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Privacy Policy

This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and its related websites, functions and content, as well as external online presences, such as our social media profiles (hereafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller

First name, last name / company name: Schnirchgasse 9-9A GmbH & Co KG
Street Building No.: Trabrennstrasse 2b
Postal code City Country: 1020 Vienna, Austria
Email address: datenschutz@soravia.at
Managing Director / Owner: DI Alois Aigner; Ing. Bernhard Ebner
Link to the legal notice: https://triiiple.at/impressum/
Contact at the central data protection office: datenschutz@soravia.at

Types of processed data:

  • Inventory data
  • Contact details
  • Content data
  • Usage data
  • Meta-/communication data

Categories of data subjects

Visitors and users of the online offer (hereinafter we also refer to the data subjects as “users”).

Purpose of the processing

  • Provision of the online offer, its functions and contents.
  • Answering contact requests and communicating with users.
  • Safety measures.
  • Reach measurement/Marketing

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, if he can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term is far-reaching and includes virtually every handling of data.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, if such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.

“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to analyze or predict certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.

“Controller” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.

“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis is mentioned in the privacy policy, the following applies: the legal basis for obtaining consent is Article 6 (1) (a) and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) (b) GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) (c) GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) (f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.

Security measures

In accordance with Art. 32 GDPR, we take suitable technical and organizational measures to ensure a level of protection appropriate to the risk, taking into consideration the state of technology, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood of occurrence and severity of the risk to the rights and freedoms of natural persons.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the exercise of data subjects’ rights, deletion of data, and to guarantee response to data vulnerability. Furthermore, we consider the protection of personal data already during the development or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).

Collaboration with contract processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (contractor processors or third parties), transmit data to them or otherwise grant access to the data, this will be done only on the basis of legal permission (e.g. in case of transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to this, it is required by a legal obligation or based on our legitimate interests (e.g. the use of agents, webhosting services, etc.).

If we commission third parties with the processing of data on the basis of a so-called “contract processing agreement”, this will be done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will be done only in order to fulfill our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special conditions of Art. 44 et seq. GDPR are present. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized level of data protection (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contract clauses”).

Rights of data subjects

You have the right to ask for confirmation as to whether the data in question are being processed and for information about these data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR, you have the right to demand completion of the data relating to you or the rectification of incorrect data relating to you.

In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to demand that a restriction be placed on the processing of the data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other controllers.

Furthermore, in accordance with Art. 77 GDPR, you have the right to file a complaint with the competent supervisory authority.

Right of revocation

You have the right to grant consent in accordance with. Art. 7 (3) GDPR with effect for the future.

Right to object

You can object to the future processing of your data at any time in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.

Cookies and the right to object to direct mail

Cookies are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, called “session cookies” or “transient cookies” are cookies that are deleted after a user leaves an online offer and closes his browser. Information such as the content of a shopping cart in an online shop or a login status can be saved in such a cookie. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. For example, the login status can be saved if users visit the website it after several days. Likewise, the interests of the users, which are used for range measurement or marketing purposes, can be stored in such a cookie. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, these are called “first-party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their computer, they will be asked to disable the corresponding option in their browser’s system settings. 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.

A general objection to the use of cookies used for online marketing purposes can be declared on a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. The storage of cookies can also be prevented by deactivating them in the browser settings. Please note that it may subsequently not be possible to use all features of this online offer.

Deletion of data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data are deleted because they is required for other and legally permitted purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.

According to legal regulations in Austria, storage takes place in particular for 7 years according to Art. 132 (1) BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.

Business-related processing

In addition, we process

  • Contract data (e.g., subject matter, term, customer category).
  • Payment data (e.g., bank details, payment history)

of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Brokerage services

We process the data of our customers, clients and prospects (collectively referred to as “customers”) in accordance with Art. 6 (1) (b) GDPR in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying mandate. In principle, this includes inventory and master data of the customer (name, address, etc.), as well as the contact data (email address, telephone, etc.), the contractual data (content of the instruction, fees, terms, information about the companies/insurers/services) and payment data (commissions, payment history, etc.). We may also process information about the characteristics and circumstances of persons or things belonging to them, if this is part of our order. This can be, for example, information about personal living conditions, movable property or real estate.
As part of our instruction, it may also be necessary for us to process special categories of data in accordance with Art. 9 (1) GDPR, in this case, in particular, information about a person’s health. If necessary, in accordance Art. 6 (1) (a), Art. 7, Art. 9 (2) (a) GDPR, we obtain the explicit consent of the customer for this.
If required for the fulfillment of the contract or as required by law, we disclose or transmit the customers’ data in the context of coverage inquiries, conclusion and processing of contractual data to providers of brokered services/facilities, insurers, reinsurers, brokerage pools, technical service providers, other service providers, such as cooperative associations, as well as financial service providers, lending institutions and capital investment companies as well as social insurance funds, tax authorities, tax consultants, legal advisers, auditors, insurance ombudsmen and institutions of the Federal Financial Supervisory Authority (BaFin). We can also hire subcontractors, e.g. sub-brokers. We obtain the consent of the customer, if this is required for the disclosure/transmission of the consent of the customer (which may be the case, for example, in the case of special categories of data according to Art. 9 GDPR).
The deletion of the data takes place after expiration of statutory warranty and comparable obligations, whereby the need to store the data is checked every three years; otherwise, the statutory storage obligations apply.
In the case of legal archiving obligations, deletion takes place after their expiration. In particular, according to German law in the insurance and finance industry, records must be kept for 5 years, broker notes for 7 years and broker contracts for 5 years and generally 6 years for documents relevant for commercial law and 10 years for tax-relevant documents.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The bases for the processing are Art. 6 (1) (c) GDPR, Art. 6 (1) (f) GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose of and interest in processing lies in administration, financial accounting, office organization, data archiving, i.e. tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.

In doing so, we disclose or transmit data to the tax office, consultants, such as tax accountants or auditors, as well as other payment agents and payment service providers.

Furthermore, we store information on suppliers, promoters and other business partners on the basis of our business interests, e.g. for the purpose of contacting you at a later date. We generally store these data, most of which are company-related, on a permanent basis.

Contact

When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the user to process the contact request and to complete it will be processed in accordance with Art. 6 (1) (b) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or a comparable system for organizing inquiries.

We will delete the inquiries if they are no longer required. We will check whether they are still needed every two years; the legal archiving obligations will continue to apply.

Hosting and emailing

The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, emailing, security and technical maintenance services we use to operate this online service.

This involves us or our hosting provider processing inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing agreement).

Collection of access data and log files

On the basis of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, we or our hosting provider collect data on each access to the server on which this service is located (so-called server log files). The access data include the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the incident in question.

Bugsnag

We include the software “Bugsnag Inc.”, 939 Harrison St, San Francisco, CA 94107, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Google Tag Manager

Google Tag Manager is a solution that allows us to manage so-called website tags through a single interface (including integrating Google Analytics and other Google marketing services into our online offering). Tag Manager itself (which implements the tags) does not process users’ personal data. With regard to the processing of users’ personal data, we refer to the following information about Google’s services. Use Policy: https://www.google.com/intl/en/tagmanager/use-policy.html.

Google Analytics

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

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

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 related to the use of this online offer and internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with IP anonymization activated. This means that the users’ IP addresses will be shortened by Google within member states of the European Union or in other states that are parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

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

For more information about Google’s data usage, settings and objection options, please read Google’s Privacy Policy (https://policies.google.com/technologies/ads), as well as the settings for displaying pop-up ads by Google (https://adssettings.google.com/authenticated).

The personal data of users will be deleted or anonymized after 14 months.

Google AdWords and conversion measurement

We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online service within the meaning of Art. 6 (1) (f) GDPR), USA, (“Google”).

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use Google’s online marketing tool “AdWords” to place ads on the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offering in a more targeted manner, so that we only present ads to users that potentially match their interests. For example, if a user sees ads for products he or she has been looking for on other online offerings, that’s called “remarketing”. For these purposes, upon access to our and other websites where the Google Advertising Network is active, Google will immediately execute a code from Google and incorporate (re)marketing tags (invisible graphics or code, also known as “web beacons”) into the website. With their help, the user can store an individual cookie, i.e. a small file (instead of cookies, comparable technologies can also be used). This file notes which websites the user visited, what content he is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visit time and other information on the use of the online offer.

Furthermore, we receive an individual “conversion cookie”. The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive any information that personally identifies users.

The data of the users are pseudonymously processed within the Google advertising network. This means that, for example, Google does not store and process users’ names or email addresses but processes the relevant data in a cookie-related manner within pseudonymous user profiles. This means that, from Google’s perspective, the ads are not managed and displayed to a specifically identified person but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.

For more information about Google’s data usage, settings and objection options, please read Google’s Privacy Policy (https://policies.google.com/technologies/ads), as well as the settings for displaying pop-up ads by Google (https://adssettings.google.com/authenticated).

Facebook Pixels, Custom Audiences and Facebook Conversion

Due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes, the “Facebook Pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”), is placed within our online offer.

Facebook is certified under the Privacy Shield Agreement, which provides a guarantee or compliance with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook pixel, it is possible for Facebook to determine the users of our online offer as a target group for displaying ads (“Facebook Ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads we have been sent only to those Facebook users who have shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products determined based on the websites visited by them), which we transmit to Facebook (“Custom Audiences”). With the aid of the Facebook Pixel, we also want to make sure that our Facebook Ads are in line with the potential interest of users and are not annoying. With the aid of the Facebook Pixel, we can also understand the effectiveness of the Facebook Ads for statistical and market research purposes, as it lets us see whether users were redirected to our website after clicking on a Facebook Ad (“Conversion”).

The processing of the data by Facebook is part of Facebook’s Data Use Policy. Accordingly, you can find general notes on the display of Facebook Ads, in Facebook’s Data Use Policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook Pixel and how it works, visit the help section of Facebook: https://www.facebook.com/business/help/651294705016616.

You may object to the data recording by the Facebook Pixel and use of your data to display Facebook Ads. To set which types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions for the use-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they can be applied for all devices, such as desktop computers or mobile devices.

You may also opt out of the use of cookies for reach measurement and promotional purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and in addition the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

Online presence in social media

We maintain an online presence in social networks and platforms in order to communicate with customers, prospects and users who are active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing policies apply to their respective operators.

Unless otherwise stated in our Privacy Policy, we process the users’ data insosfar as they communicate with us within the social networks and platforms, e.g. write articles on our online presence or send us messages.

Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) (f) GDPR), we make use of content or services offered by third-party providers in order to integrate their content and services such as videos or fonts (collectively referred to as “content”).

This always presupposes that the third-party providers of this content know the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for displaying this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to 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 may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.

YouTube

We embed the videos on the YouTube platform of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Google Fonts

We incorporate the fonts (“Google Fonts”) provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Google Maps

We include maps from the Google Maps service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, users’ IP addresses and location data, but these are not collected without their consent (usually as part of the settings on their mobile devices). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Sharing features of AddThis

Within our online offer, the service “AddThis” (1595 Spring Hill Suite 300 Vienna, VA 22182, USA) is used to share the contents of this online offer in social networks (sharing).

The use takes place on the basis of our legitimate interests, i.e. interest in a distribution of our online offer according to Art. 6 (1) (f) GDPR.

AddThis uses the personal information of the users for the provision and execution of the sharing functions. In addition, AddThis may use users’ pseudonymous information for marketing purposes. These data are collected using “cookie” text files stored on the user’s computer. Privacy policy: http://www.addthis.com/privacy, Opt-out: http://www.addthis.com/privacy/opt-out.