Privacy Policy
1 Introduction
1.1 This Privacy Policy of A2A Holding GmbH (“Policy”) describes how A2A Holding, Getreidegasse 47, Top 15, 5020 Salzburg, Austria, collects and processes personal data about you when you visit our website (“Website”) and use it. We process your data exclusively in accordance with applicable legal provisions (GDPR, DSG 2018, TKG 2003).
2 Data We Collect
2.1 Information You Provide to Us. When you visit our website, correspond with us, participate in one of our promotional campaigns, take part in our surveys, post on our websites, subscribe to our newsletter, purchase our products, create an account, or communicate with us via one of our social media platforms—such as our chatbot tools—you may provide us with information about yourself. This may include data that can be used to identify you (“personal data”). When we ask you to provide certain data, we collect the data contained in the respective forms or on the corresponding pages. In addition, you may voluntarily provide us with further information when you contact us or interact with us in any other way.
2.2 If you are a regular visitor to our website, you may, if you wish, create a user account (“User Account”) with us. The information you provide when creating a User Account includes, among other things, your name, your username for the account, your email address, your country of residence, and your phone number. When you register to create a user account with us, you will also create a unique password that allows you to access your account. We also collect information regarding your preferred content on our websites (such as videos you like).
2.3 If you decide to purchase goods or services on our website, we will also collect your shipping address, billing address, and payment information. Please note that we do not store your payment information; this is handled by an external payment service provider.
2.4 If you decide to subscribe to one of our newsletters or receive other forms of direct communication from us, you may provide us with your name, email address, gender, date of birth, and interests.
2.5 When you visit our website, we may use your personal information to enhance your user experience through recommendations tailored specifically to you. This may include recommending certain content to you based on your search history or your Facebook “Likes” and interests. We do not collect your username or password for Facebook, Twitter, or Google+. However, we may collect certain information from these websites that indicates whether you have Facebook, Twitter, or Google+ accounts. This data is used to access or obtain specific information about you from your Facebook, Twitter, or Google+ profiles, thereby improving your user experience and providing you with content that is relevant to you. This refers to information that you have made public on your profile. We do not access your personal page settings.
2.7. Data Collected Automatically. When you visit our website, we may automatically collect the following data: your IP address, login information, location, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit, including the URL clickstream (sequence of page views) to, through, and from our website, your advertising ID (if supported by your device, such as an Apple or Google product), products you’ve viewed or searched for, videos you’ve opened, download errors, duration of visits to specific pages, and interactions between pages and apps, media downloads for offline use, screen resolution, device processing and storage capacity, playback errors and buffering issues, user behavior, such as duration of app usage, as well as device IDs (for example, an IMEI address—a unique identifier assigned to mobile phones that is used by GSM networks to enable them to recognize valid mobile devices). Automatic data collection is carried out using various technologies, including “cookies” and “web beacons.”
2.9 Data we receive from other sources. We may receive data about you from other sources if you use any of our other services (e.g., payment service providers) We also work closely with third parties (including, for example, business partners, subcontractors for technical services, payment and delivery services, advertising networks, analytics providers, search engine operators, and credit bureaus) and may receive personal data about you from them (including publicly available data).
3 Why We Use Your Data
3.1 We use the data we collect to provide you with the best possible user experience when you visit our website, use our apps, or interact with us—including when you use our services and products. This includes using your data for the following purposes:
- (a) Providing and improving our products and services: We use your data to provide you with the products and services you have requested through the website, including when you make purchases, when we send you a confirmation email, or when we contact you regarding your account. We use your data to improve and customize our website, products, and services so that they better align with our users’ behavior and technical capabilities.
- (b) Setting up and managing your account: We use your information to set up your account and manage our relationship with you. We also use your information to communicate with you regarding your account and our services.
- (c) Website and App Management: We use your data to manage our website and apps for internal operations, including for troubleshooting purposes, and to better understand any errors you may encounter while using our website and apps.
- (d) Improving the use and content of our websites and apps: We use your data to improve the content of our websites and apps and to ensure that the content is displayed as effectively as possible for you and on your devices.
- (e) Protection and Security. We use data collected on our website and in our apps as part of our efforts to ensure the protection and security of our website and apps and to better manage our IT systems. We use the data captured by our security systems to provide better protection and enhanced security for our event venues and attendees.
- (f) Marketing: We use your data to communicate with you and keep you informed about our activities and events, as well as those of third parties that may be of interest to you, and to provide you with suggestions and recommendations on our website and in our apps regarding goods or services that may be of interest to you. You will receive this information from us via email (subject to your prior consent, where required by law), personalized messages on our websites, targeted advertisements on our website and on external platforms, text messages, social media, or by phone.
- (g) Online Marketing: We use your data to measure and understand the effectiveness of the advertisements we deliver to you and others, and to provide you with relevant advertisements. We also use your data when we communicate with you via social media to build and maintain our social media brand.
- (h) Personalization and Improvement of the User Experience: To the extent permitted by law, we may combine data from external sources, including social media websites, with data you have provided and data we have collected, including data obtained through cookies and web beacons. We may use this data and the aggregated data to learn more about your preferences as our customer, improve your user experience on our website and in our apps, and provide you with information, content, and offers tailored to you.
- (i) Enabling a seamless experience across all devices and platforms: We reconcile the data we have collected from you and received from you on one device or platform with the data we have collected or received from you on other devices or platforms.
- (j) Providing customer service and handling complaints and inquiries: We may use your information to provide you with more efficient customer service and to handle your complaints or inquiries.
- (k) Making Required Disclosures and Enforcing the Law: We may use your data to make the necessary disclosures in response to requests for information that we are required by law to comply with from law enforcement or regulatory authorities, supervisory bodies, or oversight agencies, or in connection with the defense of legal claims, as well as to enforce our terms and conditions and/or this policy.
- (l) Conducting sales, transfers, or restructurings of one of our business units.
4 Legal Basis for the Use of Your Data
4.1 The processing of your personal data is based on a broad legal basis, including, among others:
- (a) If you have given your consent: for example, we need your consent to process your personal data for direct marketing activities, such as when we use cookie technologies or when we process special categories of personal data, such as your clothing style.
- (b) If the processing is necessary for the performance of a contract: for example, to deliver goods you have ordered from our online store or to facilitate an in-app purchase,
- (c) When we are required to comply with a legal obligation: for example, we may need to disclose your data to a law enforcement agency or to your or our legal representatives who are representing us in a legal dispute.
- (d) When processing is necessary based on our legitimate interests; these include, among other things: (1) Providing our products and services to you, (2) ensuring that your account is adequately protected and that our website, apps, network, and information technology are secure and used properly, (3) better understanding how you use our products, services, apps, and website, and making improvements, (4) researching and analyzing the products and services you request, (5) tailoring our content, marketing, advertising, and offers to your specific interests, (6) maintaining a presence on traditional and social media, (7) facilitating efficient communication, as well as social analytics and content performance on social media, (8) ensuring the security of our business operations and those of our business partners, and monitoring the areas surrounding and within our business premises to protect our employees, customers, and the general public from misconduct or criminal activity, (9) Developing and maintaining relationships with suppliers, partners, and other companies, as well as managing the individuals who work for them, (10) Staying informed about current market practices to ensure that we offer a service that is competitive and meets our customers’ expectations, and (11) Assessing the effectiveness of advertising on our website, our apps, and on partner websites. In some states, this type of data processing requires appropriate consent. We will obtain your consent if we are legally required to do so.
5. Sharing and Disclosure of Data
5.1 We may disclose your data to third parties for the purposes specified in Section 3 of this Policy, including to external online platforms, social media platforms, and entities that provide services to us or act as our agents, such as subcontractors (including their authorized representatives) and consultants, advertising agencies, advertising networks, IT providers, database providers, backup and disaster recovery specialists, email providers, and other service providers necessary for improving our products and services.
5.2
- (a) We share aggregated, anonymized, or other non-personally identifiable data with advertising partners, ad networks, and social networks that need this data to provide you and others with selected, relevant advertisements. We also use aggregated data to help advertising partners reach the type of audience they wish to target.
- (b) We use the personal data we have collected from you to help our advertising partners show their ads to a target audience and to present our advertising messages to you, including through the Facebook Custom Audience and Google Customer Match tools. This means that you will be shown ads that are of greater interest to you based on the personal data we have collected from you, and
- (c) We share certain personal data about you and access data from analytics services and search engine providers that help us improve and optimize the website and apps in order to better tailor content and advertising to your individual needs.
5.3 Our suppliers and service providers are required to comply with our data processing and security standards. The data we provide to them, including your personal information, is made available solely for the purpose of fulfilling their duties. They are not authorized to use your personal information for any purposes other than those set forth in this policy.
Data Transfer to Payment Service Providers:
Data Transfer to Newsletter Service Providers:
We transfer your data to Mailchimp for the purpose of sending newsletters and managing subscribers.
You can find out how Mailchimp protects and uses your data here: Information on the General Data Protection Regulation: https://eepurl.com/gv_uXD
6 Opt-in or Opt-out in the Context of Direct Marketing
6.1 We and selected third parties may use the information you provide to us on our website and in our apps for direct marketing purposes, to send you updates, newsletters, event notifications, or other communications that we believe may be of interest to you.
6.2 If required by law, we will obtain your consent before sending you direct marketing materials. In any case, we will provide you with the option to opt out in every communication we send you.
6.3 You may opt out of receiving direct marketing materials from us at any time by contacting us via email at the address provided in Section 17 or by using the opt-out options provided in our email communications.
7 Analysis and Reporting Tools
7.1 To ensure that our online advertising is tailored to you and of interest to you, we analyze your behavior on our websites, partner websites, and apps, as well as your interactions with us. For example, we track when you click on articles or our ads (whether on our websites or external websites), when you interact with us on social media (by mentioning us or our products), when you communicate directly with us (including via our chatbot tools used on social media), when you purchase products from us, when you attend our events, when you open and interact with our marketing communications, and where you come from when you visit our website or download our apps.
7.2 We use third-party software. To this end, we use cookies or similar technologies to collect data about your usage behavior and to provide you with interest-based advertisements.
7.3 We also use third-party tools, including Facebook Custom Audience and Google Customer Match, to deliver advertisements to you on external platforms (including Facebook, YouTube, and Google). These tools are provided by third-party vendors, such as Facebook and Google. They enable us to match A2A Holding GmbH customers and website visitorswith Facebook or Google users in order to provide tailored advertising. For this purpose, we share your data with the relevant providers (e.g., Facebook and Google) and use cookies or similar technologies on our website to analyze how effective our advertising is on other websites. For more information about how Facebook or Google uses data, please visit the following links: https://www.facebook.com/ads/about or https://support.google.com/google-ads/answer/6379332?hl=en. You can opt out of receiving advertisements via this tool through your Facebook or Google settings, or by contacting us via email, as described in more detail in Section 17 below.
8 Cookies and Other Technologies
8.1 We collect data automatically through the use of “cookies.” Cookies may be set by us or by third parties. A cookie is a text file containing a small amount of data that a website can send to your browser and that is then stored on your computer as an anonymous tag to identify your computer, but not you. Some pages on our website use cookies to provide you with better service when you return to the site. You can set your browser to notify you before you receive a cookie; this gives you the opportunity to decide whether to accept the cookie. You can also set your browser to disable cookies. If you do so, some services on our website may not function properly.
8.2 We also use web beacons, which are commonly known as “single-pixel GIFs,” “clear GIFs,” or “tags.” Web beacons are small graphic files that may be included on our website. Web beacons allow us to optimize our products and services and provide us and third-party partners with analytical data, such as the number of visitors to our website. We may also use web beacons in our email correspondence to determine whether you open an email or take further actions. We also collaborate with other organizations to place our web beacons on their websites or in their advertisements. We do this so that we can compile statistics on how often clicking an ad on a website operated by A2A Holding GmbH or an advertising partner leads to a purchase or other interaction on an advertising partner’s website.
8.3 For our apps, we automatically collect data through the use of device IDs (“IDs”). An ID is a specific sequence of numbers and letters (“string”) that is assigned to your device but does not identify you personally. The ID allows us and third parties we select to track your behavior when you use the app. Nearly every app uses ID technology. IDs serve various purposes; for example, they remember your preferences and generally provide a better user experience. IDs can tell us, for example, whether you have used our app before or if this is your first time. They also help ensure that the ads you see through the app are tailored to you and your interests. Because of how they work, IDs are extremely useful for improving your user experience.
8.4. More information about the specific cookies and web beacons used on this website can be found in the Cookie Policy.
9 Links to Other Websites and Social Media
9.1 Links to other websites are provided for informational purposes only. Other websites are beyond our control and are not covered by this policy. When you access other websites via the links provided, the operators of those websites may collect data about you, which they may then use in accordance with their respective privacy policies in ways that may differ from our policy.
9.2 Some pages on our website may feature third-party content, applications, or plug-ins that track your use of such content, applications, or plug-ins and/or optimize your experience with them. For example, if you share an article on our website with others using a social media share button (e.g., Facebook, Twitter, or Google Plus), this action is recorded by the social network that created the button. More information about social media plug-ins on our website can be found in our Cookie Policy.
10 Data Retention
10.1 We will not retain your data for longer than is necessary for our business purposes or as required by law or regulatory requirements.
10.2 We will retain your data for as long as you have an account with one of our brands and, beyond that, for as long as necessary to comply with our legal obligations, such as retaining data for tax and accounting purposes. Your data will be retained in accordance with our internal data retention policies.
10.3 If you object to receiving direct marketing materials from us or opt out of receiving them, we will remove your contact information and your consent to marketing activities to ensure that you no longer receive promotional communications from us in the future. We will not delete personal data if it is required for investigative or inquiry purposes or in connection with a legal dispute. In such cases, the data will be retained until the matter is fully resolved.
10.4 In all cases, we will continue to protect your personal data in accordance with the provisions set forth in this policy. We will also routinely update our data to ensure that it is always up to date.
11 Your Rights
11.1 Depending on applicable law, you may, under certain circumstances, have the following rights with respect to your personal data:
- (a) Right to access your personal data. If you would like a copy of the personal data we have stored about you, please contact us at the email address provided below. Before we respond to your request, we may ask you to verify your identity and provide further details about your request. We will endeavor to process your request within a reasonable timeframe, and in any case within the timeframe prescribed by law.
- (b) Right to rectification, erasure, or restriction of processing of your personal data. If you wish to rectify or erase your personal data or restrict its processing, please contact us at the email address provided below. It is your responsibility to ensure that the information you provide is truthful, accurate, and complete, and to keep it up to date at all times.
- (c) Right to Withdraw Consent. If you have given your consent to the processing of your data, you may withdraw it at any time by contacting us at the email address provided in Section 17 below.
- (d) Right to Data Portability. You may ask us to assist you in transferring some of your data to other companies. In this regard, you have the right to request that we transfer your data to another company in a machine-readable format. You may submit your request via email using the email address provided below.
- (e) Right to Object. You may object to the manner in which we process your personal data or to direct marketing based on profiling, provided there is a legitimate interest in doing so, by submitting your request via email to the email address provided below.
- (f) The right not to be subject to automated decision-making processes. (For further details, please see section 17 below.)
- (g) Right to file a complaint with a supervisory authority. You may contact your local supervisory authority if you have a complaint regarding the way we handle your personal data.
11.2 If you have created a user account, you can access the personal data we have about you through your user account, obtain a copy of it, and correct, supplement, or delete any inaccurate data. You may also close your user account at any time.
11.3 If you wish to exercise any of the rights listed above, please contact us at the email address provided in Section 17 below.
12 Profiling
12.1 We may use your information to try to learn more about you so that, where appropriate, we can better predict which products and services you might be interested in.
12.2 On some of our e-commerce websites, we engage service providers that use automated decision-making processes to verify your address and creditworthiness. This allows us to ensure that we are using accurate address information and to assess the risk of nonpayment for our products and services.
13 Data Security
13.1 We use physical, technical, and administrative measures to protect your personal data stored by us against unauthorized access, collection, use, disclosure, copying, alteration, or deletion. All data you provide to us is stored on secure servers.
13.2 If you have a password to access our website or app, you are responsible for keeping the password secure and confidential.
14 Global Transmission
14.1 Because the Internet is a global environment, the collection and processing of personal data via the Internet inevitably involves the international transfer of data. Although we typically store the personal data we collect about you through our website in your region (for example, in the European Economic Area for visitors from Europe), your personal data may also be transferred to parties outside your region (where different data protection laws apply, such as in the U.S.), including affiliates of A2A Holding GmbH.
14.2 When this occurs, we have implemented safeguards and data protection measures to ensure that your data is adequately protected in third countries, for example, by using standard contractual clauses or, where applicable, relying on the Privacy Shield. If you would like more information on this, please contact us at the email address provided in Section 17.
15 Use of the Website by Minors
15.1 By using this website, you confirm that you are over 16 years of age. If you are 16 years old or younger, you must first obtain consent from your parents or legal guardians before providing us with data through our website or apps. Providing data without this consent is prohibited. If you nevertheless provide us with data, we will cease processing that data as soon as we become aware of it.
- Changes to the Policy
16.1 This policy was last updated on September 25, 2020. Whenever this policy is materially amended, a notice will be posted on our website for a period of 30 days. By continuing to use our website or app, you agree to the respective changes.
17 Questions, Concerns, and Complaints Regarding the Policy; Contact Information for the Data Protection Officer
17.1 This website is maintained by A2A Holding GmbH. If you have any questions, concerns, or complaints regarding this policy or our handling of your data, please send us an email at datenschutz@armargentum.com.