Trenkwalder Group AG Privacy Policy

 The legal basis for data privacy can be found in the General Data Protection Regulation (Regulation (EU) 2016/679; “GDPR”), the Data Protection Act (DSG), the Media Act (MedienG) and the Telecommunications Act (TKG).

 1.      How we collect personal data

Use of the website

We collect and utilise our users’ personal data only to the extent necessary to provide a functional website and our content and services.

We will automatically process the following personal data when you use our website:

  • The user’s IP address;

  • The browser type and version used;

  • The user’s operating system;

  • The user’s Internet service provider;

  • The date and time of access;

  • Websites from which the user’s system accesses our website;

  • Websites accessed by the user’s system via our website;

  • Log files

Our online services may contain links to the websites of Group companies or third-party providers not affiliated with us. Once the link has been clicked, we no longer have any influence on the collection, processing and use of any personal data transmitted by clicking on the link (such as the IP address or the URL of the page on which the link is located) and the conditions applicable there apply. We assume no responsibility for the processing of this kind of personal data.

Legal basis:

We base the processing of your data in the course of using our website and online services on our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR, which consists of providing our website securely and protecting it from criminal threats and acts.

Purpose of data processing

We use the collected data for the following purposes:

  • To ensure and improve the security of our website and online services and to prevent and investigate suspected unlawful use.

  • To optimise our services

Contact

If you contact us by email or telephone, we will process the personal data you provide (email, name, telephone number, user name and your request or the associated documents) to process your request and respond accordingly. 

Legal basis:

For processing and responding, we draw upon our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR to justify processing, which consists of processing and responding to your request quickly and, if necessary, responding to further enquiries.

If your request results in a further business relationship, we also process the personal data from your enquiry on the basis of our (pre)contractual obligations in accordance with Art. 6 para. 1 lit. b GDPR and Art. 6 para. 1 lit. c GDPR.

Purpose of data processing

We process your data in connection with your enquiries for the following purposes:

  • To process your enquiry quickly and provide a satisfactory response; and

  • To fulfil our role as a service provider.

Processing suppliers’ or business partners’ data

In the course of the business relationship, we process data that we have received from you as a supplier or business partner or your organisational representative (e.g. name, role, company, email address, telephone number, address, payment details), data that is part of the contract or is directly related to the business relationship, as well as data that arises in the course of communication with you as a supplier or business partner.

Legal basis:

We process your personal data to either

  • Carry out precontractual measures or to fulfil our contractual obligations (Art. 6 para. 1 lit b GDPR);

  • Fulfil our legal obligations (Art. 6 para. 1 lit c GDPR).

Purpose of data processing

The main purpose of processing your data is to initiate, maintain and process our contracts for goods and services.

2.      Storage and retention of personal data:

We store your personal data in our systems in such a way that you cannot be identified for longer than necessary. We determine this period by taking into account:

  • The need to continue storing personal data to offer and provide services set up with the user;

  • The existence of specific legal (national) obligations that necessitate the processing and storage of data for certain periods of time, e.g. in accordance with the Austrian Commercial Code (UGB) and Fiscal Code (BAO)

3.      Disclosure of personal data

To operate our website and manage our communication channels, we regularly use IT service providers for IT services, telecommunications and cloud service providers, who may also have access to personal data on our behalf and in accordance with our instructions so that they are able to provide the commissioned IT services.

We also transfer your personal data to the following recipients:

  • To Trenkwalder Group AG companies and affiliates for internal Group purposes and/or to fulfil our (pre)contractual obligations or legal obligations;

  • To external third parties to the extent necessary on the basis of our legitimate interests (e.g. auditors, insurance companies in the event of an insurance claim, legal representatives in the event of an incident, etc.);

  • To authorities and other public bodies to the extent required by law (e.g. tax authorities, courts, etc).

Personal data may also be transferred to recipients in other countries in individual cases. These countries may not be subject to the same data protection legislation as Austria.

In the event that your personal data is transferred to other countries in individual cases, we shall protect the data as described in this privacy policy. All data transfers are subject to the applicable data protection legislation.

We may transfer your personal data to countries within or outside the European Union. The GDPR guarantees the same high level of data protection throughout the European Union. When selecting our service providers, we therefore rely on European partners wherever possible if your personal data is to be processed. Only in exceptional cases will we have data processed outside the European Union as part of the use of third-party services. We shall only authorise the processing of your data in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that your data may only be processed on the basis of special guarantees, such as the EU Commission’s officially recognised determination of a level of data protection corresponding to the EU or compliance with officially recognised special contractual obligations, the “standard data protection clauses”.

4.       Your rights as a data subject

You have the right to obtain information about the personal data we process about you. You also have the right to have incorrect data corrected and your data deleted (“right to be forgotten)”. You can also revoke your consent to the processing of personal data with effect for the future if the processing is based on your consent. You may also have the right to restrict the processing of your data and the right to receive the data you have provided in a structured, common and machine-readable format (“data portability”). You have the right not to be subject to automated individual decision-making if this profiling has a legal effect on you or significantly affects you in a similar way.

You have the right to object to data processing at any time if there are reasons for this arising from your particular situation.

You also have the option of lodging a complaint with a data protection supervisory authority. The data protection supervisory authority responsible for us is the Austrian Data Protection Authority, Barichgasse 40-42, 1030 Vienna, email: dsb.@dsb.gv.at, tel: +43 1 52 152-0.

You can contact us at any time if you require further information about the processing of your personal data.

5.      Cookies

This website uses cookies to optimise the website experience for the user and to ensure that the website functions properly. This website uses cookies to collect and store anonymised information about you and your usage behaviour to provide you with information that is tailored to your individual needs and relevant to you.

Cookies are small text files that are stored by a website server on your computer or other devices for internet use. Your web browser sends these cookies back to the website each time you visit. This allows us to identify you when you visit the site again and to store information about your preferences. You can find more information about cookies and how they work here: http://www.aboutcookies.org/.

Certain cookies we use are necessary to display the website to you and to allow you to use our website and certain features properly. Data processing is necessary for the purpose of data security and the prevention of misuse and is therefore carried out on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Section 165 para. 3 TKG. We also use cookies to store information about the settings you have selected and to customise our website to your individual needs; this applies, for example, to language selection. This information is not personal data and is anonymised. It is not used for any purposes other than those described here.

We also use analytics services that allow us to determine the effectiveness of our website content and to put the relevant interest of visitors into specific terms in the respective content. Furthermore, the services help to optimise the website’s features.

We use the Google Tag Manager service provided by Google. Google is a group of companies consisting of Google Ireland Ltd. (provider of the service), Gordon House, Barrow Street, Dublin 4, Ireland and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and other affiliated companies of Google LLC. Google Tag Manager is an auxiliary service and processes personal data itself only for technically necessary purposes. Google Tag Manager ensures that other components are loaded, which in turn may collect data. Google Tag Manager does not access this data. It only collects data on how the individual tags are used.

The legal basis for processing your personal data is your consent in accordance with Art. 6 para.1 lit. a GDPR if the consent includes the storage of cookies or access to information on the user’s end device. Your personal data may be transferred to the United States. The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected.

You have the right to revoke your consent at any time. The revocation of consent is effective for the future and does not affect the legality of the processing carried out prior to revocation.

You can revoke your consent to data processing and third-country transfer at any time by accessing the “Cookie settings” via the footer at the bottom of the website and unchecking the box under “Performance cookies”. This does not affect the legitimacy of any prior processing of your data.

Further information about the handling of user data can be found in Google Tag Manager's privacy policy: https://policies.google.com/privacy?hl=en-US#intro.

We use Google Analytics on our website (service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), a web analysis service that provides statistics and basic analysis tools for search engine optimisation (SEO) and marketing purposes. Google Analytics collects user data from each website visitor by using page tags that run on each visitor’s web browser to collect data and send it to one of Google’s data collection servers.

The legal basis for processing your personal data is Art. 6 para. 1 lit. a GDPR. The recipient of your personal data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. In Google Analytics 4, the anonymisation of IP addresses is activated by default. As a result, your IP address will be truncated by Google within Member states of the European Union or in other signatory states to the Agreement on the European Economic Area. According to Google, the truncated IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

During your visit to the website, your user behaviour is recorded in the form of “events”. Events can be: • Page views • First visit to the website • Start of the session • Interaction with the website • Clicks on external links • Internal search queries • Interaction with videos • Downloads • Adverts viewed/clicked on • Scrolling behaviour • Your approximate location (region) • Technical information about your browser and the end devices you use (e.g. language setting, screen resolution) • Referrer URL (website/advertising from which you came to this website).

We are aware of our responsibility with regard to your personal data and we take measures to protect it. IP addresses are only processed in truncated form so that they cannot be traced back to individuals. If the data collected about you enables you to be identified as an individual, it is immediately excluded and deleted. We only use Google Analytics if you agree to performance cookies. We use Google Analytics to analyse the use of our website and to make regular improvements to it. The statistics we obtain by using Google Analytics enable us to improve our services and make them more interesting for you as a user. The legal basis for the use of Google Analytics is your consent in accordance with Art. 6 para. 1 sentence. 1 lit. a GDPR. Your personal data may be transferred to the United States. The transfer of your data is subject to appropriate safeguards in accordance with Art. 46 GDPR. For this purpose, appropriate safeguards within the meaning of Art. 46 para. 2 GDPR are agreed with the data importer if this is necessary.

The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected.

Further information on the handling of user data can be found in the Google Analytics privacy policy at: https://policies.google.com/privacy?hl=en-US#intro 

If your settings include providers that transfer data to countries without an adequacy decision in accordance with Art. 45 GDPR and without suitable safeguards in accordance with Art. 46 GDPR, your consent also applies to this. There is a risk that any of your data transmitted in this way may be subject to access by authorities in these third countries for control and monitoring purposes and that no effective legal remedies are available against this.

We use the Google reCaptcha service on our website to determine whether a human or a computer is making a specific entry. Google uses the following data to check whether a human or a computer is making entries: IP address of the end device used, the website visited where the reCaptcha service is integrated, the date and duration of the visit, information on the browser and operating system used, the Google account used if you are logged in to Google, mouse movements over the reCaptcha areas and tasks in which users have to identify images.

The legal basis for the aforementioned data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest in this data processing is to ensure the security of our website and to protect against automated entries (attacks).

Further information about the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland can be found at https://www.google.com/policies/privacy/

Opt-out: https://adssettings.google.com/authenticated.

In order to set out our content correctly on all browsers and in an attractive graphical form, we use script libraries and text libraries such as Google Web Fonts (https://www.google.com/webfonts/) on this website.

Google Web Fonts are transferred to your browser cache to avoid multiple loading. If your browser does not support Google Web Fonts or prevents access, content is displayed in a standard font. Accessing script libraries or font libraries automatically activates a connection to the library operator. It is theoretically possible for the operators of such libraries to collect data, although it is currently unclear whether they do and, if so, for what purposes.
The legal basis for the use of script libraries is our legitimate interest in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR.

The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy/

6.      Information

If you have any questions about the collection and use of your personal data by us, we will be happy to provide you with information about the personal data stored about you at any time, free of charge and without delay. If you want to have your data corrected, blocked or deleted or if you have any complaints, requests for information or general questions on the subject of data protection, please contact us via email (info@trenkwalder.com), or at Trenkwalder Group AG, Data Protection, Rennweg 97-99, Kern 08, 6.OG, Vienna 1030.

7.      Changes

It may be necessary to adapt the content of this privacy policy from time to time. Therefore, we reserve the right to change it at any time. We will also publish the changed version of the privacy policy here. Therefore, if you visit us again, you should read through the data protection notice once again.

 

Last updated: December 2023