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The following privacy policy is intended to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).
The terms used are not gender-specific.
As of: June 12, 2024
Table of contents
My Solo OG
Stubenring 20/VI
1010 Vienna
Austria
Email address: office@mysolo.at
Phone number: +436605585588
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.
National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer, and automated decision-making in individual cases.
Note on the applicability of the GDPR and Swiss DSG: This privacy policy serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data,” “overriding interest,” and “sensitive personal data” used in the Swiss FADP, the terms ‘processing’ of “personal data,” “legitimate interest,” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DSG within the scope of the Swiss DSG.
In accordance with legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of threats to the rights and freedoms of natural persons.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability, and separation. Furthermore, we have established procedures that guarantee the exercise of data subjects' rights, the deletion of data, and responses to data breaches. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
In the course of our processing of personal data, it may happen that this data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.
Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if processing takes place in connection with the use of third-party services or the disclosure or transfer of data to other persons, bodies, or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent, or in the case of contractual or legally required transfers (Art. 49 (1) GDPR). In addition, we will inform you of the basis for third-country transfers for individual providers from third countries, whereby adequacy decisions take precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain US companies as adequate within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ . We will inform you in our privacy policy which service providers we use are certified under the Data Privacy Framework.
We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing procedures.If there are several specifications regarding the storage period or deletion periods for a piece of data, the longest period shall always apply.
If a period does not expressly begin on a specific date and lasts at least one year, it shall automatically commence at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period shall be the date on which the termination or other termination of the legal relationship takes effect.
We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.
Further information on processing procedures, methods, and services:
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
We process data relating to our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”), within the framework of contractual and comparable legal relationships and associated measures, and with regard to communication with contractual partners (or pre-contractual), for example to respond to inquiries.
We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for the purposes of administrative tasks associated with these obligations and for company organization. We also process the data on the basis of our legitimate interests in both proper and economic business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, within the framework of this privacy policy.
We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for archiving for legal reasons (e.g. for tax purposes, usually ten years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, after the end of the order.
Further information on processing procedures, methods, and services:
Personal data of service recipients and clients—including customers, clients, or, in special cases, patients, business partners, and other third parties—is processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.
The data collected is used to fulfill contractual obligations and to organize operational processes efficiently. This includes processing business transactions, managing customer relationships, optimizing sales strategies, and ensuring internal billing and financial processes. In addition, the data supports the protection of the rights of the controller and facilitates administrative tasks and the organization of the company.
Personal data may be disclosed to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. The data will be deleted after the expiry of the statutory retention periods or when the purpose of the processing no longer applies. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.
Further information on processing operations, procedures, and services:
In the course of our business activities, and in compliance with statutory requirements, we use additional services, platforms, interfaces, or plug-ins provided by third parties (collectively referred to as “services”). Their use is based on our interests in the proper, lawful, and economically efficient operation of our business and our internal organization.
In the context of contractual and other legal relationships, on the basis of statutory obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, for this purpose, engage additional service providers alongside banks and credit institutions (collectively referred to as “payment service providers”).
The data processed by the payment service providers include identification data, such as name and address; banking data, such as account numbers or credit card numbers; passwords, TANs, and checksums; as well as contract-related, amount-related, and recipient-related information. This information is required in order to carry out the transactions. However, the data entered are processed and stored exclusively by the payment service providers. This means that we do not receive any account- or credit-card-related information, but only information confirming or rejecting a payment.
In some cases, the payment service providers may transmit data to credit reference agencies. Such transmission serves the purpose of identity and creditworthiness checks. In this regard, we refer to the general terms and conditions and the data protection notices of the respective payment service providers.The terms and conditions and the data protection notices of the respective payment service providers apply to payment transactions and can be accessed on their respective websites or transaction applications. We also refer to these for further information and for the exercise of rights of withdrawal, rights of access, and other data subject rights.
Further information on processing operations, procedures, and services:
We process users’ data in order to provide our online services to them. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the users’ browser or end device.
Further information on processing operations, procedures, and services:
Cookies are small text files or other storage records that store information on end devices and read information from them. For example, they are used to store the login status in a user account, the contents of a shopping cart in an online shop, or the content accessed or functions used within an online offering. Cookies may also be used for various other purposes, such as ensuring functionality, security, and convenience of online offerings, as well as for analyzing visitor traffic.
Information on consent: We use cookies in accordance with statutory provisions. Therefore, we obtain prior consent from users unless such consent is not required by law. In particular, consent is not required where the storage and retrieval of information, including cookies, is strictly necessary in order to provide users with a telemedia service expressly requested by them (i. e., our online offering). Revocable consent is clearly communicated to users and includes information on the respective cookie usage.
Information on data protection legal bases: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we request consent. If users give their consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies are processed on the basis of our legitimate interests (e. g., in the economically efficient operation of our online offering and the improvement of its usability) or, where processing takes place in the context of fulfilling our contractual obligations, where the use of cookies is necessary in order to meet those contractual obligations. The purposes for which we use cookies are explained in the course of this privacy policy or within our consent and processing procedures.
Storage duration: With regard to storage duration, the following types of cookies are distinguished:
General information on withdrawal and objection (opt-out): Users may withdraw any consent they have given at any time and may also object to processing in accordance with statutory requirements, including by using their browser’s privacy settings.
Further information on processing operations, procedures, and services
Users may create a user account. As part of the registration process, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of the performance of contractual obligations. The data processed include, in particular, login information (username, password, and an email address).
In the course of using our registration and login functions as well as the user account, we store the IP address and the time of the respective user action. Storage takes place on the basis of our legitimate interests and those of the users in protecting against misuse and other unauthorized use. As a rule, these data are not disclosed to third parties unless such disclosure is necessary for the assertion of our claims or we are legally obliged to do so.
Users may be informed by email about processes relevant to their user account, such as technical changes.
Further information on processing operations, procedures, and services:
When contacting us (e. g., by post, contact form, email, telephone, or via social media), as well as within the scope of existing user and business relationships, the information provided by the inquiring persons is processed insofar as this is necessary to respond to contact requests and any requested measures.
Further information on processing operations, procedures, and services:
We send newsletters, emails, and other electronic notifications (hereinafter referred to as “newsletters”) exclusively with the recipients’ consent or on the basis of a statutory legal basis. Where the content of the newsletter is specified at the time of subscription, such content is decisive for the users’ consent. As a rule, providing an email address is sufficient to subscribe to our newsletter. However, in order to offer a personalized service, we may ask for the user’s name for personal addressing in the newsletter or for additional information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove that consent was previously given. Processing of these data is restricted to the purpose of potentially defending legal claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a suppression list (so-called “blocklist”). vor.
The logging of the subscription process is carried out on the basis of our legitimate interests for the purpose of proving its proper execution. Where we engage a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system.
Content:
Information about us, our services, promotions, and offers.
Further information on processing operations, procedures, and services:
We process the personal data of participants in prize draws and competitions only in compliance with the applicable data protection provisions, insofar as the processing is contractually required for the provision, implementation, and administration of the prize draw, the participants have consented to the processing, or the processing serves our legitimate interests (e.g., in ensuring the security of the prize draw or protecting our interests against misuse, such as by collecting IP addresses when submitting prize draw entries).
If participants’ submissions are published as part of the prize draw (e.g., as part of a vote, the presentation of prize draw entries or winners, or reporting on the prize draw), we point out that participants’ names may also be published in this context. Participants may object to this at any time.
If the prize draw takes place within an online platform or a social network (e.g., Facebook or Instagram, hereinafter referred to as an “online platform”), the terms of use and data protection provisions of the respective platforms apply in addition. In such cases, we point out that we are responsible for the information provided by participants in the context of the prize draw, and that inquiries relating to the prize draw should be addressed to us.
Participants’ data are deleted as soon as the prize draw or competition has ended and the data are no longer required to notify the winners or because no further inquiries regarding the prize draw are to be expected. As a rule, participants’ data are deleted no later than six months after the end of the prize draw. Data relating to winners may be retained for a longer period, for example in order to respond to inquiries regarding prizes or to fulfill prize obligations; in such cases, the retention period depends on the type of prize and may amount to up to three years for goods or services, for example, in order to process warranty claims. In addition, participants’ data may be stored for a longer period, for example in the form of reporting on the prize draw in online and offline media.
If data are collected in the context of the prize draw for other purposes as well, their processing and retention period are governed by the data protection information applicable to such use (e.g., in the case of newsletter registration as part of a prize draw).
Web analytics (also referred to as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, in the form of pseudonymous values. By means of reach analysis, we can, for example, determine at what times our online offering or its functions or content are most frequently used, or encourage reuse. Likewise, we are able to identify which areas require optimization.
In addition to web analytics, we may also use testing procedures, for example to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles—i.e., data aggregated for a specific usage process—may be created for these purposes, and information may be stored in and subsequently read from a browser or an end device. The data collected include, in particular, visited websites and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data vis-à-vis us or the providers of the services we use, the processing of location data is also possible.
In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect users. In general, no clear personal data of users (such as email addresses or names) are stored within the scope of web analytics, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of users, but only the information stored in their profiles for the purposes of the respective procedures.
Information on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, users’ data are processed on the basis of our legitimate interests (i.e., our interest in providing efficient, cost-effective, and user-friendly services). In this context, we also refer to the information on the use of cookies in this privacy policy.
Further information on processing operations, procedures, and services:
We process personal data for the purposes of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on users’ potential interests, as well as the measurement of the effectiveness of such content.
For these purposes, so-called user profiles are created and stored in a file (the so-called “cookie”) or similar procedures are used by means of which information relevant to the display of the aforementioned content is stored about the user. This may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information such as the browser used, the computer system used, and information on usage times and functions used. If users have consented to the collection of their location data, such data may also be processed.
In addition, users’ IP addresses are stored. However, we use available IP masking procedures (i.e., pseudonymization by truncating the IP address) to protect users. As a rule, no clear personal data of users (such as email addresses or names) are stored within the scope of online marketing procedures; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing procedures know the users’ actual identities, but only the information stored in their profiles.
The information contained in the profiles is generally stored in cookies or by means of similar procedures. These cookies may subsequently also be read on other websites that use the same online marketing procedures, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the servers of the respective online marketing service providers.
By way of exception, it may be possible to associate clear personal data with profiles, primarily where users are, for example, members of a social network whose online marketing procedures we use and where the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example by giving consent during registration.
As a rule, we only receive access to aggregated information about the success of our advertisements. However, within the scope of so-called conversion tracking, we can determine which of our online marketing measures have led to a so-called conversion, i.e., for example, the conclusion of a contract with us. Conversion tracking is used solely for the purpose of analyzing the effectiveness of our marketing measures.
Unless otherwise stated, please assume that the cookies used are stored for a period of up to two years.
Information on legal bases: Where we ask users for their consent to the use of third-party providers, consent constitutes the legal basis for data processing. Otherwise, users’ data are processed on the basis of our legitimate interests (i.e., our interest in providing efficient, cost-effective, and user-friendly services). In this context, we also refer to the information on the use of cookies in this privacy policy.
Information on withdrawal and objection (opt-out)
We refer to the data protection notices of the respective providers and the opt-out options specified for each provider. If no explicit opt-out option is specified, users may, on the one hand, disable cookies in their browser settings. However, this may restrict the functionality of our online offering. We therefore additionally recommend the following opt-out options, which are offered collectively by region:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) United States: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
Further information on processing operations, procedures, and services:
We maintain online presences within social networks and, in this context, process user data in order to communicate with users active there or to provide information about us.
We note that user data may be processed outside the European Union. This may result in risks for users, as, for example, the enforcement of users’ rights may be made more difficult.
Furthermore, users’ data within social networks are generally processed for market research and advertising purposes. For example, usage profiles may be created on the basis of users’ usage behavior and the interests resulting therefrom. These profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to users’ interests. For this purpose, cookies are generally stored on users’ devices, in which usage behavior and users’ interests are stored. In addition, data may also be stored in the usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we also note that these can be exercised most effectively with the respective providers. Only they have direct access to the user data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you may contact us.
Further information on processing operations, procedures, and services:
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or maps (collectively referred to below as “content”).
Integration always requires that the third-party providers of this content process users’ IP addresses, as they would otherwise be unable to deliver the content to users’ browsers. The IP address is therefore necessary for the display of such content or functions. We endeavor to use only content whose respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Through such pixel tags, information such as visitor traffic on the pages of this website may be evaluated. The pseudonymous information may also be stored in cookies on users’ devices and may include, among other things, technical information about the browser and operating system, referring websites, visit times, and other information on the use of our online offering, and may also be combined with such information from other sources.
Information on legal bases: Where we ask users for their consent to the use of third-party providers, consent constitutes the legal basis for data processing. Otherwise, users’ data are processed on the basis of our legitimate interests (i.e., our interest in providing efficient, cost-effective, and user-friendly services). In this context, we also refer to the information on the use of cookies in this privacy policy.
Further information on processing operations, procedures, and services:
We ask you to regularly review the content of our privacy policy. We adapt this privacy policy as soon as changes to the data processing activities carried out by us make this necessary. We will inform you if the changes require any action on your part (e.g., consent) or any other individual notification.
Where we provide addresses and contact details of companies and organizations in this privacy policy, please note that such addresses may change over time and ask that you verify the information before making contact.
This section provides an overview of the terms used in this privacy policy. Where terms are defined by law, the statutory definitions apply. The following explanations are intended primarily to aid understanding.