First name, last name / company name: Soravia Group GmbH
Street Building No.: TownTown, Thomas-Klestil-Platz 3
Postal code City Country: 1030 Vienna, Austria
Email address: email@example.com
Managing Director / Owner: Erwin F. Soravia, Hanno Soravia
Link to the legal notice https://www.soravia.at/impressum/
Contact at the central data protection office: firstname.lastname@example.org
Types of processed data:
- Inventory data
- Contact details
- Content data
- Usage data
- Meta-/communication data
Categories of data subjects
Visitors and users of the online offer (hereinafter we also refer to the data subjects as “users”).
Purpose of the processing
- Provision of the online offer, its functions and contents.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach measurement/Marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, if he can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term is far-reaching and includes virtually every handling of data.
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, if such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to analyze or predict certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
“Controller” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 32 GDPR, we take suitable technical and organizational measures to ensure a level of protection appropriate to the risk, taking into consideration the state of technology, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood of occurrence and severity of the risk to the rights and freedoms of natural persons.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the exercise of data subjects’ rights, deletion of data, and to guarantee response to data vulnerability. Furthermore, we consider the protection of personal data already during the development or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).
Collaboration with contract processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (contractor processors or third parties), transmit data to them or otherwise grant access to the data, this will be done only on the basis of legal permission (e.g. in case of transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to this, it is required by a legal obligation or based on our legitimate interests (e.g. the use of agents, webhosting services, etc.).
If we commission third parties with the processing of data on the basis of a so-called “contract processing agreement”, this will be done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will be done only in order to fulfill our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special conditions of Art. 44 et seq. GDPR are present. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized level of data protection (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contract clauses”).
Rights of data subjects
You have the right to ask for confirmation as to whether the data in question are being processed and for information about these data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to demand completion of the data relating to you or the rectification of incorrect data relating to you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to demand that a restriction be placed on the processing of the data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other controllers.
Furthermore, in accordance with Art. 77 GDPR, you have the right to file a complaint with the competent supervisory authority.
Right of revocation
You have the right to grant consent in accordance with. Art. 7 (3) GDPR with effect for the future.
Right to object
You can object to the future processing of your data at any time in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.
Cookies and the right to object to direct mail
Cookies are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, called “session cookies” or “transient cookies” are cookies that are deleted after a user leaves an online offer and closes his browser. Information such as the content of a shopping cart in an online shop or a login status can be saved in such a cookie. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. For example, the login status can be saved if users visit the website it after several days. Likewise, the interests of the users, which are used for range measurement or marketing purposes, can be stored in such a cookie. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, these are called “first-party cookies”).
If users do not want cookies stored on their computer, they will be asked to disable the corresponding option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
According to legal regulations in Austria, storage takes place in particular for 7 years according to Art. 132 (1) BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The bases for the processing are Art. 6 (1) (c) GDPR, Art. 6 (1) (f) GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose of and interest in processing lies in administration, financial accounting, office organization, data archiving, i.e. tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.
In doing so, we disclose or transmit data to the tax office, consultants, such as tax accountants or auditors, as well as other payment agents and payment service providers.
Furthermore, we store information on suppliers, promoters and other business partners on the basis of our business interests, e.g. for the purpose of contacting you at a later date. We generally store these data, most of which are company-related, on a permanent basis.
We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The applicant data are processed in order to fulfill our (pre-)contractual obligations in the context of the application process within the meaning of Art. 6 (1) (b) GDPR and Art. 6 (1) (f) GDPR if we are required to perform the data processing, e.g. in the context of legal procedures.
The application process requires applicants to provide us with applicant data. The necessary applicant data are marked if we offer an online form, otherwise they are evident from the job descriptions and basically include information on the person, postal and contact addresses and the application documents, such as cover letter, CV and certificates. In addition, applicants can voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) (b) GDPR (e.g. health data, such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) (a) GDPR (e.g. health data, if necessary for performance of the occupation).
If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us in accordance with the latest state of technology.
Furthermore, applicants can send us their applications via email. However, please note that emails are generally not sent in encrypted form and that applicants must provide the encryption themselves. We can therefore take no responsibility for the transmission of the application between the sender and its receipt on our server, and therefore recommend the use of an online form or postal delivery instead. Instead of applying via the online form and email, applicants still have the opportunity to send us their application by post.
The data provided by the applicants may be further processed by us for employment purposes in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.
The deletion is subject to the candidate submitting a legitimate revocation after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.
As part of the application, we offer applicants the opportunity to be included in our “Talent Pool” for a period of two years on the basis of consent given in accordance with Art. 6 (1) (b) and Art. 7 GDPR.
The application documents in the Talent Pool are processed solely as part of future job advertisements and a job search and will be destroyed at the latest after expiration of the deadline. Candidates are informed that their consent to be admitted to the talent pool is voluntary, that it has no influence on the current application process, and that they can revoke this consent at any time in the future and declare an objection within the meaning of Art. 21 GDPR.
When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the user to process the contact request and to complete it will be processed in accordance with Art. 6 (1) (b) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or a comparable system for organizing inquiries.
We will delete the inquiries if they are no longer required. We will check whether they are still needed every two years; the legal archiving obligations will continue to apply.
Information about the newsletter and consent
The following information explains the contents of our newsletter and clarifies the procedures for registration, shipping and statistical evaluation, as well as your right to cancel subscription at any time.
By subscribing to our newsletter, you declare your consent to receive the newsletter and agree to the procedures described.
Content of newsletters
We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the express consent of the recipient or legal permission. Following a subscription to our newsletter, the user’s consent will be upheld provided the contents continue to reflect the described material. Furthermore, our newsletters contain information and news about Soravia Group (in particular Soravia Service GmbH, Soravia Equity GmbH, SoReal GmbH, Soravia Deutschland GmbH, IFA Institut für Anlageberatung Aktiengesellschaft, ifa invest GmbH, ivv Immobilien Verkauf and Vermietungs GmbH, ima Real Estate Management GmbH, icm Real Estate Comfort Management GmbH, Checkmyplace.com, a product of CMP Data Business Institute GmbH, SEM Energy and Building Management GmbH, ASSA GmbH, Ruby Hotels & Resorts GmbH, Dorotheum GmbH & Co KG) and its existing and future projects as well as invitations to various events.
Double opt-in and subscription data storage
Subscription to our newsletter follows a double opt-in procedure. That is, after registering, users receive an e-mail requesting confirmation of the subscription. This confirmation is required to ensure subscribers use their own e-mail addresses and not those of third-parties.
In order to maintain that subscription procedures follow legal requirements, all newsletter subscriptions will be recorded. This includes storage of subscription details and the time of confirmation, as well as the IP address. Similarly, any changes to your data will be stored with MailChimp.
Use of the mailing service provider “MailChimp”
The newsletter is distributed by “MailChimp”, a newsletter shipping platform of Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA.
The email addresses of our newsletter recipients, as well as their other information described in these notes, are stored on MailChimp’s servers in the USA. MailChimp uses this information to send and evaluate the newsletters on our behalf. Furthermore, MailChimp may, according to its own information, use these data to optimize or improve its own services, e.g. for technical optimization of the shipping and the presentation of the newsletter, or for economic purposes, to determine in which countries the recipients are located. However, MailChimp does not use the data of our newsletter recipients to write to them on its own behalf or to pass the data on to third parties.
In order to sign-up for the newsletter, subscribers’ must provide their e-mail address. For the purposes of writing personal salutations on the newsletter and invitations we also request user’s title, and first and last names.
Statistical surveys and analysis
The newsletters contain a web beacon, a pixel-size file that is requested from the MailChimp server when the newsletter is opened. As part of this request, technical information, such as information about the browser and your system, as well as your IP address and time of the request are collected. This information is used to improve the technical performance of services based on specifications about the audience and their reading habits, based on their locations (which can be determined using the IP address) or the access times.
Also included in the statistical survey is information regarding if the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor that of MailChimp to observe individual users. Instead, we use the information retrieved to learn more about our users reading habits so that we can adapt our content to better serve their interests.
Online call and data management
Your basic data protection rights include rights to information, correction, deletion, restriction, data portability, revocation and opposition. If you believe that the processing of your data violates data protection laws or if your data protection rights have otherwise been violated in any way, you can complain to the supervisory authorities. In Austria, this is the Data Protection Authority.
You can contact us at:
Soravia Service GmbH, FN 70218 m, Thomas-Klestil-Platz 3, 1030 Wien;
email@example.com; Tel. +43-1-71690
Termination / Revocation
You can terminate your subscription or revoke your consent to our newsletter at any time. By doing so you also revoke your consent for MailChimp to contact you or carry out statistical analysis. Unfortunately, it is not possible to separately revoke either receipt of the newsletter through MailChimp, or the statistical analysis.
A link to cancel the newsletter can be found at the end of each newsletter.
You can unsubscribe from the newsletter at any time at firstname.lastname@example.org.
Lawful basis for legal obligations of the General Data Protection Regulation
In accordance with provisions of the General Data Protection Regulation (GDPR), which came into force on 25 May 2018, by providing their email address the data subject has given consent to the processing of his or her personal data on the basis on Article 6. 1.(a)(7) of the GDPR. The use of the mail service provider MailChimp, as well as the application of statistical surveys and analysis, and the logging of the registration process, are based on our legitimate interests in accordance with. Article 6. 1.(f) of the GDPR. Our aim is to provide a user-friendly and secure newsletter system that serves both our business interests and the expectations of our users.
Furthermore, in accordance to Article 21 of the GDPR, you can at any time object to future processing of your personal data. In particular, objection can be made to processing of personal data for direct marketing purposes.
Hosting and emailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, emailing, security and technical maintenance services we use to operate this online service.
This involves us or our hosting provider processing inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing agreement).
Collection of access data and log files
On the basis of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, we or our hosting provider collect data on each access to the server on which this service is located (so-called server log files). The access data include the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the incident in question.
Google Tag Manager
Google Tag Manager is a solution that allows us to manage so-called website tags through a single interface (including integrating Google Analytics and other Google marketing services into our online offering). Tag Manager itself (which implements the tags) does not process users’ personal data. With regard to the processing of users’ personal data, we refer to the following information about Google’s services. Use Policy: https://www.google.com/intl/en/tagmanager/use-policy.html.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymization activated. This means that the users’ IP addresses will be shortened by Google within member states of the European Union or in other states that are parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of these data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
The personal data of users will be deleted or anonymized after 14 months.
Integration of services and contents of third parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) (f) GDPR), we make use of content or services offered by third-party providers in order to integrate their content and services such as videos or fonts (collectively referred to as “content”).
This always presupposes that the third-party providers of this content know the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for displaying this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.