Data Privacy Policy

Protecting your personal data is important to us. Therefore, we process your data exclusively on the basis of legal regulations (GDPR, TKG 2021). In this privacy policy, we inform you about the most important aspects of data processing in our company.

This privacy policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as "data") within our offer and the associated websites, functions, and content as well as external online presences, such as our social media profiles (hereinafter 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
Managing Director/Owner: Michael Laussegger, MSc A dedicated data protection officer has not been appointed because our core activities do not include large-scale processing of special categories of data or systematic, comprehensive monitoring of data subjects.

Types of processed data:

Inventory data (e.g., names, addresses).
Contact details (e.g., email, phone numbers).
Content data (e.g., text input, photographs, videos).
Usage data (e.g., visited websites, interest in content, access times).
Meta/communication data (e.g., device information, IP addresses). Categories of data subjects

Visitors and users of the online offer (Hereinafter, we also collectively refer to the affected persons as "users"). Purpose of processing

Provision of the online offer, its functions, and content.
Optimization of products and services.
Responding to contact inquiries and communicating with users.
Security measures.
Reach measurement/marketing

Terms used

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data.

"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

The "controller" is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

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

Relevant legal bases

In accordance with Article 13 of the GDPR, we inform you of the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR, the legal basis for processing for the performance of our services and the execution of contractual measures as well as for responding to inquiries is Art. 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Art. 6(1)(f) GDPR. In the event that the 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 Article 32 of the GDPR, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as the access, input, disclosure, availability, and separation thereof. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and the response to data threats. We also consider the protection of personal data in the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR).

Cooperation with processors and third parties

If we disclose, transmit, or otherwise grant access to data to other persons and companies (processors or third parties) as part of our processing, this is done only on the basis of legal permission (e.g., if data transmission to third parties, such as payment service providers, is required for the performance of the contract pursuant to Art. 6(1)(b) GDPR), if you have consented, if a legal obligation provides for this, or based on our legitimate interests (e.g., when using agents, web hosts, etc.).

If we engage third parties to process data on the basis of a so-called "data processing agreement", this is 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 if this occurs in the context of using the services of third parties or disclosing or transferring data to third parties, this will only take place if it is necessary to fulfill our (pre-)contractual obligations, on the basis of your consent, a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means, for example, that processing is carried out on the basis of special guarantees, such as the officially recognized determination of an adequate level of data protection equivalent to that of the EU or compliance with officially recognized special contractual obligations (so-called "Standard Contractual Clauses (SCCs)") coupled with supplementary technical and organizational measures.

Rights of data subjects

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

You have the right, in accordance with Art. 16 GDPR, to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the data concerned be deleted without delay, or alternatively, in accordance with Art. 18 GDPR, to demand that the processing of the data be restricted.

You have the right, in accordance with Art. 20 GDPR, to receive the data concerning you that you have provided to us and to request its transmission to other controllers.

Furthermore, pursuant to Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.

Right to revoke consent

You have the right to revoke consent already given pursuant to Art. 7(3) GDPR with effect for the future

Right to object

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

Cookies and objection rights in direct marketing

"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 information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be stored. Cookies are referred to as "permanent" or "persistent" if they remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of users can also be stored in such a cookie, which is used for audience measurement or marketing purposes. Cookies that are offered by providers other than the controller who operates the online offer are referred to as "third-party cookies" (otherwise, if they are only the controller's cookies, they are referred to as "first-party cookies").

We can use temporary and permanent cookies and inform you about this within the framework of our privacy policy.

If users do not want cookies that are not technically essential to be stored on their computer, they are asked to use our cookie management banner to manage their consent, or deactivate the corresponding option in the system settings of their browser. Stored 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 for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case, not all functions of this online offer can be used.

Deletion of data

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.

According to legal requirements in Austria, the storage is carried out in particular for 7 years in accordance with § 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 provided services, telecommunications, radio, and television services, which are 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 of the contract, term, customer category).
Payment data (e.g., bank details, payment history) of our customers, interested parties, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

Order processing in the online shop and customer account

We process the data of our customers as part of the ordering process in our online shop to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

The data processed include inventory data, communication data, contract data, payment data, and the persons affected by the processing include our customers, interested parties, and other business partners. The processing is carried out for the purpose of providing contractual services within the framework of operating an online shop, billing, delivery, and customer service. Here, we use session cookies for storing the contents of the shopping cart and permanent cookies for storing the login status.

The processing is based on Art. 6(1)(b) (performance of order processes) and c (legally required archiving) GDPR. The information marked as necessary is required to establish and fulfill the contract. We only disclose the data to third parties within the scope of delivery, payment, or within the scope of legal permissions and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfillment of the contract (e.g., at the request of the customer for delivery or payment).

Users can optionally create a user account, in particular by viewing their orders. As part of the registration, the required mandatory information is communicated to the users. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a legal obligation to retain it for commercial or tax reasons pursuant to Art. 6(1)(c) GDPR. Information in the customer account remains until it is deleted with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to secure their data before the end of the contract if they have terminated it.

As part of the registration and renewed logins as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the users' interest in protection against misuse and other unauthorized use. These data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so pursuant to Art. 6(1)(c) GDPR.

Deletion takes place after the expiry of legal warranty and comparable obligations; the necessity of retaining the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after their expiry (end of commercial (6 years) and tax (10 years) retention obligation).

Artificial Intelligence Features

Our websites and applications utilize Google Gemini and Lovable AI (powered by Google Gemini) to provide intelligent features and enhanced functionality. When you engage with these AI-enabled tools, your data is processed specifically to deliver the services and outputs you request.

Scope of Data Processing: To provide AI-driven insights, we process user-provided content, including text, documents, or materials uploaded for analysis. This may also include contact information necessary for context and any personal data you voluntarily include within your prompts or queries.

Data Transmission and Handling: Your data is transmitted securely via Lovable’s infrastructure to Google Gemini. Processing is governed by the principle of purpose limitation, meaning your data is used strictly to provide the requested AI functionality. This processing is temporary and focused on delivering immediate results; we follow strict data minimization protocols to ensure only the information necessary to fulfill your request is shared with the AI model.

Compliance and Security Standards: We partner with providers who maintain industry-leading security standards. Lovable maintains ISO 27001:2022 and SOC 2 Type II certifications, and Google AI services are operated in alignment with GDPR compliance standards. While data may be processed in Google data centers globally, all international transfers are protected by appropriate safeguards, such as Standard Contractual Clauses or adequacy decisions, in compliance with GDPR requirements.

Your Rights and Control: We process AI-related data based on explicit consent, legitimate interest, and contract performance. You maintain full control over your experience: you can choose whether to activate AI features, withdraw your consent for AI processing at any time, and exercise all standard GDPR rights—including the right to access, rectification, portability, and erasure of data processed by these systems.

External Payment Service Providers

We use external payment service providers through whose platforms users and we can conduct payment transactions (e.g., with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html).

Stripe Payment Processing

We use the payment service provider Stripe, operated by Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, for processing payments.

Legal Basis: The use of Stripe is based on Art. 6(1)(b) GDPR (Performance of Contract), as the processing is necessary to execute the payment transaction required for the purchase of goods or services.

Purpose of Processing: Stripe collects and processes payment data (e.g., credit card numbers, bank details, transaction details) to enable and verify payments. Stripe's own terms and conditions and privacy policy apply to the processing of data by Stripe.

Data Transfer to Third Countries (USA): In the course of processing, data may be transferred to Stripe, Inc. in the USA. We ensure that this transfer is adequately safeguarded by relying on the Standard Contractual Clauses (SCCs) issued by the European Commission, coupled with supplementary technical and organizational measures.

Further Information: For more details on Stripe’s privacy practices and your rights, please refer to their privacy policy: https://stripe.com/privacy.

In the context of contract fulfillment, we use payment service providers on the basis of Art. 6(1)(b) GDPR (Performance of Contract). Otherwise, we use external payment service providers based on our legitimate interests pursuant to Art. 6(1)(f) GDPR in order to provide our users with effective and secure payment options.

The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract, sum, and recipient-related information. The information is required to process the transactions. However, the entered data is only processed and stored by the payment service providers. That is, we do not receive account or credit card-related information, but only information with confirmation or negative confirmation of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission serves the purpose of identity and credit checks. For this, we refer to the terms and conditions and privacy policies of the payment service providers.

For payment transactions, the terms and conditions and privacy policies of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and to assert withdrawal, information, and other data subject rights.

Business Analyses and Market Research

In order to operate our business economically, recognize market trends, and understand the wishes of contract partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata based on Art. 6(1)(f) GDPR, with the affected persons including contract partners, prospective customers, customers, visitors, and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing, and market research. We can consider the profiles of registered users with information such as the services they have used. The analyses serve us to increase user-friendliness, optimize our offering, and improve cost-effectiveness. The analyses are for our use only and are not disclosed externally unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the users or after two years from the conclusion of the contract. Otherwise, overall business analyses and general trend determinations are created anonymously whenever possible.

Contact

When contacting us (e.g., via contact form, email, telephone, or social media), the user's details are processed for handling the contact request and its processing pursuant to Art. 6(1)(b) GDPR. The user's details may be stored in a Customer Relationship Management (CRM) system or comparable inquiry organization.

We delete the inquiries if they are no longer necessary. We review the necessity every two years; Furthermore, the statutory archiving obligations apply.

Newsletter

With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch, and statistical evaluation procedures, and your rights of objection. By subscribing to our newsletter, you agree to receive it and the described procedures.

Newsletter Content: We only send newsletters, emails, and other electronic notifications with advertising information (hereinafter "Newsletter") with the consent of the recipients or a legal permission. If the content of a newsletter is specifically described within the context of a registration, it is decisive for the user's consent. Otherwise, our newsletters contain information about our products and related information (e.g., security notices), offers, promotions, and our company.

Double-Opt-In and Logging: The registration for our newsletter takes place in a so-called double opt-in procedure. After registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with someone else's email address. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation times, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

Registration Data: To subscribe to the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for personal address in the newsletter.

The dispatch of the newsletter and the associated performance measurement are based on the recipient's consent pursuant to Art. 6(1)(a), Art. 7 GDPR in conjunction with § 107(2) Telecommunications Act (TKG) or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6(1)(f) GDPR in conjunction with § 107(2) and (3) TKG.

The logging of the registration process is based on our legitimate interests pursuant to Art. 6(1)(f) GDPR. Our interest is in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of users, and also allows us to provide evidence of consent.

Cancellation/Revocation - You can cancel the receipt of our newsletter at any time, i.e., revoke your consent. A link to unsubscribe from the newsletter can be found at the end of each newsletter. We can store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them in order to be able to provide evidence of previously given consent. The processing of this data is limited to the purpose of possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).

Legal Basis and Consent The use of Google Analytics, including the setting of cookies for analysis purposes, is based on your explicit consent (Art. 6 para. 1 lit. a GDPR). You provide this consent via our cookie management banner. You can revoke your consent at any time, which will prevent the collection of future data.

Purpose of Processing Google Analytics uses cookies to analyze how you use our online offering. The information generated by the cookie is used on our behalf to evaluate the use of our online offering, compile reports on website activities, and provide us with other services related to the use of the website and the internet. Pseudonymous user profiles can be created from the processed data.

IP Anonymization We only use Google Analytics with IP anonymization enabled. This ensures that your IP address is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before transmission. 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 your browser will not be merged with other Google data.

Data Transfer to Third Countries (USA) Data collected by Google Analytics may be transferred to and stored on Google servers in the USA. Since the USA is considered a third country without an equivalent level of data protection to the EU, we ensure adequate safeguards for this transfer by using the Standard Contractual Clauses (SCCs) issued by the European Commission, coupled with supplementary technical and organizational measures to ensure the protection of your data.

Objection and Opt-Out You can prevent the storage of cookies by adjusting your browser software settings. Additionally, you can object to the collection and processing of data generated by the cookie and related to your use of the online offering by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Data Retention The personal data of users collected through Google Analytics will be automatically deleted or anonymized after 14 months.

Further Information Further information on data use by Google, settings, and objection options can be found in Google's data protection declaration: https://policies.google.com/technologies/ads.

Google Ads (AdWords) and Conversion Tracking

We use the online marketing services of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) to place ads and measure their effectiveness.

Legal Basis and Consent The use of Google Ads, including the setting of cookies for remarketing and conversion tracking, is based on your explicit consent (Art. 6 para. 1 lit. a GDPR). We collect this consent via our cookie management banner. You can withdraw your consent at any time.

Purpose of Processing We use Google Ads to place ads within the Google advertising network (e.g., in search results, on websites, etc.) so that they are displayed to users who have shown interest in our products or services ("remarketing"). For this purpose, Google uses (re)marketing tags (web beacons) and stores a cookie (or comparable technology) on the user's device when our website is accessed. This file records which websites the user has visited, which content they are interested in, which offers they have clicked on, and technical information about the browser, operating system, and visit time. Furthermore, we utilize conversion tracking, which provides us with an anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. We do not receive any information that personally identifies users.

Pseudonymization The data of the users is processed pseudonymously within the Google advertising network. Google does not store and process the names or email addresses of the users, but processes the relevant data cookie-related within pseudonymous user profiles.

Data Transfer to Third Countries (USA) Data collected by Google Ads may be transferred to and stored on Google servers in the USA. Since the USA is considered a third country without an equivalent level of data protection to the EU, we ensure adequate safeguards for this transfer by using the Standard Contractual Clauses (SCCs) issued by the European Commission, coupled with supplementary technical and organizational measures to ensure the protection of your data.

Further Information and Opt-Out Further information on data use by Google, setting options, and objection options can be found in Google's data protection declaration (https://policies.google.com/technologies/ads) as well as in the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated).

Online Presence in Social Media

We maintain online presences within social networks and platforms in order to communicate with customers, interested parties, and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users who communicate with us within social networks and platforms, e.g., by posting contributions on our online presences or by sending us messages.

Google ReCaptcha

We integrate the function for recognizing bots, e.g., in online forms ("ReCaptcha"), provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Legal Basis: The processing is carried out on the basis of our legitimate interests (Art. 6(1)(f) GDPR) in protecting our online offer from misuse and spam.

Data Transfer to Third Countries (USA): Data collected by ReCaptcha may be transferred to Google servers in the USA. We ensure an adequate level of data protection for this transfer through the use of Standard Contractual Clauses (SCCs) and supplementary measures as required by GDPR.