Privacy policy according to DSGVO

1. Basic

With this privacy policy, we inform you about the type, scope and purpose of the collection and use of personal data by the website operator TwoWings Privatstiftung, Hafferlstraße 7, 4020 Linz, Austria.

The website operator takes your data protection very seriously and treats your personal data confidentially and in accordance with the legal regulations. Since changes can be made to this data protection declaration due to new technologies and the constant further development of this website, we recommend that you read through the data protection declaration again at regular intervals.

The term "personal data" means all data that can be personally related to you. This includes, for example, name, address, e-mail addresses, and user behavior. With regard to the other terms, in particular the terms "processing" and "consent", we refer to the legal data protection definitions. Further definitions of terms can be found in Art. 4 DSGVO.

2. Name and address of the responsible person

The responsible person in the sense of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is the:

TwoWings Foundation

Hafferlstrasse 7

4020 Linz

3. Name and address of the data protection officer

The data protection officer of the responsible person is:

TwoWings Foundation

Jasmin Ettehadieh, MSc

Hafferlstrasse 7

4020 Linz

4. General information on data processing

Personal data processing scope

As a matter of principle, we process personal data of our users only insofar as this is necessary for the provision of a functional website as well as our contents and services. The processing of our users’ personal data is regularly carried out only with the consent of the user. An exception applies in those cases where obtaining prior consent is not possible for factual reasons and the processing of the data is permitted by legal regulations.

Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. Insofar as processing personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) lit. c DSGVO serves as the legal basis. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-mentioned interest, Art. 6 (1) f DSGVO serves as the legal basis for the processing.

Data deletion and storage period

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

5. Access data

We, the website operator or page provider, collect data about access to the website on the basis of our legitimate interest (see Art. 6 para. 1 lit. f. DSGVO) and store them as "server log files" on the website server. The following data is logged in this way:

• Visited website
• Time at the time of access
• Amount of data sent in bytes
• Source/reference from which you came to the site
• Browser used
• Operating system used
• IP address used

The server log files are stored for a maximum of 7 days and then deleted. The data is stored for security reasons, e.g., to be able to clarify cases of abuse. If data must be retained for evidentiary reasons, it is exempt from deletion until the incident has been finally clarified.

6. Reach measurement & cookies

This website uses cookies for pseudonymized reach measurement, which are transmitted to the user's browser either by our server or the server of a third party. Cookies are small files that are stored on your terminal device. Your browser accesses these files. The use of cookies increases the user-friendliness and security of this website.

Common browsers offer the setting option to not allow cookies. Note: It is not guaranteed that you will be able to access all functions of this website without restrictions if you make the appropriate settings.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: Google Analytics Opt-out Browser Add-on Download Page

Collection and processing of personal data

The website operator collects, uses and discloses your personal data only if this is permitted by law or if you consent to the collection of such data. Personal data is any information that can be used to identify you and can be traced back to you - for example, your name, e-mail address and telephone number.

You can also visit this website without providing any personal information. However, in order to improve our online services, we store (without personal reference) your access data to this website. This access data includes, for example, the file you requested or the name of your Internet provider. By anonymizing the data, it is not possible to draw conclusions about your person.

7. Handling of contact data

If you contact us as the website operator through the contact options offered (e.g., by form on the website or by e-mail), your information will be stored so that it can be used to process and respond to your request.

8. Dealing with comments and contributions

If you leave a post or comment on this website, your IP address will be stored. This is done on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO and serves our security as website operator: Because if your comment violates applicable law, we can be prosecuted for it, which is why we have an interest in the identity of the comment or post author.

9. Google Analytics

Due to our legitimate interests, this website uses the "Google Analytics" service for the optimization and analysis of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO the service "Google Analytics", which is offered by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). The service (Google Analytics) uses "cookies" - text files that are stored on your terminal device. The information collected by the cookies is usually sent to a Google server in the USA and stored there.

Google LLC is certified under the Privacy Shield agreement: Privacy Shield

IP anonymization is used on this website. The IP address of the user is shortened within the member states of the EU and the European Economic Area and in the other contracting states of the agreement. Only in individual cases is the IP address initially transmitted unabbreviated to a Google server in the USA and shortened there. This shortening eliminates the personal reference of your IP address. The user's IP address transmitted by the browser is not combined with other data stored by Google.

As part of the agreement on the order data agreement, which we as website operators have concluded with Google Inc., the latter uses the information collected to create an evaluation of website use and website activity and provides services associated with the internet use.

The data collected by Google on our behalf is used to evaluate the use of our online offering by individual users, e.g., to create reports on website activity in order to improve our online offering.

You have the option of preventing cookies from being stored on your device by making the appropriate settings in your browser. It is not guaranteed that you can access all functions of this website without restrictions if your browser does not allow cookies.

Furthermore, you can use a browser plug-in to prevent the information collected by cookies (including your IP address) from being sent to and used by Google Inc. The following link will take you to the corresponding plugin: Download-Seite für das Browser-Add-on zur Deaktivierung von Google Analytics

Alternatively, you can prevent Google Analytics from collecting data about you within this website by clicking on  this link. By clicking on the above link, you will download an "opt-out cookie". Your browser must, therefore, generally allow the storage of cookies for this purpose. If you delete your cookies regularly, you will need to click on the link again each time you visit this website.

Here you can find more information about the use of data by Google Inc:

• Wie wir Daten von Websites oder Apps verwenden, auf bzw. in denen unsere Dienste genutzt werden – Datenschutzerklärung & Nutzungsbedingungen – Google (Data collected from Google partners).
• https://adssettings.google.de/authenticated (Settings about advertisements displayed to you)
• Werbung – Datenschutzerklärung & Nutzungsbedingungen – Google (Use of cookies in ads)

You give your consent to data processing by Google Analytics by confirming the website's Consent Tool.

10. Google Maps

We integrate the maps of the service "Google Maps" of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices). The data may be processed in the USA. When using Google Maps, Google also processes and uses data about the use of the Maps functions by visitors to the websites. For more information on data processing by Google, please refer to Google's privacy policy at Datenschutzerklärung – Datenschutzerklärung & Nutzungsbedingungen – Google . There you can also change your settings in the Privacy Center so that you can manage and protect your data.

11. Newsletter

Description and scope of data processing

On our website there is the option to subscribe to a free newsletter. In doing so, the data from the input mask (including first name, last name, e-mail address) are transmitted to us by your consent when you register for the newsletter.

• E-mail address
• IP address of the calling computer
• Date and time of registration

In order to provide you with targeted information, we also collect and process information voluntarily provided on areas of interest, address, birthday and other fields, if applicable. For the processing of the data, your consent is obtained during the registration process and reference is made to this privacy policy.

As soon as you have registered for the newsletter, we will send you a confirmation e-mail with a link to confirm your registration. You can cancel your subscription to the newsletter at any time.

To do so, click on the unsubscribe link at the bottom of the newsletter.

Legal basis for data processing

The legal basis for sending the newsletter is your consent.

Purpose of data processing

The purpose of collecting the user's e-mail address is to deliver the newsletter.

Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. Accordingly, the user's e-mail address is stored for as long as the subscription to the newsletter is active.

Possibility of objection and removal

The subscription to the newsletter can be cancelled by the affected user at any time. For this purpose, a corresponding link can be found in each newsletter.

12. Rights of the user

As a user, you have the right to receive, upon request and free of charge, information about what personal data has been stored about you. You also have the right to have incorrect data corrected and to have your personal data processed restricted or deleted. If applicable, you may also exercise your right to data portability. If you believe that your data has been processed unlawfully, you may lodge a complaint with the relevant supervisory authority.

Deletion of data

Unless your request conflicts with a legal obligation to retain data (e.g. data retention), you have a right to have your data deleted. Data stored by us will be deleted if it is no longer required for its intended purpose and there are no legal retention periods. If deletion cannot be carried out because the data is required for permissible legal purposes, data processing will be restricted. In this case, the data will be blocked and not processed for other purposes.

13. Right of objection

Users of this website may exercise their right to object to the processing of their personal data at any time.

If you wish to correct, block, delete or obtain information about the personal data stored about you, or if you have any questions regarding the collection, processing or use of your personal data, or if you wish to revoke any consent you may have given, please contact us at the following e-mail address: office@twowings.com