Privacy Policy

Declaration on the obligation to inform

In the following data protection declaration, we inform you about the most important aspects of data processing within the scope of our website. We collect and process personal data only on the basis of the legal provisions (General Data Protection Regulation, E-Commerce Act & Media Act). As soon as you access or visit our website as a user, your IP address, as well as the beginning and end of the session is recorded. This is for technical reasons and therefore constitutes a legitimate interest within the meaning of Art. 6 Para. 1 Lit F DSGVO.

Right of information & revocation

You have the right at any time, free of charge and without delay, to inquire about the data collected about you. Likewise, you can revoke your consent to the use of your provided personal data with effect for the future. For this purpose, please contact the service provider indicated in the imprint.

General

When you access our website, general information (so-called server log files) is automatically collected. These include, among other things, the web browser you are using as well as your operating system and your Internet service provider. This data does not allow any conclusions to be drawn about your person and is statistically evaluated by us in order to improve our website technically and in terms of content. The collection of this information is necessary in order to be able to deliver the content of the website correctly.

The use of the website is generally possible without providing personal data. As far as personal data (e.g. name, address or e-mail addresses) are collected, this is always done, as far as possible, on a voluntary basis. This data will not be passed on to third parties without your express consent.

If a contractual relationship is to be established, the content of which is to be developed or changed, or if you send us an inquiry, we collect and use personal data from you insofar as this is necessary for this purpose (inventory data). We collect, process and use personal data to the extent necessary to enable you to use the website (usage data). All personal data will only be stored as long as it is necessary for the stated purpose (processing your request or processing a contract). In this context, we take into account retention periods under tax and commercial law. By order of the competent authorities, we must provide information about this data (inventory data) in individual cases, insofar as this is necessary for the purposes of criminal prosecution, to avert danger, to fulfill the legal tasks of the constitution protection authorities or the Military Counter-Intelligence Service or to enforce intellectual property rights.

We expressly point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. It is not possible to provide complete protection against access to data.

The use of contact data published within the framework of the imprint obligation by third parties for the purpose of sending advertising and information material not expressly requested is hereby expressly prohibited. Excepted from this are existing business relationships or you have a corresponding consent from us.

The providers and all third parties mentioned on this website expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information. The same applies to the commercial use and dissemination of data.

Scope of application

This data protection declaration applies to all personal data processed by us within the company and to all personal data processed by companies commissioned by us (order processors). By personal data, we mean information within the meaning of Art. 4 No. 1 DSGVO, such as a person’s name, e-mail address and postal address. The processing of personal data ensures that we can offer and invoice our services and products, whether online or offline. The scope of this privacy policy includes:

• • all online presences (websites, online stores) that we operate
  • social media presences and email communications
  • mobile apps for smartphones and other devices

In short, the data protection declaration applies to all areas in which personal data is processed in the company via the aforementioned channels in a structured manner. If we enter into legal relationships with you outside of these channels, we will inform you separately if necessary.

Legal basis

In the following privacy statement, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
As far as EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016, which you can of course read online on EUR-Lex, the access to EU law, at https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

1. 1. Consent (Article 6(1)(a) DSGVO): You have given us your consent to process data for a specific purpose. An example would be the storage of your entered data of a contact form.
   2. Contract (Article 6(1) lit. b DSGVO): In order to fulfill a contract or pre-contractual obligations with you, we process your data. For example, if we conclude a purchase contract with you, we need personal information in advance.
   3. Legal obligation (Article 6(1)(c) DSGVO): If we are subject to a legal obligation, we process your data. For example, we are legally obliged to keep invoices for accounting purposes. These usually contain personal data.
   4. Legitimate interests (Article 6(1)(f) DSGVO): In the case of legitimate interests that do not restrict your fundamental rights, we reserve the right to process personal data. For example, we need to process certain data in order to operate our website in a secure and economically efficient manner. This processing is therefore a legitimate interest.

Other conditions, such as the performance of recordings in the public interest and the exercise of official authority, as well as the protection of vital interests, do not generally arise for us. If such a legal basis should nevertheless be relevant, it will be indicated at the appropriate place.

In addition to the EU Regulation, national laws also apply:

In Austria, this is the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act), or DSG for short.

Contact details of the responsible person

If you have any questions about data protection or the processing of personal data, you will find the contact details of the responsible person or body below:

TOWELINO e.U.
David Slavik
Seitenstettengasse 5/37, 1010 Vienna, Austria
Authorized to represent: David Slavik
E-Mail: [email protected]
Phone: +43 681 812 72 279
Imprint: https://www.towelino.at/impressum/

Rights according to the General Data Protection Regulation

According to Article 13, 14 DSGVO we inform you about the following rights you have to ensure a fair and transparent processing of data:

• According to Article 15 DSGVO, you have the right to information about whether we process data from you. If this is the case, you have the right to receive a copy of the data and to know the following information:
  • For what purpose we are processing;
  • the categories, i.e. the types of data that are processed;
  • who receives this data and if the data is transferred to third countries, how security can be guaranteed;
  • how long the data will be stored;
    the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
  • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
  • The origin of the data if we have not collected it from you;
  • Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
• You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
  You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
• According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
• According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
• According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
  • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
  • If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
  • If data is used to carry out profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
• According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
• You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

In short, you have rights – do not hesitate to contact the responsible party listed above with us!

If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. The following local data protection authority is responsible for our company:

Austria Data Protection Authority

Address: Barichgasse 40-42, 1030 Vienna, Austria.
Telephone number: +43 1 52 152-0
E-mail address: [email protected]
Website: https://www.dsb.gv.at/

Cookies

Storage period of cookies

The storage period depends on the respective cookie and is specified further below. Some cookies are deleted after less than an hour, others can remain stored on a computer for several years.
You can also influence the storage period yourself. You can manually delete all cookies at any time via your browser (see also “Right to object” below). Furthermore, cookies that are based on consent will be deleted at the latest after revocation of your consent, whereby the legality of the storage remains unaffected until then.

Right of objection – how can I delete cookies?

You decide how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option to delete, disable or only partially allow cookies. For example, you can block third-party cookies but allow all other cookies.
If you want to find out which cookies have been stored in your browser, if you want to change or delete cookie settings, you can find it in your browser settings:

1. 1. Chrome: Delete, enable and manage cookies in Chrome.
   2. Safari: Manage cookies and website data with Safari.
   3. Firefox: Delete cookies to remove data that websites have placed on your computer
   4. Internet Explorer: delete and manage cookies
   5. Microsoft Edge: delete and manage cookies

If you generally don’t want cookies, you can set your browser to notify you whenever a cookie is about to be set. This way, you can decide for each cookie whether to allow it or not. The procedure varies depending on the browser. It is best to search for the instructions in Google using the search term “delete cookies Chrome” or “disable cookies Chrome” in the case of a Chrome browser.

Legal basis

Since 2009, there are the so-called “Cookie Guidelines”. This states that the storage of cookies requires your consent (Article 6 (1) a DSGVO). Within the EU countries, however, there are still very different reactions to these directives. In Austria, however, this directive was implemented in Section 96 (3) of the Telecommunications Act (TKG).
For absolutely necessary cookies, even if there is no consent, there are legitimate interests (Article 6 (1) (f) DSGVO), which in most cases are of an economic nature. We want to provide visitors to the website with a pleasant user experience and for this purpose certain cookies are often absolutely necessary.
Insofar as cookies that are not absolutely necessary are used, this is only done in the case of your consent. The legal basis in this respect is Art. 6 para. 1 lit. a DSGVO.

Web analytics

We use software on our website to evaluate the behavior of website visitors, called web analytics for short. This involves collecting data that the respective analytic tool provider (also called tracking tool) stores, manages and processes. The data is used to create analyses of user behavior on our website and made available to us as the website operator. In addition, most tools offer various testing options. For example, we can test which offers or content are best received by our visitors. To do this, we show you two different offers for a limited period of time. After the test (so-called A/B test), we know which product or content our website visitors find more interesting. For such test procedures, as for other analytics procedures, user profiles may also be created and the data stored in cookies.

Duration of data processing

We will inform you about the duration of data processing below, provided we have further information on this. In general, we process personal data only as long as it is strictly necessary for the provision of our services and products. If it is required by law, as in the case of accounting, for example, this storage period may also be exceeded.
Right of objection

You also have the right and the possibility to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, disabling or deleting cookies in your browser.

Legal basis

The use of web analytics requires your consent, which we have obtained with our cookie popup. According to Art. 6 (1) lit. a DSGVO (consent), this consent constitutes the legal basis for the processing of personal data, as may occur during the collection by web analytics tools.

In addition to consent, there is a legitimate interest on our part to analyze the behavior of website visitors and thus to improve our offer technically and economically. With the help of web analytics, we detect website errors, can identify attacks and improve the economic efficiency. The legal basis for this is Art. 6 para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use the tools insofar as you have given your consent.

Since web analytics tools use cookies, we also recommend that you read our general privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy statements of the respective tools.

Google Analytics

On our website, we use the analysis tracking tool Google Analytics (GA) of the American company Google Inc. For the European area, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. Google Analytics collects data about your actions on our website. For example, when you click on a link, this action is stored in a cookie and sent to Google Analytics. Using the reports we receive from Google Analytics, we can better tailor our website and service to your preferences. In the following, we will go into more detail about the tracking tool and, in particular, inform you about what data is stored and how you can prevent this.

Google Analytics is a tracking tool used to analyze traffic to our website. In order for Google Analytics to work, a tracking code is built into the code of our website. When you visit our website, this code records various actions you take on our website. Once you leave our website, this data is sent to Google Analytics servers and stored there.

Google processes the data and we receive reports about your user behavior. These reports may include, but are not limited to, the following:

• • Audience reports: through audience reports, we get to know our users better and know more precisely who is interested in our service.
  • Ad reports: Ad reports help us analyze and improve our online advertising.
  • Acquisition reports: Acquisition reports give us helpful information on how to attract more people to our service.
  • Behavior reports: This is where we learn how you interact with our website. We can track the path you take on our site and which links you click.
  • Conversion reports: Conversion is when you take a desired action based on a marketing message. For example, you go from being a mere website visitor to a buyer or newsletter subscriber. These reports help us learn more about how our marketing efforts are working for you. This is how we aim to increase our conversion rate.
  • Real-time reports: Here we always know immediately what is happening on our website. For example, we can see how many users are currently reading this text.

What data is stored by Google Analytics?

Google Analytics uses a tracking code to create a random, unique ID that is linked to your browser cookie. This is how Google Analytics recognizes you as a new user. The next time you visit our site, you will be recognized as a “returning” user. All collected data is stored together with this user ID. This makes it possible to evaluate pseudonymous user profiles.

In order to analyze our website with Google Analytics, a property ID must be inserted into the tracking code. The data is then stored in the corresponding property. For each newly created property, the Google Analytics 4 property is standard. Alternatively, you can also create the Universal Analytics property. Depending on the property used, data is stored for different lengths of time.

Labels such as cookies and app instance IDs are used to measure your interactions on our website. Interactions are all types of actions you take on our website. If you also use other Google systems (such as a Google account), data generated through Google Analytics may be linked to third-party cookies. Google does not share Google Analytics data unless we, as the website operator, authorize it. Exceptions may occur if required by law.

How long and where is the data stored?

Google has their servers located all over the world. Most servers are located in America and consequently your data is mostly stored on American servers. You can read exactly where Google’s data centers are located here: https://www.google.com/about/datacenters/locations/?hl=de

Your data is distributed on different physical disks. This has the advantage that the data can be accessed more quickly and is better protected against manipulation. In each Google data center, there are corresponding emergency programs for your data. If, for example, the hardware at Google fails or natural disasters paralyze servers, the risk of a service interruption at Google still remains low.

The retention period of the data depends on the properties used. When using the newer Google Analytics 4 properties, the retention period of your user data is fixed at 14 months. For other so-called event data, we have the option to choose a retention period of 2 months or 14 months.

For Universal Analytics properties, Google Analytics defaults to a retention period of 26 months for your user data. Then your user data is deleted. However, we have the option to choose the retention period of user data ourselves. We have five variants available for this purpose:

• • Deletion after 14 months
  • Deletion after 26 months
  • Deletion after 38 months
  • Deletion after 50 months
  • No automatic deletion

In addition, there is also an option for data to be deleted only when you no longer visit our website within the time period we have selected. In this case, the retention period will be reset each time you visit our website again within the specified period.

Once the specified period has expired, the data is deleted once a month. This retention period applies to your data associated with cookies, user recognition and advertising IDs (e.g. DoubleClick domain cookies). Reporting results are based on aggregated data and are stored separately from user data. Aggregated data is a merging of individual data into a larger unit.

How can I delete my data or prevent data storage?

According to European Union data protection law, you have the right to obtain information about your data, update it, delete it or restrict it. Using the browser add-on to disable Google Analytics JavaScript (ga.js, analytics.js, dc.js), you can prevent Google Analytics from using your data. You can download and install the browser add-on at https://tools.google.com/dlpage/gaoptout?hl=de. Please note that this add-on only disables the collection of data by Google Analytics.

If you generally want to deactivate, delete or manage cookies, you will find the relevant links to the respective instructions for the most popular browsers under the section “Cookies”.

Legal basis

The use of Google Analytics requires your consent, which we have obtained with our cookie popup. According to Art. 6 (1) lit. a DSGVO (consent), this consent constitutes the legal basis for the processing of personal data, as may occur during the collection by web analytics tools.

In addition to consent, there is a legitimate interest on our part to analyze the behavior of website visitors and thus to improve our offer technically and economically. With the help of Google Analytics, we detect website errors, can identify attacks and improve the economic efficiency. The legal basis for this is Art. 6 para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use Google Analytics if you have given your consent.

Google also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks to the legality and security of data processing.

As a basis for data processing at recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular in the USA) or a data transfer there, Google uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through these clauses, Google undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the US. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

The Google Ads Data Processing Terms, which refer to the standard contractual clauses, can be found at https://business.safety.google/intl/de/adsprocessorterms/.

We hope we have been able to provide you with the most important information regarding Google Analytics data processing. If you want to learn more about the tracking service, we recommend these two links: https://marketingplatform.google.com/about/analytics/terms/de/ and https://support.google.com/analytics/answer/6004245?hl=de.

Comment function

In the context of the comment function of our blog, as well as in the evaluation of our products, we collect personal data (e.g. name, e-mail) in the context of your comment on a post only to the extent that you have provided it to us. When publishing a comment, the email address you provide will be stored but not published. Your given name will be published. You can also use a pseudonym.

This text was created using, among others, the data protection generator of AdSimple and that of HENSCHE Rechtsanwälte.