Data protection

Privacy Policy

Table of Contents

Introduction and Overview

We have drafted this Privacy Policy (Version 01.12.2022-112344467) to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (hereinafter "data") we, as the controller – and the processors (e.g., providers) we have commissioned – process, will process in the future, and what legitimate options you have. The terms used are to be understood as gender-neutral.
In short: We provide you with comprehensive information about the data we process about you.

Privacy policies usually sound very technical and use legal jargon. This privacy policy, however, aims to describe the most important things to you as simply and transparently as possible. Where transparency is enhanced, technical terms are explained in a user-friendly manner, links to further information are provided, and graphics are used. We thus inform you in clear and simple language that, in the course of our business activities, we only process personal data when there is a corresponding legal basis. This is certainly not possible if one provides as brief, unclear, and legal-technical explanations as are often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative, and perhaps some information is included that you were not yet aware of.
If you still have questions, we ask you to contact the responsible body named below or in the imprint, follow the available links, and view further information on third-party sites. Our contact details can, of course, also be found in the imprint.

Scope

This privacy policy applies to all personal data processed by us in the company and to all personal data processed by companies commissioned by us (processors). By personal data, we mean information within the meaning of Art. 4 No. 1 GDPR, such as name, email address, and postal address of a person. The processing of personal data ensures that we can offer and bill our services and products, whether online or offline. The scope of this privacy policy includes:

  • all online presences (websites, online shops) that we operate
  • social media presences and email communication
  • mobile apps for smartphones and other devices

In short: The privacy policy applies to all areas in which personal data is processed in a structured manner within the company via the mentioned channels. Should we enter into legal relationships with you outside of these channels, we will inform you separately if necessary.

Legal Basis

In the following privacy policy, we provide you with transparent information about the legal principles and regulations, i.e., the legal bases of the General Data Protection Regulation, which allow us to process personal data.
As far as EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016. You can, of course, read this EU General Data Protection Regulation online on EUR-Lex, the access to EU law, at https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=celex%3A32016R0679.

We process your data only if at least one of the following conditions applies:

  1. Consent (Article 6(1)(a) GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of your data entered in a contact form.
  2. Contract (Article 6(1)(b) GDPR): To fulfill a contract or pre-contractual obligations with you, we process your data. For example, if we conclude a purchase agreement with you, we need personal information in advance.
  3. Legal Obligation (Article 6(1)(c) GDPR): If we are subject to a legal obligation, we process your data. For example, we are legally obliged to keep invoices for accounting purposes. These usually contain personal data.
  4. Legitimate Interests (Article 6(1)(f) GDPR): In the case of legitimate interests that do not restrict your fundamental rights, we reserve the right to process personal data. For example, we must process certain data to operate our website securely and economically efficiently. This processing is therefore a legitimate interest.

Further conditions such as the performance of tasks in the public interest and the exercise of official authority, as well as the protection of vital interests, generally do not apply to us. Should such a legal basis nevertheless be relevant, it will be indicated at the appropriate place.

In addition to the EU regulation, national laws also apply:

  • In Austria, this is the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Datenschutzgesetz), or DSG for short.
  • In Germany, the Bundesdatenschutzgesetz, or BDSG for short, applies.

Should further regional or national laws apply, we will inform you about them in the following sections.

Contact Information of the Controller

Should you have any questions regarding data protection or the processing of personal data, you will find the contact details of the responsible person or entity below:
Gregor Schatzer
Römerweg 11
6408 Pettnau

Email: office@greemillaa.com
Phone: +43 676 3927839
Imprint: https://www.greemillaa.com/impressum/

Storage Duration

It is a general criterion for us that we store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as the reason for data processing no longer exists. In some cases, we are legally obliged to store certain data even after the original purpose has ceased to exist, for example, for accounting purposes.

Should you wish to delete your data or revoke your consent to data processing, the data will be deleted as quickly as possible and as far as there is no obligation to store it.

We will inform you about the specific duration of the respective data processing further down, if we have further information about it.

Rights according to the General Data Protection Regulation

According to Articles 13, 14 GDPR, we inform you about the following rights you are entitled to, to ensure fair and transparent data processing:

  • According to Article 15 GDPR, you have the right to information about whether we process your data. If this is the case, you have the right to receive a copy of the data and to know the following information:
    • for what purpose we process the data;
    • the categories, i.e., the types of data processed;
    • who receives this data and, if the data is transferred to third countries, how security can be guaranteed;
    • how long the data is stored;
    • the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
    • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
    • the origin of the data if we have not collected it from you;
    • whether profiling is carried out, i.e., whether data is automatically evaluated to create a personal profile of you.
  • According to Article 16 GDPR, you have the right to rectification of data, which means that we must correct data if you find errors.
  • According to Article 17 GDPR, you have the right to erasure ("right to be forgotten"), which specifically means that you may request the erasure of your data.
  • According to Article 18 GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
  • According to Article 20 GDPR, you have the right to data portability, which means that we will provide your data to you in a common format upon request.
  • According to Article 21 GDPR, you have a right to object, which, if exercised, leads to a change in processing.
    • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you can object to the processing. We will then check as quickly as possible whether we can legally comply with this objection.
    • If data is used for direct marketing, you can object to this type of data processing at any time. We may no longer use your data for direct marketing thereafter.
    • If data is used for profiling, you can object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
  • According to Article 22 GDPR, you have the right not to be subject to a decision based solely on automated processing (e.g., profiling) in certain circumstances.
  • According to Article 77 GDPR, you have the right to lodge a complaint. This means you can complain to the data protection authority at any time if you believe that the processing of personal data violates the GDPR.

In short: You have rights – do not hesitate to contact the responsible body listed above!

If you believe that the processing of your data violates data protection law or that your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the Data Protection Authority, whose website you can find at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). For our company, the following local data protection authority is responsible:

Austrian Data Protection Authority

Director: Mag. Dr. Andrea Jelinek
Address: Barichgasse 40-42, 1030 Vienna
Phone No.: +43 1 52 152-0
Email address: dsb@dsb.gv.at
Website: https://www.dsb.gv.at/

Data Processing Security

To protect personal data, we have implemented both technical and organizational measures. Where possible, we encrypt or pseudonymize personal data. This makes it as difficult as possible, within our capabilities, for third parties to infer personal information from our data.

Art. 25 GDPR speaks of "data protection by design and by default" and means that security is always considered when it comes to both software (e.g., forms) and hardware (e.g., access to the server room), and appropriate measures are taken. In the following, we will go into specific measures if necessary.

TLS encryption with https

TLS, encryption, and https sound very technical, and they are. We use HTTPS (Hypertext Transfer Protocol Secure) to transmit data securely over the internet.
This means that the entire transmission of all data from your browser to our web server is secured - no one can "eavesdrop".

With this, we have introduced an additional layer of security and comply with data protection by design (Article 25(1) GDPR). By using TLS (Transport Layer Security), an encryption protocol for secure data transmission on the internet, we can ensure the protection of confidential data.
You can recognize the use of this data transmission security by the small padlock symbol in the upper left of the browser, to the left of the internet address (e.g., beispielseite.de) and the use of the https scheme (instead of http) as part of our internet address.
If you would like to know more about encryption, we recommend searching Google for "Hypertext Transfer Protocol Secure wiki" to get good links to further information.

Communication

Communication Summary
???? Data subjects: Everyone who communicates with us by phone, email, or online form
???? Data processed: e.g., phone number, name, email address, entered form data. More details can be found for each contact method used
???? Purpose: Handling communication with customers, business partners, etc.
???? Storage duration: Duration of the business case and legal requirements
?? Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. b GDPR (contract), Art. 6 para. 1 lit. f GDPR (legitimate interests)

If you contact us and communicate by phone, email, or online form, personal data may be processed.

The data will be processed for handling and processing your inquiry and the associated business transaction. The data will be stored for as long as required by law.

Affected persons

All those who seek contact with us via the communication channels we provide are affected by the aforementioned processes.

Telephone

If you call us, the call data will be stored pseudonymously on the respective end device and by the telecommunications provider used. In addition, data such as name and telephone number may subsequently be sent by email and stored for answering inquiries. The data will be deleted as soon as the business case has been completed and legal requirements permit.

Email

If you communicate with us by email, data may be stored on the respective end device (computer, laptop, smartphone, etc.) and data will be stored on the email server. The data will be deleted as soon as the business case has been completed and legal requirements permit.

Online Forms

If you communicate with us using an online form, data will be stored on our web server and, if applicable, forwarded to one of our email addresses. The data will be deleted as soon as the business case has been completed and legal requirements permit.

Legal Basis

The processing of data is based on the following legal bases:

  • Art. 6 para. 1 lit. a GDPR (Consent): You give us consent to store your data and to continue to use it for purposes related to the business case;
  • Art. 6 para. 1 lit. b GDPR (Contract): There is a necessity for the fulfillment of a contract with you or a processor such as the telephone provider, or we must process the data for pre-contractual activities, such as the preparation of an offer;
  • Art. 6 para. 1 lit. f GDPR (Legitimate Interests): We want to conduct customer inquiries and business communication in a professional manner. For this, certain technical facilities such as email programs, Exchange servers, and mobile network operators are necessary to conduct communication efficiently.

Cookies

Cookies Summary
???? Data subjects: Website visitors
???? Purpose: dependent on the respective cookie. More details can be found below or from the software manufacturer that sets the cookie.
???? Data processed: Dependent on the cookie used. More details can be found below or from the software manufacturer that sets the cookie.
???? Storage duration: dependent on the respective cookie, can vary from hours to years
?? Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are cookies?

Our website uses HTTP cookies to store user-specific data.
In the following, we explain what cookies are and why they are used so that you can better understand the following privacy policy.

Whenever you surf the internet, you use a browser. Well-known browsers include Chrome, Safari, Firefox, Internet Explorer, and Microsoft Edge. Most websites store small text files in your browser. These files are called cookies.

One thing is undeniable: cookies are truly useful helpers. Almost all websites use cookies. More precisely, they are HTTP cookies, as there are also other cookies for other application areas. HTTP cookies are small files that are stored by our website on your computer. These cookie files are automatically placed in the cookie folder, so to speak, the "brain" of your browser. A cookie consists of a name and a value. When defining a cookie, one or more attributes must also be specified.

Cookies store certain user data from you, such as language or personal page settings. When you revisit our site, your browser transmits the "user-related" information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are used to. In some browsers, each cookie has its own file; in others, such as Firefox, all cookies are stored in a single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie from the server, which the browser uses again as soon as another page is requested.

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner websites (e.g., Google Analytics). Each cookie must be assessed individually, as each cookie stores different data. The expiration time of a cookie also varies from a few minutes to several years. Cookies are not software programs and do not contain viruses, Trojans, or other "malware." Cookies also cannot access information on your PC.

For example, cookie data might look like this:

Name: _ga
Value: GA1.2.1326744211.152112344467-9
Purpose: Distinguishing website visitors
Expiration date: after 2 years

A browser should be able to support these minimum sizes:

  • At least 4096 bytes per cookie
  • At least 50 cookies per domain
  • At least 3000 cookies in total

What types of cookies are there?

The question of which specific cookies we use depends on the services used and will be clarified in the following sections of the privacy policy. At this point, we would like to briefly discuss the different types of HTTP cookies.

One can distinguish 4 types of cookies:

Essential cookies
These cookies are necessary to ensure basic website functions. For example, these cookies are needed when a user places a product in the shopping cart, then navigates to other pages, and only later proceeds to checkout. These cookies prevent the shopping cart from being deleted even if the user closes their browser window.

Functional cookies
These cookies collect information about user behavior and whether the user receives any error messages. In addition, these cookies are also used to measure loading times and website behavior across different browsers.

Targeting cookies
These cookies ensure better user-friendliness. For example, entered locations, font sizes, or form data are stored.

Advertising cookies
These cookies are also called targeting cookies. They are used to deliver individually tailored advertising to the user. This can be very practical, but also very annoying.

Usually, when you visit a website for the first time, you will be asked which of these cookie types you wish to allow. And of course, this decision is also stored in a cookie.

If you want to know more about cookies and are not afraid of technical documentation, we recommend https://datatracker.ietf.org/doc/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) named "HTTP State Management Mechanism".

Purpose of processing via cookies

The purpose ultimately depends on the specific cookie. More details can be found below or from the software manufacturer that sets the cookie.

What data is processed?

Cookies are small helpers for many different tasks. Unfortunately, it is not possible to generalize what data is stored in cookies, but we will inform you about the processed or stored data within the scope of the following privacy policy.

Storage duration of cookies

The storage duration depends on the respective cookie and will be specified further below. Some cookies are deleted after less than an hour, others can remain stored on a computer for several years.

You also have an influence on the storage duration yourself. You can manually delete all cookies at any time via your browser (see also "Right to object" below). Furthermore, cookies based on consent will be deleted at the latest after revocation of your consent, whereby the lawfulness of storage until then remains unaffected.

Right to object – how can I delete cookies?

How and whether you want to use cookies is up to you. Regardless of which service or website the cookies originate from, you always have the option to delete, deactivate, or only partially allow cookies. For example, you can block third-party cookies, but allow all other cookies.

If you want to find out which cookies have been stored in your browser, if you want to change or delete cookie settings, you can find this in your browser settings:

Chrome: Delete, enable, and manage cookies in Chrome

Safari: Manage cookies and website data with Safari

Firefox: Delete cookies to remove data that websites have stored on your computer

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete and manage cookies

If you generally do not want cookies, you can set your browser to always inform you when a cookie is to be set. This way, you can decide for each individual cookie whether to allow it or not. The procedure varies depending on the browser. It is best to search for instructions on Google using the search term "delete cookies Chrome" or "disable cookies Chrome" in the case of a Chrome browser.

Legal Basis

Since 2009, there have been so-called "Cookie Directives." These stipulate that storing cookies requires your consent (Article 6(1)(a) GDPR). However, within EU countries, there are still very different reactions to these directives. In Austria, this directive was implemented in § 96(3) of the Telecommunications Act (TKG). In Germany, the Cookie Directives were not implemented as national law. Instead, this directive was largely implemented in § 15(3) of the Telemedia Act (TMG).

For strictly necessary cookies, even if no consent has been given, there are legitimate interests (Article 6(1)(f) GDPR), which are in most cases of an economic nature. We want to provide website visitors with a pleasant user experience, and certain cookies are often absolutely necessary for this.

To the extent that non-essential cookies are used, this only occurs with your consent. The legal basis in this respect is Art. 6 para. 1 lit. a GDPR.

In the following sections, you will be informed more precisely about the use of cookies, if the software used employs cookies.

Website Builder Systems Introduction

Website Builder Systems Privacy Policy Summary
???? Data subjects: Website visitors
???? Purpose: Optimizing our service
???? Data processed: Data such as technical usage information like browser activity, clickstream activities, session heatmaps, as well as contact details, IP address, or your geographical location. More details can be found below in this privacy policy and in the privacy policy of the providers.
???? Storage duration: depends on the provider
?? Legal bases: Art. 6 para. 1 lit. f GDPR (Legitimate Interests), Art. 6 para. 1 lit. a GDPR (Consent)

What are website builder systems?

We use a website builder system for our website. Builder systems are special forms of a Content Management System (CMS). With a builder system, website operators can create a website very easily and without programming knowledge. In many cases, web hosts also offer builder systems. By using a builder system, personal data from you can also be collected, stored, and processed. In this privacy text, we provide you with general information about data processing by builder systems. More detailed information can be found in the providers' privacy policies.

Why do we use website builder systems for our website?

The biggest advantage of a website builder system is its ease of use. We want to offer you a clear, simple, and uncluttered website that we can easily operate and maintain ourselves – without external support. A website builder system now offers many helpful functions that we can use even without programming knowledge. This allows us to design our web presence according to our wishes and offer you an informative and pleasant time on our website.

What data is stored by a modular website system?

What data is stored exactly depends, of course, on the website builder system used. Each provider processes and collects different data from the website visitor. However, as a rule, technical usage information such as operating system, browser, screen resolution, language and keyboard settings, hosting provider, and the date of your website visit are collected. Furthermore, tracking data (e.g., browser activity, clickstream activities, session heatmaps, etc.) may also be processed. In addition, personal data may also be collected and stored. This usually includes contact data such as email address, telephone number (if you have provided it), IP address, and geographical location data. What data is stored exactly can be found in the provider's privacy policy.

How long and where is the data stored?

We will inform you further down about the duration of data processing in connection with the website builder system used, if we have further information about it. You can find detailed information about this in the provider's privacy policy. In general, we only process personal data for as long as it is absolutely necessary for the provision of our services and products. It is possible that the provider stores data from you according to its own standards, over which we have no influence.

Right to object

You always have the right to information, rectification, and erasure of your personal data. If you have any questions, you can also contact the controller of the website builder system used at any time. Contact details can be found either in our privacy policy or on the website of the respective provider.

You can delete, deactivate, or manage cookies that providers use for their functions in your browser. This works in different ways depending on which browser you use. Please note, however, that not all functions may then work as usual.

Legal Basis

We have a legitimate interest in using a website builder system to optimize our online service and present it to you efficiently and user-friendly. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). However, we only use the builder insofar as you have given your consent.

Insofar as the processing of data is not absolutely necessary for the operation of the website, the data will only be processed on the basis of your consent. This applies in particular to tracking activities. The legal basis in this respect is Art. 6 para. 1 lit. a GDPR.

With this privacy policy, we have provided you with the most important general information regarding data processing. If you would like to find out more about this, you will find further information - if available - in the following section or in the provider's privacy policy.

Wordpress.com Privacy Policy

We use WordPress.com, a website builder system, for our website. The service provider is the American company Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA.

WordPress processes your data, among other things, in the USA. We would like to point out that, in the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks for the lawfulness and security of data processing.

As the basis for data processing by recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e., particularly in the USA) or for data transfers to them, WordPress uses so-called standard contractual clauses (= Art. 46 para. 2 and 3 GDPR). Standard Contractual Clauses (SCC) are model templates provided by the EU Commission and are intended to ensure that your data also complies with European data protection standards when it is transferred to and stored in third countries (such as the USA). Through these clauses, WordPress undertakes to comply with the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses, among other places, here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

The data processing agreements, which comply with the standard contractual clauses, can be found at https://wordpress.com/support/data-processing-agreements/.

You can find out more about the data processed by using WordPress.com in the privacy policy at https://automattic.com/de/privacy/.

Explanation of Terms Used

We always strive to write our privacy policy as clear and understandable as possible. However, especially with technical and legal topics, this is not always easy. It often makes sense to use legal terms (e.g., personal data) or certain technical terms (e.g., cookies, IP address). However, we do not want to use them without explanation. Below you will find an alphabetical list of important terms used that we may not have sufficiently addressed in the previous privacy policy. If these terms were taken from the GDPR and are definitions, we will also list the GDPR texts here and add our own explanations if necessary.

Consent

Definition according to Article 4 of the GDPR

For the purposes of this Regulation:

‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Explanation: Typically, on websites, such consent is obtained via a cookie consent tool. You are probably familiar with this. Whenever you visit a website for the first time, you are usually asked via a banner whether you agree to or consent to data processing. Most of the time, you can also make individual settings and thus decide for yourself which data processing you allow and which you do not. If you do not consent, no personal data about you may be processed. In principle, consent can, of course, also be given in writing, i.e., not via a tool.

Personal data

Definition according to Article 4 of the GDPR

For the purposes of this Regulation:

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Explanation: Personal data are therefore all data that can identify you as a person. These are usually data such as:

  • Name
  • Address
  • Email address
  • Postal address
  • Phone number
  • Date of birth
  • Identification numbers such as social security number, tax identification number, ID card number, or student ID number
  • Bank details such as account number, credit information, account balances, and much more.

According to the European Court of Justice (ECJ), your IP address also counts as personal data. IT experts can determine at least the approximate location of your device and subsequently you as the connection owner using your IP address. Therefore, storing an IP address also requires a legal basis within the meaning of the GDPR. There are also so-called "special categories" of personal data that are particularly worthy of protection. These include:

  • racial or ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • genetic data, such as data obtained from blood or saliva samples
  • biometric data (information about psychological, physical, or behavioral characteristics that can identify a person).
    Health data
  • data concerning sexual orientation or sex life

Profiling

Definition according to Article 4 of the GDPR

For the purposes of this Regulation:

‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Explanation: Profiling involves collecting various pieces of information about a person to learn more about them. In the web sector, profiling is often used for advertising purposes or for credit checks. Web and advertising analysis programs, for example, collect data about your behavior and interests on a website. This results in a special user profile, which can be used to target advertising to a specific audience.

Conclusion

Congratulations! If you are reading these lines, you have really "fought" your way through our entire privacy policy, or at least scrolled this far. As you can see from the length of our privacy policy, we do not take the protection of your personal data lightly at all.
It is important to us to inform you to the best of our knowledge and belief about the processing of personal data. In doing so, we not only want to tell you what data is processed, but also to explain the reasons for using various software programs. Generally, privacy policies sound very technical and legal. However, since most of you are not web developers or lawyers, we wanted to take a different linguistic approach and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. Therefore, the most important terms are explained in more detail at the end of the privacy policy.
If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you a pleasant time and hope to welcome you back to our website soon.

All texts are protected by copyright.

Source: Created with the Privacy Policy Generator by AdSimple

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