Privacy Policy
Table of contents
- Objective and responsible entity
- Basic information on data processing
- Processing of personal data
- Collection of access data
- Use of cookies
- Google Analytics
- Google Re/Marketing Services
- Facebook Social Plugins
- Facebook Remarketing
- Twitter buttons
- Integration of third-party services and content
- Integration of online forms
- Web fonts
- User rights and deletion
- Changes to the privacy policy
1. Objective and responsible entity
This privacy policy clarifies the nature, scope, and purpose of the processing (including collection, processing, and use as well as obtaining consents) of personal data within our online offering and the associated websites, functions, and content (hereinafter collectively referred to as “online offering” or “website”). The privacy policy applies regardless of the domains, systems, platforms, and devices (e.g., desktop or mobile) on which the online offering is executed. The provider of the online offering and the data protection responsible entity is the VOLTERIO GmbH, owned by Dipl.-Ing. Christian Flechl, located at Stempfergasse 3/I, 8010 Graz, Austria (hereinafter referred to as “provider”, “we”, or “us”). For contact options, please refer to our imprint. The term “users” includes all customers and visitors to our online offering. The terms used, such as “users”, are to be understood in a gender-neutral manner.
2. Basic information on data processing
We process user’s personal data only in compliance with the relevant data protection regulations in accordance with the principles of data minimization and avoidance. This means that user data is only processed when there is a legal basis, in particular when the data is required to provide our contractual services and online services, or when there is a legal obligation or consent for processing.
We implement organizational, contractual, and technical security measures according to the state of the art to ensure compliance with the provisions of data protection laws and to protect the data processed by us against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.
If content, tools, or other means from other providers (hereinafter collectively referred to as “third-party providers”) are used within the scope of this privacy policy, and their stated location is outside the country, it is assumed that data is transferred to the domicile countries of the third-party providers. The transfer of data to third countries takes place either on the basis of a legal permission, user consent, or special contractual clauses ensuring the legally required security of the data.
3. Processing of personal data
In addition to the expressly stated uses in this privacy policy, personal data is processed for the following purposes based on legal permissions or user consent:
- Provision, execution, maintenance, optimization, and security of our services, service, and user performances
- Contact and allocation for possible inquiries
- Ensuring effective customer service and technical support.
We only transmit user data to third parties if necessary for billing purposes (e.g., to a payment service provider) or for other purposes necessary to fulfill our contractual obligations towards the users (e.g., address notification to suppliers). When contacting us (via contact form or email), the user’s details are stored for the purpose of processing the request and in case of follow-up questions. Personal data is deleted as soon as it has served its purpose and there are no legal retention obligations opposing its deletion.
4. Collection of access data
We collect data about every access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, amount of data transferred, message about successful access, browser type and version, the user’s operating system, referrer URL (previously visited page), IP address, and the requesting provider.
We use the log data without assignment to the person of the user or other profiling according to legal regulations only for statistical evaluations for the purpose of operation, security, and optimization of our online offer. However, we reserve the right to check the log data retrospectively if there is a justified suspicion of illegal use based on concrete evidence.
5. Use of cookies
“Cookies” are small files stored on users’ devices. Cookies can store different information. This information may include language settings on a website, login status, a shopping cart, or the position where a video was watched.
Cookies are usually also used when the interests of a user or their behavior (e.g., viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used to display content to users that corresponds to their potential interests. This process is also referred to as “tracking”, i.e., tracking the potential interests of users. The term “cookies” also includes other technologies that fulfill the same functions as cookies (e.g., if user data is stored using pseudonymous online identifiers, also referred to as “user IDs”).
If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy.
- Legal basis: The legal basis for processing your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies are based on our legitimate interests (e.g., in the economic operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.
- Revocation and objection (opt-out): Regardless of whether processing is based on consent or legal permission, you have the option to revoke consent or object to the processing of your data by cookie technologies at any time (collectively referred to as “opt-out”).
You can initially declare your objection using the settings of your browser, e.g., by deactivating the use of cookies (which may also restrict the functionality of our online offer).
An objection to the use of cookies for online marketing purposes can be made through 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/ or generally at http://optout.aboutads.info.
- Processing of cookie data based on consent: Before we process or have cookies processed as part of using cookies, we ask users for revocable consent. Before consent is given, only cookies that are necessary for the operation of our online offer are used. Their use is based on our interest and the interest of users in the expected functionality of our online offer.
Processed data types: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses). Data subjects: Users (e.g., website visitors, users of online services). Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
6. Google Analytics
These terms of use for Google Analytics (this “Agreement”) apply between Google Ireland Limited (“Google”) and the legal entity (hereinafter “you” or “your”) that signs this Agreement. The terms of use can be found here: https://marketingplatform.google.com/about/analytics/terms/de/
We use Google Analytics, a web analytics service provided by Google Ireland Limited (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is usually transmitted to a Google server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on activities within this online offering, and to provide us with other services related to the use of this online offering and internet usage. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with IP anonymization enabled. 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.
The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Further information on data use for advertising purposes by Google, settings, and objection options can be found on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use websites or apps of our partners”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.de/settings/ads (“Manage information Google uses to show you advertisements”), and http://www.google.com/ads/preferences (“Determine what advertising Google shows you”).
The data collected by this service is transferred to a third country (USA). Your express consent constitutes the legal basis for this data transfer in accordance with Art 49 para. 1 lit a in conjunction with Art 6 para. 1 lit a GDPR. Prior to obtaining your consent, we informed you that the USA currently does not have a level of data protection that corresponds to EU standards. For this reason, the European Court of Justice declared the “Privacy Shield” (Adequacy Decision pursuant to Art 45 GDPR) invalid in the Schrems II case.
7. Google Re/Marketing Services
We use the marketing and remarketing services (hereinafter “Google marketing services”) of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
Google marketing services allow us to display advertisements for and on our website in a more targeted manner, in order to present users with ads that potentially match their interests. For example, if users are shown ads for products they have previously been interested in on other websites, this is referred to as “remarketing”. For these purposes, when our and other websites where Google marketing services are active are accessed, Google runs code directly and embeds so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) into the website. These tags place an individual cookie, i.e., a small file, on the user’s device (instead of cookies, similar technologies can also be used). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com, or googleadservices.com. This file records which websites the user has visited, which content they are interested in, and which offers they have clicked on, as well as technical information about the browser and operating system, referring websites, visit time, and other information about the use of the online offering. The IP address of the user is also recorded, but we inform Google Analytics within the scope of Google Analytics that the IP address is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases will it be transmitted in full to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google offers. The information mentioned above may also be linked to such information from other sources. If the user subsequently visits other websites, they can be shown ads tailored to their interests accordingly.
User data is processed pseudonymously within the scope of Google marketing services. This means that Google stores and processes, for example, not the name or email address of the user but processes the relevant data cookie-related within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by “DoubleClick” about users is transmitted to Google and stored on Google’s servers in the USA.
One of the Google marketing services we use is the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies cannot thus be tracked through the websites of AdWords customers. The information obtained using the cookie is used to create conversion statistics for AdWords customers who have decided to use conversion tracking. AdWords customers find out the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that personally identifies users.
Based on the Google marketing service “DoubleClick”, we include third-party ads. DoubleClick uses cookies to enable Google and its partner websites to serve ads based on users’ visits to this website or other websites on the Internet. We also include third-party ads based on the Google marketing service “AdSense”. AdSense uses cookies to enable Google and its partner websites to serve ads based on users’ visits to this website or other websites on the Internet. Another Google marketing service we use is the “Google Tag Manager”, which enables additional Google analysis and marketing services to be integrated into our website (e.g., “AdWords”, “DoubleClick”, or “Google Analytics”).
For more information on Google’s data use for marketing purposes, please visit the overview page: https://www.google.com/policies/technologies/ads, and Google’s privacy policy is available at https://www.google.com/policies/privacy.
If you wish to opt-out of data collection by Google marketing services, you can use the settings and opt-out options provided by Google: http://www.google.com/ads/preferences.
The data collected by this service is transferred to a third country (USA). Your express consent constitutes the legal basis for this data transfer in accordance with Art 49 para. 1 lit a in conjunction with Art 6 para. 1 lit a GDPR. Prior to obtaining your consent, we informed you that the USA currently does not have a level of data protection that corresponds to EU standards. For this reason, the European Court of Justice declared the “Privacy Shield” (Adequacy Decision pursuant to Art 45 GDPR) invalid in the Schrems II case.
8. Facebook Social Plugins
Our online offering uses social plugins (“plugins”) from 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 be identified by one of the Facebook logos (white “f” on a blue tile, the terms “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
When a user accesses a function of this online offering that contains such a plugin, their device establishes a direct connection to Facebook’s servers. The content of the plugin is transmitted directly from Facebook to the user’s device and integrated into the online offering. This allows usage profiles to be created from the processed data. Therefore, we have no influence on the extent of data that Facebook collects using this plugin and inform users to the best of our knowledge.
By integrating the plugins, Facebook receives information that a user has accessed the corresponding page of the online offering. If the user is logged into Facebook, Facebook can assign the visit to their Facebook account. If users interact with the plugins, for example by pressing the Like button or leaving a comment, the corresponding information is transmitted directly from their device to Facebook and stored there. Even if a user is not a member of Facebook, there is still the possibility that Facebook will learn and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.
The purpose and scope of data collection and the further processing and use of the data by Facebook, as well as the relevant rights and privacy settings of the users, can be found in Facebook’s privacy policy: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about them via this online offering and link it to their stored member data on Facebook, they must log out of Facebook before using our online offering and delete their cookies. Further settings and objections to the use of data for advertising purposes can be made within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. These settings are platform-independent, i.e., they are applied to all devices, such as desktop computers or mobile devices.
9. Facebook Remarketing
Within our online offering, so-called “Facebook pixels” from the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ( “Facebook”), are used. With the help of the Facebook pixel, Facebook is able to determine the visitors to our offering as a target group for the display of ads, so-called “Facebook ads”. Accordingly, we use the Facebook pixel to display Facebook ads only to Facebook users who have also shown an interest in our internet offering. That is, with the help of the Facebook pixel, we want to ensure that our Facebook ads correspond to the potential interests of users and do not appear annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were redirected to our website after clicking on a Facebook ad.
The Facebook pixel is immediately integrated by Facebook when our web pages are called up and can store a so-called cookie, i.e., a small file, on your device. If you then log into Facebook or visit Facebook while logged in, your visit to our offering will be noted in your profile. The data collected about you is anonymous to us, so it does not provide us with any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible. The processing of the data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, you can find further information on the functioning of the remarketing pixel and generally on the display of Facebook ads in Facebook’s data usage policy: https://www.facebook.com/policy.php.
You can object to the collection by the Facebook pixel and the use of your data for the display of Facebook ads. To do this, you can visit the page set up by Facebook and follow the instructions on usage-based advertising settings: https://www.facebook.com/settings?tab=ads or object via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. The settings are platform-independent, i.e., they are applied to all devices, such as desktop computers or mobile devices.
10. Twitter buttons
We use the buttons of the Twitter service. These buttons are offered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. They can be identified by terms such as “Twitter” or “Follow” or associated with a stylized blue bird. With the help of the buttons, it is possible to share a post or webpage of this online offering on Twitter or to follow the provider on Twitter.
When a user accesses a webpage of this online offering that contains such a button, their browser establishes a direct connection to Twitter’s servers. The content of the Twitter buttons is transmitted directly from Twitter to the user’s browser. Therefore, we have no influence on the extent of data that Twitter collects using this plugin and inform users to the best of our knowledge. According to this, only the user’s IP address and the URL of the respective webpage are transmitted to Twitter when the button is accessed, but not used for other purposes than displaying the button. Further information on this can be found in Twitter’s privacy policy at http://twitter.com/privacy.
11. Integration of Third-Party Services and Content
It may happen that within our online offering, content or services from third-party providers, such as maps or fonts from other websites, are integrated. The integration of third-party content always requires that the third-party providers perceive the IP address of the users, since they would not be able to send the content to the users’ browsers without the IP address. The IP address is therefore required for the presentation of this content. Furthermore, the providers of third-party content may set their own cookies and process the data of users for their own purposes. Usage profiles can be created from the processed data. We will use this content as data-sparingly and data-avoidant as possible and choose reliable third-party providers with regard to data security.
The following presentation provides an overview of third-party providers and their content, along with links to their privacy policies, which contain further information on data processing and, in some cases, opt-out options:
- External Fonts from Google Fonts: The integration of Google Fonts is done by making a server call to Google, usually in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
- Maps from the “Google Maps” service by Google Inc.: Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
- Videos from the “YouTube” platform by Google Inc.: Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
12. Integration of Online Forms
Online forms are provided by our service provider WSForms. The data is forwarded to the servers of WSForms for the purpose of transmission and processing. Westguard Solutions operates this Internet portal, and there is an agreement for order data processing in place.
13. Web Fonts
- Font Awesome: We process connection data and browser data with our order processor Fontawesome, Fonticons, Inc., for the purpose of providing the fonts required by the web browser to display the website. Details can be found in Fontawesome’s privacy policy.
- Google Fonts: We process connection data and browser data with our order processor Google Fonts, Google Ireland Limited, for the purpose of providing the fonts required by the web browser to display the website. Details can be found in Google Fonts’ privacy policy and FAQs.
- Adobe Fonts: We process connection data and browser data with our order processor Adobe Systems Software Ireland Limited, for the purpose of providing the fonts required by the web browser to display the website. Details can be found in Adobe Systems Software Ireland Limited’s privacy policy and FAQs.
14. User Rights and Data Deletion
Users have the right to request free information about the personal data stored by us about them. They also have the right to correct incorrect data, revoke consent, block and delete their personal data, and, in the event of a belief of unlawful data processing, to lodge a complaint with the competent supervisory authority.
The data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention obligations to the contrary.
15. Changes to the Privacy Policy
We reserve the right to change the privacy policy to adapt it to changed legal situations or changes to the service and data processing. Users are requested to regularly inform themselves about the content of the privacy policy.
Date: September 8, 2022