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Privacy Policy


This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offer and its related websites, functions and content, as well as external online presences, such as our social media profiles (hereafter 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

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: datenschutz@soravia.at
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: datenschutz@soravia.at

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

Terms used

“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. 13 GDPR we inform you about the legal basis of our data processing. For users from the area of application of the data protection basic regulation (GDPR), i.e. the EU and the EEC, the following applies, provided that the legal basis is not specified in the data protection explanation:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for the processing for the fulfilment of our services and the execution of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 Para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person necessitate the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to the controller is Art. 6 para. 1 lit. e GDPR.
The legal basis for the processing to safeguard our legitimate interests is Art. 6 Para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected shall be governed by the provisions of Art. 6 (4) GDPR.
The processing of special categories of data (pursuant to Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.

Security measures

In accordance with the legal requirements, 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.

Collaboration with contract processors, joint managers and third parties

If, in the context of our processing, we disclose data to other persons and companies (contractor processors, joint managers 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, to fulfill the contract), users have consented, it is required by a legal obligation or based on our legitimate interests (e.g. the use of agents, webhosting services, etc.).

If we disclose, transmit or otherwise grant access to data to other companies of our group of companies, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the legal requirements.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or in the context of the use of third party services or disclosure or transmission of data to other persons or companies, 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 express consent or contractually required transfer, we process or allow the data to be processed only in third countries with a recognised level of data protection, which includes US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission).

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 the provisions of law.

In accordance with the provisions of law, 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 the provisions of law, 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 the provisions of the law.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with the provisions of law and request their transmission to other controllers.

Furthermore, in accordance with legal requirements, you have the right to file a complaint with the competent supervisory authority.

Right of revocation

You have the right to grant consent with effect for the future.

Right to object

You can object to the future processing of your data at any time in accordance with the provisions o law. 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”).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If we ask the user to consent to the use of cookies (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal cookies of the users will be processed in accordance with the following explanations within the framework of this data protection declaration on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR) or if the use of cookies is necessary for the provision of our contract-related services, in accordance with Art. 6 Para. 1 lit. b. GDPR, or if the use of cookies is necessary for the performance of a task in the public interest or in the exercise of official authority, pursuant to Art. 6 para. 1 lit. e. GDPR, processed.

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.

A general objection to the use of cookies used for online marketing purposes can be declared on a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. The storage of cookies can also be prevented by deactivating them in the browser settings. Please note that it may subsequently not be possible to use all features of this online offer.

Deletion of data

The data processed by us will be deleted in accordance with the statutory provisions or their processing will be restricted. Unless explicitly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data are deleted because they is required for other and legally permitted purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.

Changes and Updates to the Privacy Policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

Contractual services

We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).

We do not process any special categories of personal data, unless these are components of a commissioned or contractual processing.

We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their indication, if this is not evident for the contracting parties. Disclosure to external persons or companies will only take place if it is necessary within the framework of a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements.

Within the scope of using our online services, we can store the IP address and the time of the respective user action. The storage takes place on the basis of our justified interests, as well as the interests of the users in the protection against abuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims according to art. 6 para. 1 lit. f. GDPR is necessary or there is a legal obligation to do so pursuant to Art. 6 Para. 1 lit. c. GDPR.

The data will be deleted when the data is no longer required for the fulfilment of contractual or statutory welfare obligations and for the handling of any warranty and comparable obligations, whereby the necessity of data retention is reviewed every three years; otherwise the statutory retention obligations apply.

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.

Microsoft Cloud Services

We use the cloud and cloud software services offered by Microsoft (software as a service, for example, Microsoft Office) for the following purposes: storing and managing documents, managing calendars, sending e-mail, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing websites, forms or other content and information, as well as chatting and participating in audio and video conferences.

Here the personal data of the users are processed, as far as these become part of the documents and contents processed within the described services or are part of communication procedures. This may include, for example, user master data and contact data, data on processes, contracts, other processes and their contents. Microsoft also processes usage data and metadata used by Microsoft for security purposes and service optimization.

In the course of using publicly accessible documents, websites or other content, Microsoft may store cookies on the user’s computer for purposes of web analysis or to remember user settings.

We use the Microsoft Cloud services on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR in efficient and secure administrative and cooperation processes. Furthermore, the processing takes place on the basis of an order processing contract with Microsoft.

For more information, see the Microsoft Privacy Statement (https://privacy.microsoft.com/de-de/privacystatement) and the Microsoft Cloud Services Security Notes (https://www.microsoft.com/de-de/trustcenter). You can object to the processing of your data in the Microsoft Cloud in accordance with the legal requirements. In addition, the deletion of the data within Microsoft’s cloud services is determined by the other processing procedures in which the data is processed (e.g. deletion of data no longer required for contractual purposes or storage for purposes of taxation of data required).

The Microsoft Cloud services are offered by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. If data is processed in the USA, we refer to the certification of Microsoft under the Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).

Privacy policy in the application process

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 (in Germany additionally § 26 BDSG applies).

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.

By submitting the application to us, the applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set forth in this privacy policy.

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.

Talent Pool

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) (a) 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.

Contact

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) (within the framework of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other inquiries) 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.

newsletter

With the following information, we inform you about the contents of our newsletter and clarify 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, accompanying information (e.g. safety instructions), offers, actions about and from our companies 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. Likewise the changes of your data stored with the dispatch service provider are logged.

Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of addressing you personally.

The dispatch of the newsletter and the performance measurement associated with it are based on the consent of the recipients pursuant to Art. 6 Para. 1 lit. a, Art. 7 GDPR in conjunction with § 107 Para. 2 TKG or, if consent is not required, on our legitimate interests in direct marketing pursuant to Art. 6 Para. 1 as per f. GDPR in connection with § Art. 107 Par. 2 and 3 TKG.

The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.

Cancellation – You may cancel your subscription to our newsletter at any time, i.e. we may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of your previous consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.

Newsletter – “MailChimp”

The newsletter is distributed by the dispatch service provider “MailChimp”, a newsletter shipping platform of Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA.
You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is responsible for the delivery of our products on the basis of our legitimate interests pursuant to Art. 6 Para. 1 lit. f. GDPRand an order processing contract in accordance with Art. 28 Para. 3 S. 1 GDPR.

The dispatch service provider can use the data of the recipients in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

Newsletter Success Measurement

The newsletters contain a web beacon, a pixel-size file that is requested from our server when the newsletter is opened or if we use a dispatch service provider, from whose server is retrieved. 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 from any used dispatch service provider, if used, 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.
A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled.

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.

Bugsnag

We include the software “Bugsnag Inc.”, 939 Harrison St, San Francisco, CA 94107, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

StackPath’s Content Delivery Network

We use a so-called “Content Delivery Network” (CDN), offered by StackPath, LLC, 2021 McKinney Avenue, Suite 1100 Dallas, Texas 75201, USA. StackPath is certified under the Privacy Shield Agreement, providing a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000CbahAAC&status=Active).

A CDN is a service with the help of which contents of our online offer, especially large media files such as graphics or scripts, can be delivered faster with the help of regionally distributed servers connected via the Internet. The processing of user data is carried out solely for the aforementioned purposes and to maintain the security and functionality of the CDN.

The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimization of our online offer.

Further information can be found in StackPath’s privacy policy: https://www.stackpath.com/legal/privacy-statement.

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 Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our online 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.

For more information about Google’s data usage, settings and objection options, please read Google’s Privacy Policy (https://policies.google.com/technologies/ads), as well as the settings for displaying pop-up ads by Google (https://adssettings.google.com/authenticated).

If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR).

As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/privacy) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

The personal data of users will be deleted or anonymized after 14 months.

Google Universal Analytics

We use Google Analytics in the form of “universal analytics”. “Universal Analytics” refers to a Google Analytics procedure in which user analysis is performed on the basis of a pseudonymous user ID and a pseudonymous profile of the user is thus created with information from the use of various devices (so-called “cross-device tracking”).

Target group formation with Google Analytics

We use Google Analytics to display ads placed by Google and its partners within our advertising services only to users who have shown an interest in our online services or who have specific characteristics (e.g. interests in specific topics or products determined on the basis of the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of users.

Google Adsense with personalized ads

We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

We use the AdSense service to display ads on our website and receive a fee for displaying or otherwise using them. For these purposes, usage data such as the click on an ad and the IP address of the user is processed, whereby the IP address is shortened by the last two digits. For this reason, the processing of user data is pseudonymised.

We use Adsense with personalized ads. Google uses the websites or apps users visit and the user profiles they create to determine their interests. Advertisers use this information to tailor their campaigns to these interests, which is beneficial to both users and advertisers. For Google, ads are personalized when collected or known data determines or influences ad selection. This includes, but is not limited to, past searches, activities, site visits, app usage, demographics, and location information. Specifically, this includes demographic targeting, targeting to interest categories, remarketing, targeting to match lists, and targeting lists uploaded to DoubleClick Bid Manager or Campaign Manager.

If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR).

As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Google Adsense with non-personalized ads

We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

We use the AdSense service to display ads on our website and receive a fee for displaying or otherwise using them. For these purposes, usage data such as the click on an ad and the IP address of the user is processed, whereby the IP address is shortened by the last two digits. For this reason, the processing of user data is pseudonymised.

We use Adsense with non-personalized displays. The ads are not displayed on the basis of user profiles. Non-personalized ads are not based on past user behavior. Targeting uses contextual information, including rough (e.g., local) geographic targeting based on current location, content on the current website or app, and current keywords. Google prohibits any personalized targeting, including demographic targeting and targeting based on user lists.

If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR) are processed.

As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Google AdWords and Conversion Measurement

We use the Google “AdWords” online marketing method to place ads on the Google advertising network (e.g., in search results, videos, websites, etc.) so that they are displayed to users who have an alleged interest in the ads. This allows us to display ads for and within our online offerings in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested in other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are called up, a Google code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, what content he is interested in and what offers the user has clicked, as well as technical information on the browser and operating system, referring websites, visit times and other information on the use of the online service.

Furthermore we receive an individual “Conversion-Cookie”. The information collected with the help of the cookie is used by Google to compile conversion statistics for us. However, we only know the anonymous total number of users who clicked on our ad and were directed to a page with a conversion tracking tag. However, we do not receive any personally identifiable information.

User data is processed pseudonymously within the Google advertising network. This means, for example, that Google does not store and process the user’s name or e-mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.

If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR).

As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Google Doubleclick

We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

We use the online marketing method Google “Doubleclick” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Double Click is characterized by the fact that ads are displayed in real time based on users’ suspected interests. This allows us to display ads for and within our online offering in a more targeted manner to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested in other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are called up, Google executes a code directly from Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, what content he is interested in and what offers the user has clicked, as well as technical information on the browser and operating system, referring websites, visit times and other information on the use of the online service.

The IP address of the user is also recorded, whereby this is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is it transmitted in full to a Google server in the USA and shortened there. Google may also link the above information to such information from other sources. If the user subsequently visits other websites, ads tailored to the user’s profile may be displayed according to the user’s presumed interests.

User data is processed pseudonymously within the Google advertising network. This means, for example, that Google does not store and process the user’s name or e-mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information Google Marketing Services collects about users is transmitted to Google and stored on Google’s servers in the United States.

If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR).

As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Visual Website Optimizer

Within our online offer the service Visual Website Optimizer (an offer of Wingify Software Private Limited, 404, Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India) is used.

Visual Website Optimizer allows you to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) within the framework of so-called “A/B-Testings”, “Clicktracking” and “Heatmaps”. A/B tests serve to improve the user-friendliness and performance of online offers. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the contents or labels of the navigation elements can differ. Subsequently, the behaviour of the users, e.g. longer stay on the website or more frequent interaction with the elements, can be used to determine which of these websites or elements correspond more closely to the needs of the users. “Clicktracking” allows you to keep track of users’ movements within an entire online offering. Since the results of these tests are more accurate if the user’s interaction can be followed over a certain period of time (e.g. if a user would like to return), cookies are usually stored on the user’s computer for these test purposes. “Heatmaps” are mouse movements of the users, which are combined to an overall picture, with the help of which it can be recognized, for example, which web page elements are preferred and which web page elements users prefer less.

Cookies are only stored on the user’s devices for these test purposes. Only pseudonymous data of the users will be processed. For further information we refer to the privacy policy of Visual Website Optimizer: https://vwo.com/privacy-policy/.

If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR).

If you do not want the Visual Website Optimizer to track your usage patterns, you can opt out of data collection by following this link: https://www.soravia.at/?vwo_opt_out=1.

Online presences in social media

We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services.

We would like to point out that user data may be processed outside the European Union. This could result in risks for users, e.g. because it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield, we would like to point out that by doing so they commit themselves to comply with EU data protection standards.

Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).

The processing of users’ personal data is carried out on the basis of our legitimate interests in effective information for users and communication with users pursuant to Art. 6 Para. 1 lit. f. GDPR. If the users are requested by the respective providers of the platforms to consent to the aforementioned data processing, the legal basis for the processing is Art. 6 Para. 1 lit. a., Art. 7 GDPR.

For a detailed representation of the respective processing and the possibilities of objection (Opt-Out), we refer to the following linked information of the providers.

Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and give information. Should you nevertheless need help, you can contact us.

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.

Vimeo

We can integrate the videos of the platform “Vimeo” of the provider Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy.
We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=en) or the settings of Google for data use for marketing purposes (https://adssettings.google.com/).

Youtube

We integrate the videos of the platform “YouTube” of the provider 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.

Google Fonts

We incorporate the fonts (“Google Fonts”) of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. According to Google, user data is used solely for the purpose of displaying fonts in the user’s browser. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and consideration of possible licensing restrictions for their integration. Privacy policy: https://www.google.com/policies/privacy/.

Google ReCaptcha

We integrate the function to recognize bots, e.g. for entries in online forms (“ReCaptcha”) of the provider 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.

Google Maps

We include maps from the Google Maps service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The processed data may include, in particular, users’ IP addresses and location data, but these are not collected without their consent (usually as part of the settings on their mobile devices). The data can be processed in the USA.
Privacy Policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Instagram

Within our online offer, functions and contents of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. If the users are members of the Instagram platform, Instagram can assign the call of the above contents and functions to the user profiles there. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/.

Linkedin

The functions and content of the LinkedIn service offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland can be integrated into our online offer. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online service within LinkedIn. If the users are members of the platform LinkedIn, LinkedIn can assign the call of the above-mentioned contents and functions to the profiles of the users there.
Privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy.
LinkedIn is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active).
Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Fonts.com

This website uses “fonts.com”, a font service provided by Linotype GmbH (“fonts.com”), Werner-Reimers-Strasse 2-4, 61352 Bad Homburg (“fonts.com”). Each time you visit this website, files are loaded from a “fonts.com” server to display the text in a particular font. Their IP address can be transferred to a server of “fonts.com” and stored within the usual weblog. Further processing of this information is the responsibility of “fonts.com”, please refer to the Privacy Policy (“https://www.monotype.com/legal/privacy-policy) of “fonts.com” for conditions and settings.

Analysis and Optimization Service Hotjar

We use Hotjar, an analysis software from Hotjar Ltd, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta (“Hotjar”). With the help of the information obtained thanks to Hotjar, we can analyze and improve the use of our online services.

For this purpose alone, data of the users of our online offer are stored and evaluated. We use Hotjar to analyze our online offer and not the individual users. The data of the users are therefore pseudonymised and processed within the European Union as well as on the basis of the order processing contract offered by Hotjar. User entries, e.g. in forms or keystrokes, are not processed, i.e. neither stored by Hotjar nor transmitted to Hotjar (unless these entries are clearly intended for users for evaluation purposes, e.g. feedback forms).

For the aforementioned purposes, Hotjar stores and evaluates cookies with a pseudonymous identification number on user devices. The cookies that Hotjar uses have a different “lifetime”; some remain valid for up to 365 days, some remain valid only during the current visit.

The processed data of the users include in particular:

  • Devices and metadata: IP address of the terminal (collected and stored in anonymous format), screen resolution/display of the terminal, type of terminal (individual terminal identifiers), operating system and browser type, referring URL and domain;
  • Geographical location (country only);
  • Usage data and log data: Date and time when the online service was accessed, preferred language, user interactions, such as mouse events (movements, position and clicks), keyboard entries, websites accessed and interactions with their content and functions;
  • Content data: Entries in surveys and feedback forms.

If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). GDPR).

Users can prevent Hotjar from collecting the data by using their browser’s Do-Not-Track settings or by clicking and following the instructions on the following link: https://www.hotjar.com/legal/compliance/opt-out.

Datenschutzerklärung von Hotjar: https://www.hotjar.com/legal/policies/privacy.
Cookie-Richtlinie: https://www.hotjar.com/legal/policies/cookie-information

LinkedIN Insight

We use the LinkedIn Insight Conversion Tool from LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA, which allows us to obtain information about your use of our Web site and to display promotional content tailored to your interests on other Web sites. To do this, a 120-day cookie is placed in your browser that allows LinkedIn to recognize you when you visit a website. LinkedIn uses this information to provide us with anonymous ad activity reports and information about how you interact with our website.

You can deactivate the LinkedIn Insight Conversion Tool and interest-based advertising by opting out at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
If you are a LinkedIn member, click on the field “Reject LinkedIn”. Other visitors click on “Reject”.

Further information on data protection at LinkedIn can be found here: https://www.linkedin.com/legal/privacy-policy#choices-oblig

Your rights

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;
datenschutz@soravia.at; 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 marketing@soravia.at.