- In particular, the following personal data is processed by the Google Tag Manager:
- Online identifiers (including cookie identifiers).
- IP address
- In addition, you can find more detailed information about the Google Tag Manager on the websites https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/
as well as at
https://www.google.com/intl/de/policies/privacy/index.html (section “Data we receive based on your use of our services”).
- Furthermore, we have concluded an order processing contract with Google for the use of the Google Tag Manager (Art. 28 GDPR). Google processes the data on our behalf in order to trigger the stored tags and display the services on our website. Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google.
- If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation remains for all affected tracking tags that are integrated by the Google Tag Manager.
- By integrating the Google Tag Manager, we pursue the purpose of being able to carry out a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services.
- The legal basis for the processing of personal data described here as part of the measurement process is consent expressly granted by you in accordance with Art. 6 Para. 1 lit. a GDPR.
- The legal basis for the processing of those data that are processed in the context of obtaining consent is our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. We have a legitimate interest in being able to prove that you have given your consent to the measurement procedure (Art. 7 (1) GDPR).
Google Ad Services
- This website uses the remarketing or “similar target group” function of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
- You can be targeted with advertising by placing personalised and interest-based ads when you visit other websites in the so-called “Google Display Network”. “Google Remarketing” or the function “Similar target groups” uses so-called “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website. These text files are used to record your visits and anonymous data about the use of the website. Personal data will not be stored. If you visit another website in the so-called “Google Display Network”, you may see advertisements that most likely take into account product and information areas previously accessed on our website.
- The legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.
Google AdWords Conversion Tracking
- This website uses the “Google AdWords Conversion Tracking” function of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
- Google AdWords Conversion Tracking uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site when they click on a Google ad. The cookies are valid for a maximum of 90 days. Personal data will not be stored. As long as the cookie is valid, Google and we as website operators can recognisze that you clicked on an ad and reached a specific target page (e.g. order confirmation page, newsletter registration). These cookies cannot be tracked across multiple websites by different AdWords participants. The cookie creates conversion statistics in “Google AdWords”. These statistics record the number of users who clicked on one of our ads. It also counts how many users have reached a target page that has been provided with a “conversion tag”. However, the statistics do not contain any data with which you can be identified.
- The legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.
Facebook Pixel (Facebook Custom Audience)
- We use on our website Facebook Website Custom Audiences and have integrated the so-called Facebook pixel.
- This pixel is used to collect pseudonymous information about the use of this website (e.g. information about viewed content). The transmitted data of the pixel can be used to target you on Facebook with individualized advertising, provided you have a Facebook account.
- The legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.
Usercentrics Consent Management
- We process the following data in the process:
- Consent data or data of consent (anonymized log data (Consent ID, Processor ID, Controller ID), Consent Status, Timestamp).
- Device data (e.g. shortened IP addresses (IP v4, IP v6), device information, timestamp)
- User data (e.g. eMail, ID, browser information, SettingIDs, Changelog)
- The ConsentID (contains the above data), the Consent status incl. timestamp are stored in the local memory of your browser and simultaneously on the cloud servers used. Further processing will only take place if you submit a request for information or revoke your consent. In this case, the relevant information is provided to us in a compact data format in an easily readable text form for the purpose of data exchange (JSON file).
- No user information is stored for the statistics of the use of the granted or not granted consent. Only the frequency and locations of clicks are stored.
- The personal data is stored on a Google Cloud server located in the EU (Brussels, Belgium or Frankfurt am Main, Germany).
- The purpose of the data processing is the analysis and management of the consents granted, in order to comply with our obligation of a GDPR-compliant consent management. The use of Usercentrics serves the purpose of proving granted and non-granted consents as well as their management.
- The legal basis for the management of your consents for the processing of your personal data is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the legally secure documentation and verifiability of consents, the control of marketing measures on the basis of the consent granted as well as the optimization of consent rates.
- The data is deleted as soon as it is no longer required. The associated cookie has a term of 60 days. The revocation document of a previously granted consent is kept for a period of three years. The retention is based on the one hand on our accountability pursuant to Art. 5 para. (2) GDPR.
Processing for the purpose of carrying out our business processes
Participation in a European Citizens‘ Initiative (ECI)
- Fix The Status Quo OÜ (Harju maakond, Tallinn, Kristiine linnaosa, A. H. Tammsaare tee 47, 11316, Estonia) – hereinafter FTSQ – is providing us a form which is used for
- collecting data of ECI participants (Case 1) and
- collecting supporter data for lead generation and monitoring activity (Case 2).
- Case 1: We have therefore concluded an agreement on joint responsibility acc. to Art. 26 GDPR with Eurogroup for Animals (Rue Ducale 29, 1000 Brussels, Belgium firstname.lastname@example.org / email@example.com).
- Case 2: The data entered in the lead generation form is transferred directly to our Customer Relationship Management System (Salesforce).
Newsletter and email communication
- With the following information we inform you about the contents of our newsletter and email communication as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to the receipt and the described procedures.
As part of the registration for our newsletter and email communication, we obtain the consent of our supporters through a dedicated checkbox added in our various channels. The registrations for the newsletter and email communication are recorded for the fulfilment of legal obligations of proof. This includes the storage of the time of registration and confirmation as well as the IP address.
- Email tool
The newsletter and email communication is sent out by Salesforce Marketing Cloud (SFDC Netherlands BV, Gustav Mahlerlaan 2970, 1081 LA, Amsterdam; the Netherlands) – hereinafter referred to as “dispatch service provider”. The data protection regulations of the e-mail tool provider can be viewed here: https://www.salesforce.com/eu/company/privacy/
According to its own information, the e-mail tool provider can use this data in pseudonymous form – i.e. without allocation to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter and e-mail communication or for statistical purposes in order to determine from which countries the recipients come. However, the e-mail tool provider does not use the data of our newsletter recipients to contact themselves or to pass the data on to third parties.
- registration data
To register for the newsletter and email communication, you must enter your email address, title, first name and surname as well as to check the consent checkbox.
- statistical survey and analyses
The newsletters and email communication contain a so-called “web-beacon”, i.e. a pixel-sized file which is retrieved from the server of the email tool provider when the newsletter or email communication is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times.
The statistical surveys also include determining whether the newsletters and email communications are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is not our intention, nor that of the email tool provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
- legal bases
The use of the email tool provider, the performance of statistical surveys and analyses as well as the logging of the registration process shall be based on our legitimate interests in accordance with Article 6 (1) (f) GDPR. We are interested in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of our users.
You can cancel the receipt of our newsletter and email communication at any time, i.e. revoke your consent. You will find a link to opt out at the end of each newsletter and email communication. If the users have cancelled the newsletter or email communication reception, the personal data of the users processed for its dispatch will be deleted.
- Cookies are information transmitted by our web server or third-party web servers to the users’ web browsers where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
- In the case that users do not want that cookies are stored on their computer, they will be asked to disable the corresponding option in their browser’s system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.
Version: August 2022